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Call for comments: We welcome the feedback of the organic community. The standards board meets in December of each year to vote on any proposed changes. To contribute to the standards discussion, please send an email with thoughts for changes and improvements, to with the subject line Standards.

Real Organic Project respects the inspections conducted by MOFGA, NOFA-NY, OneCert, OEFFA, New Jersey DOA, and VOF for adhering to the soil fertility requirements of 205.203. As such, the inspections approved by these certifying agencies are a first step toward qualifying farms for Real Organic Project certification, assuming they complete the entirety of Real Organic Project certification process.

Our mission is to grow people’s understanding of foundational organic values and practices. We have created an add-on label to USDA certified organic to provide more transparency on these farming practices. USDA organic certification is a prerequisite to participate in the add-on program.

Real Organic Project is family farmer-driven and embraces centuries-old organic farming practices along with new scientific knowledge of ecological farming.  We believe that crops grown in soil and livestock raised on pasture-based systems are fundamental to organic farming.  Healthy soils equal healthy crops and livestock, which equal healthy people and a healthy climate.

The USDA has recently embraced hydroponics and has dropped the proposed rule on animal welfare. Many farmers now feel the USDA organic label no longer adequately reflects how we farm, and many in the organic community feel a loss of identity within the label. Our community worked for years to build an organic label that people can trust.

Much about the National Organic Program is a success, and most of the farms being certified deserve to be called real organic. But the farm products from a tiny minority of large industrial operations now being certified are at odds with the original intent of organic farming. Unfortunately, these few operations produce a large, and growing, proportion of the food labeled organic on the market today.

Organic Farming was defined back in its infancy as a farming method that is centered on maintaining fertile and biologically healthy soil. The Organic Foods Production Act (OFPA), and the resulting USDA/National Organic Program (NOP) Standards reflect this well. Section 205.203 of the National Organic Program Regulations does a fine job of describing soil management practices on an organic farm.

However, there is an issue. Even though the word “must” is used in the pertinent opening paragraphs of this section of the regulation, the NOP has allowed certifiers and their growers to ignore soil management if they (the certifier) think it is not applicable. Although we believe there are a handful of situations where soil is not required for production, traditional organic standards require soil for ALL production of plants to harvest.

Furthermore, it is the management of the soil that makes the farm system and land organic. In most instances, it is the land that gets certified and the farm creates a farm system plan to outline the practices that build soil health. The driving force behind the Real Organic Project is our belief that organic production standards should be based on the traditional organic guidelines of crops being grown in managed soil, with only a few, very clear exceptions explained below.

The ROP standards for soil management are the NOP standards stated in Section 205.203 of the NOP Regulatory Text, however the ROP standards honors the legal meaning of the word “must.” In section 205.203 the National Organic Program uses the word “must” because that is what is required by the law (the OFPA). Crop production that is not based on soil may be productive, safe, environmentally sound, etc., but it is not organic.

Two areas of the NOP soil management section need clarification. First is the misinterpreted section on managing livestock manure and composting guidelines. Second is the limited exceptions to the soil management requirement.


At the heart of soil husbandry on many organic farms is livestock manure. Livestock manure carries human pathogens and other contaminants. As a result, the NOP regulations require that manure must be handled in such a way that it does not “contribute to contamination of the crops, soil or water by plant nutrients, pathogenic organisms, heavy metals, or residues of prohibited substances.” In order to reduce the risk of food contamination from human pathogens, the NOP requires either a waiting period between application of manure and harvest of the organic crop, that it be applied to land producing non-food crops, or composting of the manure.

In Section 205.203(c)(2) in their regulation the NOP presents an example of how to make compost. This was misinterpreted by many growers and certifiers to be the only way to make compost. Recognizing this misinterpretation, the National Organic Standards Board (NOSB) convened two task forces that delivered comprehensive reports to the NOSB on compost (2002) and compost tea (2004). The NOSB then made a final recommendation to the NOP on compost, compost tea, processed manure, and vermicompost in November 2006.

The NOP concurred with the NOSB that the examples provided in § 205.203(c)(1-3) is not a finite list of acceptable plant and animal materials for use in organic production. For example, there are many other acceptable ways to make compost. Site-specific variation in feedstock materials, management practices, and production requirements dictate that organic producers exercise flexibility in managing plant and animal materials on their operations.

On July 22, 2011 a Guidance from the NOP went into effect (NOP 5021 – Compost and Vermicompost in Organic Crop Production). This is presented in the Appendix.