WIMAUMA, Fla. — If you are using or are considering using containers in a certified organic system, be aware of policy changes that will impact your record keeping practices and may impact your certification status. On June 3, the USDA notified accredited organic certifying agents of a clarification to the rules covering certification of organic container production. Prior to June 3, it was possible for container operations to be certified organic even if the underlying soil may not necessarily pass organic certification. Containers were considered an independent system because they did not include the location’s soil for crop production. Crops produced in pots filled with soilless media (such as pine bark and compost) on landscape fabric would be an example of this type of system. Now, after June 3, containers and soil are no longer mutually exclusive. Basically, both soil and containers need to be certified. The clarified rule states:
“the legal requirements related to the three-year transition period apply to all container systems built and maintained on land.”
In other words, the National Organic Program (NOP) views containers as an extension of the soil. If the soil would not meet the criteria for organic certification, then the container will not meet the criteria either.
Certifiers are instructed to assess land use histories for container system sites in the same way that an in-ground system is assessed. If the land on which the container production system is situated has had any prohibited substances applied, then the container system cannot be certified as organic until three years have passed between the last such application and the first harvest. Also, following certification, no prohibited substances may be applied anywhere in the system, including on the underlying land. This clarification is not retroactive to operations and sites that were certified prior to the issuance of the USDA notification. A copy of the USDA memo is included below.
–Doug Phillips, UF/IFAS