Frequently Asked Questions About Product Review
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About OMRI
What is OMRI's shipping address for sending materials by private courier services like UPS?
If you're using a private courier service, such as FedEx or UPS, send your application to:
Organic Materials Review Institute
2495 Hilyard Street, Suite "B"
Eugene, OR 97405-3698 USA
Where can I get more information on organic food production?
These are the most important sources of information:
You can also check our list of OMRI Certifying Subscribers.
Why is OMRI not USDA accredited as an organic certifier?
OMRI is unique. Although we are a certifier, we are not an organic food/fiber/feed certifier. Therefore, we are not eligible for accreditation by the USDA. Instead, OMRI has recently achieved ISO accreditation. The audit and accreditation was coincidentally done by the USDA (actually the Audit, Review and Compliance Division). USDA auditors confirmed that OMRI solely uses the National Organic Program Rule.
However, while ineligible for USDA organic certifier accreditation, the National Organic Program has recently acknowledged our vital role. A March 5, 2008 memo published on the NOP website explains this to the accredited certifiers and the public.
Application Questions
How should I present my completed application packet to OMRI?
When putting together your completed application packet to send to OMRI for review, please DO NOT use staples, binders, dividers or page protectors. We store all files in locked, confidential file cabinets. OMRI staff must remove all of these extraneous items for the application materials to fit.
Simply place all of your application materials in an envelope, in an orderly fashion. Include a cover letter with any necessary explanations or comments.
If you are using public mail service, send your application to: Organic Materials Review Institute PO Box 11558 Eugene, OR 97440-3758
If you are using a private courier service, such as FedEx or UPS, send your application to: Organic Materials Review Institute 2495 Hilyard Street, Suite "B" Eugene, OR 97405-3698 USA
Are there any products that OMRI will not review?
OMRI reviews input products and does not review devices. Devices are considered to be out of the scope of OMRI's Review Program.
OMRI’s Review Program routinely encounters difficult technical issues for which it consults industry experts for guidance and interpretation of the NOP Rule. When a product review has an issue that is outside of OMRI’s or the NOP’s current written standards, OMRI’s policy is to place the product under “unresolved” status for a maximum of 275 days while OMRI gathers evidence to help guide the review. If OMRI is unable to resolve the issue within the given timeframe, it forfeits the application and returns the application fees to the applicant. In certain cases where interpretation is needed from the NOP before making a decision, OMRI designates an unresolved issue as “Beyond Resolution,” and no longer accepts applications that pertain to the particular issue.
OMRI has identified two issues that are currently Beyond Resolution. Please see the relevant information below to determine if your product may be related before applying to OMRI.
ISSUE #1: Soy Protein Isolate
Class: CF
Soy protein isolated using a synthetic acid that is not on the National List of allowed synthetics at §205.601. The National Organic Standards Board (NOSB) has not determined whether this type of isolation causes a chemical change to the soy protein such that the isolate would be considered synthetic or not.
ISSUE #2: Passive pheromone dispensers
Class: CP
Passive pheromone dispensers are eligible to use List 3 inert ingredients under 7 CFR 205.601(m). The definition is generally considered to include twist ties, ropes, coils and other retrievable dispensers where the active pheromone is not in contact with the crop. It is unclear if formulations that are applied to the crop and are not possible to retrieve are passive pheromone dispensers.
Can I use Genetically Modified Organisms (GMO) in my product?
OMRI refers to the U.S. National Organic Standards Board definition of genetic engineering at Title 7 Part 205.105 (e) and 205.2 Excluded Methods for review of input materials and processes:
"Directly produced products or ingredients derived from genetic engineering techniques, cannot be made otherwise, and have a potential to express the trait that has been added by such techniques. Genetic engineering includes a variety of methods used to genetically modify organisms or influence their growth and development by means that are not possible under natural conditions or processes and are not considered compatible with organic production. Such methods include cell fusion, micro- and macro encapsulation, and recombinant DNA technology (including gene deletion, gene doubling, introducing a foreign gene, and changing positions of genes when achieved by recombinant DNA technology). Such methods do not include traditional breeding, conjugation, fermentation, hybridization, in vitro fertilization, or tissue culture."
All applicants must submit a Genetic Engineering, Ionizing Radiation and Sewage Sludge Declaration to OMRI for the final product and each ingredient. In most circumstances, the use of genetically engineered organisms or their products are prohibited in any form or at any stage in organic production, processing, or handling. The final input product for use in organic production, processing or handling must not contain any genetically modified organisms.
When specific criteria are met, a GE material is reviewed as non-GE material and may be allowed for use in OMRI Listed products. To address questions about Excluded Methods (GE), OMRI has designed Decision Tree Flowcharts for GE in Crops, Livestock and Processing on pages 144 -151 of the OMRI Policy and Standards Manual. Please see the Decision Tree Flowcharts for questions about the use of GE materials in OMRI Listed Products. Suppliers receive a copy the OMRI Policy and Standards Manual when they order an application kit.
Do I need to know the manufacturing process for all of my ingredients?
If the ingredient is nonsynthetic, you will need to submit a manufacturing process for it. OMRI requires a description of the manufacturing process for every ingredient submitted as nonsynthetic in order to determine that it is nonsynthetic. Please be sure that you know the manufacturing process for an ingredient before you apply. You will not need to know the manufacturing process for any permitted synthetic ingredients. To find out whether a synthetic substance is permitted for your product, see the Generic Materials List within the OMRI Policy and Standards Manual.
How can I get my product listed?
We have a whole page dedicated to that very topic...
How do I determine whether my product/ingredient is synthetic or nonsynthetic?
The USDA organic regulations define synthetic as such:
A substance that is formulated or manufactured by a chemical process or by a process that chemically changes a substance extracted from naturally occurring plant, animal, or mineral sources, except that such term shall not apply to substances created by naturally occurring biological processes.
The task to determine whether something is synthetic can be very technical. We recommend these steps to help you decide whether a substance is synthetic.
- Look for your substance in the Generic Materials List within the OMRI Policy and Standards Manual. This list specifies whether synthetic or nonsynthetic versions of those substances exist and whether they are permissible for use in organic agriculture or food processing. We present the Generic Materials List in three sections: CROPS, LIVESTOCK, and PROCESSING & HANDLING based on the intended use of a product. Be sure to search in the appropriate section based on the intended use of your product.
- If you do not find the substance in the appropriate section of the Generic Materials List, then turn to pages 142–143 of the OMRI Policy and Standards Manual and read section 10.1.1 Synthetic versus Nonsynthetic Determination and review Figure 1: Proposed Decision Tree to Distinguish Synthetic and Nonsynthetic Substances.
OMRI policy prevents our staff from providing specialized advice to any individual or company. However, if you have a question about whether a particular substance is synthetic and it is not answered by using the OMRI Policy and Standards Manual, then please contact us. Please keep in mind that OMRI may not be able to determine whether a particular substance is synthetic without reviewing your complete application.
How much does the review cost?
We have entire page dedicated to this topic as well. Please see the Review Cost page.
I have already ordered the Application Kit. How can I receive extra copies of the application forms?
If you have already completed the Pre-Application Form and submitted it us, you should have received a hard copy Application Kit with the necessary forms and checklists and the OMRI Policy and Standards Manual in the mail. You also received a username and password that gives you access to these documents on the OMRI website. If you are having trouble accessing these documents, please let us know.
If you are interested in applying for the first time, please read this page.
Is there a list of consultants who can help with the application and continuing work?
While OMRI does not endorse or recommend any particular consultant, we have compiled a partial list of the consultants with some experience preparing OMRI applications. Find this list here.
One of my ingredient suppliers is not willing to provide me with information on their manufacturing process. How can I move forward?
OMRI has a system for handling confidential information from third parties. A third party confidentiality agreement allows an ingredient supplier to send proprietary information directly to OMRI. Only the third party and OMRI will be able to view this information and OMRI will protect this information as it does any confidential information. Please contact OMRI for a copy of our agreement. OMRI must receive a third party confidentiality fee of $190.00 and the completed agreement before the third party information is submitted. The third party confidentiality fee is subject to yearly renewal fee of $114.
Should I send a sample of my product?
Please do not send samples of the product, as we do not have laboratory resources available to analyze products. However, some products require official laboratory analysis to be submitted with the application.
For help locating a lab to do the analysis, see the Partial List of Analytical Labs that OMRI has put together.
What are the OMRI Standards?
OMRI publishes the OMRI Policy and Standards Manual, which contains standards for products intended for use in certified organic production or processing under the USDA National Organic Program. We base these standards on the USDA regulations for organic agriculture (7 CFR part 205—also called the NOP Rule). Suppliers receive a copy of the OMRI Policy and Standards Manual when they oder an application kit.
What is a “single ingredient” product?
Only products that contain a single substance in the final product are single ingredient products. For example, a microbial product composed of a single microorganism without any media in the final product is a single ingredient product. A blended fertilizer with blood and bone meals is not a single ingredient product because the product contains multiple ingredients. Water (or moisture) does not count as an ingredient while calculating the fee.
OMRI product review fees are based on the ingredients. If your product is submitted with a payment for a single ingredient product review and the product is considered multi-ingredient, the review will not begin until full payment is received. If you overpay, OMRI will refund the difference. If you have any questions, please contact OMRI.
What is an OMRI Category?
An OMRI Category, or Listing, is a general category of materials used in organic crop production, food processing, and livestock production. The specific categories used by OMRI are published as the OMRI Generic Materials List, and are contained within the OMRI Standards Manual. Each product listed in the OMRI Products List must have a category listing. When applying for a product to be listed by OMRI, choose the one material listing that best fits your product.
What is an OMRI Class?
An OMRI Product Use Class is the classification for which you want OMRI to review your product. The OMRI Class groups materials into several distinct end-use classes. You will fill out a checklist specific to the Class you are applying for.
The full list of OMRI Product Use Classes is:
Crop Fertilizer or Soil Amendment (CF)
Crop Pest, Weed, or Disease Control (CP)
Crop Management Tool or Production Aid (CT)
Livestock Feed Ingredient (LF)
Livestock Health Care (LH)
Livestock External Parasiticide or Pesticide (LP)
Livestock Management Tool or Production Aid (LT)
Processing Agricultural Ingredient or Processing Aid (PA)
Processing Non-agricultural Ingredient or Processing Aid (PN)
Processing Pest Control (PP)
Processing Sanitizer or Cleaner (PS)
Processing Container and Packaging Material (PC)
For more information on the OMRI Product Use Classes, see the OMRI Generic Materials List, which is also contained in Part 9 of the OMRI Policy and Standards Manual.
What laboratory tests are required for my product?
The type of testing varies greatly depending on the product to be reviewed. Testing for fecal coliform and Salmonella, Heavy Metals, and Nutrient levels may be required. For information on which tests are required, see the applicable checklist in your application packet. For help locating a lab to do the analysis, see the Partial List of Analytical Labs that OMRI has put together.
Lab analysis reports must be labeled in a way that is consistent with the product name, declare the methods and units used, and be less than a year old.
Will OMRI securely guard the confidentiality of my formula and ingredient sources?
Yes, OMRI takes the matter of confidential business material very seriously. OMRI policies on confidential information are outlined in section 1.6.1 of the 2010 OMRI Policy and Standards Manual. Confidential materials are clearly separated from public materials (Supplier Application Form and Product Application Form), and never released to the public for any reason.
The OMRI Review Panel, the committee deciding on the status of products, only reviews confidential information during a Review Panel meeting. The Review Panel members have explicit instructions to destroy all confidential information shortly after the meeting.
During Review
What are OMRI review standards for compost products?
All compost products must meet general review requirements as described in the OMRI Policy and Standards Manual and in the application materials you receive with your application kit. Specific requirements for compost are listed on pages 80-81 of the OMRI Policy and Standards Manual. If you do not have a copy of this manual, use the online Generic Materials List search. Follow the link and enter “compost” in the Search Generic Materials box. You may also see the table below for a quick comparison between compost categories.
All compost must meet the same pathogen and heavy metal requirements. Composts which have levels above the pathogen threshold will be listed as Allowed with Restrictions in the Category: Manure-raw. Composts which do not meet the heavy metal requirements may receive a caution statement or may not be eligible for OMRI Listing [For information about maximum allowable levels of pathogens or heavy metals see Review Standards for Lab Analyses or contact OMRI].
A complete Sample Compost Application is available for your reference. Once you click on the link, scroll to the bottom the page and click on the Sample Compost Application PDF.
| Table of Compost Categories for Comparison | |||||
| OMRI Listed Category | OMRI Listed Status | Feedstocks | Time at Temperature 131-170°F | Turning Frequency | C:N Ratio of initial uncomposted feedstocks
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| Compost – in-vessel or static aerated pile (plant and animal materials)
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Allowed | Plant and/or animal materials | 3 days | n/a | Between 25:1-40:1 |
| Compost – windrow | Allowed | Plant and/or animal materials | 15 days | 5 times in 15 days | Between 25:1-40:1 |
| Compost – plant materials | Allowed | Plant materials only | 3 days | Periodic | n/a |
| Compost – other | Allowed | Plant and/or animal materials | 3 days | Periodic | n/a |
How can I expedite my application?
The best way to have your application reviewed quickly is to submit a complete application with all forms correctly completed and all supporting documentation for the final product and each ingredient as specified in the checklist. OMRI does not provide expedited service; complete applications are processed as quickly as possible in the order in which they are received. Applicants are encouraged to contact OMRI prior to submitting their application packet to confirm that the application is complete.
How does OMRI determine whether synthetic growth media is allowed for use in the production of microbial products?
For microbial products with synthetic growth media remaining in the final product, the compliance of the media is dependant on the intended use of the product. For pesticides, all synthetic media that appear in the final product are allowed if they are defined as allowed inert ingredients on the National List. For livestock feed ingredients, processing ingredients and processing aids, any agricultural substances used as growth media that remain in the finished product must be certified organic. Synthetic livestock minerals used as microbial growth media and identified in Appendix A of the OMRI Policy and Standards Manual may remain in the finished product for products within the Livestock Feed Ingredient class only.
How long does the review take?
The length of time for a product to complete the review process varies on the type of product. OMRI does not guarantee the length of time needed to complete a review of an application. Re-packaged product applications and Product Changes can be reviewed as quickly as two months. The average review time for new product applications is six to nine months or less if the application is complete. Incomplete applications often take longer than the average.
While OMRI does not guarantee of the length of time it will take to review an application, OMRI staff will make every effort to advance the review as quickly as possible. The single most important factor in determining how long the review will take is whether the application arrives with all the required information.
What are OMRI policies for product labeling?
We have a whole section of the OMRI Policy and Standards Manual describing this very topic. To summarize, OMRI will not list a product if it finds that a product‘s label provides false or misleading information to potential users. Any nutrient claims made on the label must be supported by verifiable lab analysis. Additionally, OMRI has strict policies for using the term organic on product labels.
Please see pages 16-17 of the 2010 OMRI Policy and Standards Manual, §2.7 for more information.
What do I need to submit to OMRI if I want to change my product during its initial review?
If a product undergoes a change in formulation during the initial review process, the applicant is required to submit a new application fee and all documentation regarding the new ingredient, formulation, manufacturing process, and/or other changed component. See Section 2.9.5 of the OMRI Policy and Standards Manual for a list of applicable product changes regarding formulation or manufacturing.
For example, if an applicant changes a multi-ingredient product to a single ingredient product during review, the applicant must submit a product reformulation fee for a single ingredient product application ($190). If an applicant changes a multi-ingredient product by changing one of the ingredients, the applicant must submit product reformulation fee for a multi-ingredient product application ($580). The information needed to complete your application will be requested once the new fee has been paid. For more information about fees see Review Cost page.
Other changes, such as changes to the product name or product label usually do not incur a fee. See Section 2.9 of the OMRI Policy and Standards Manual for details.
What is the difference between the OMRI status of "Allowed" (A) and "Allowed with Restrictions" (R) on the OMRI Products List?
OMRI assigns a status of Allowed with Restrictions to products that contain one or more ingredients that are allowed with restrictions on the OMRI Generic Materials List. Allowed products are composed solely of ingredients listed on the OMRI Generic Materials List as allowed. All products must be used as directed on their labels. While Allowed products may be used in certified organic production, Allowed with Restrictions products may be used only for certain uses, or only under specific documented conditions.
OMRI considers materials Allowed with Restrictions when the substance is listed with a restriction on the National List, or there is a restriction described in the text of the USDA National Organic Program Rule. Some Allowed with Restrictions materials may be used only after preferred alternatives were attempted and their use is documented in the Organic System Plan. Both Allowed synthetic and Prohibited nonsynthetic materials that appear on the National List may have annotations that limit their use. Some materials may be used only from a specific source or if the material is free from contamination by prohibited substances. Check with the certification agency for policy regarding material evaluation and usage restrictions as certifiers may not allow use of an Allowed with Restrictions material if it does not comply with regulations for that material's usage.
What is the OMRI process for reviewing applications?
OMRI processes complete applications in the order in which they are received, assigning a reviewer each time a new review starts. This person will be your contact for any questions you have about the progress of your product application.
The reviewer prepares a summary and a recommendation for the application as soon as it is determined to be complete. The OMRI Review Panel—a national board of experts from the organic industry—studies the summary and recommendation and votes on a product's status or requests more information. Products that comply are given an "Allowed" or "Allowed with Restrictions" status and are added to the OMRI Products List. Your reviewer will notify you within 12 business days after the Review Panel completes their decision-making process.
When the decision is to accept the application, OMRI issues a certificate and an approval letter. Also, OMRI will post your product on our website and in our quarterly supplement to the OMRI Products List. Every January, we print the OMRI Products List, which will include your product if it has been approved. Finally, the OMRI Listed® Seal is licensed to your company for use in association with the product.
Post Review
Can I call my product "certified organic" once approved?
No. The term "certified organic" is reserved for food and fiber products that meet the USDA National Organic Program production standards. Organic operators look for the OMRI Listed® Seal because it assures them the product has passed OMRI expert review for use in organic production.
The reason lays in a basic understanding of two different types of certification offered in the organic industry. The first type is for the foods, fibers, and feeds. These products are eligible to be called "Certified Organic" and carry the USDA's seal for organic products. The second type is for the products used to grow or produce organic foods, feed, or fibers. They include substances such as fertilizers, pesticides, and other materials used on the farm or in the food processing facility. They are not eligible to carry the USDA seal or be called "certified organic." These types of products are either allowed or not allowed for use in organic agriculture or food processing.
Because the job of determining whether the inputs are allowed can be a tough one, OMRI has dedicated itself to the task exclusively. This means that OMRI reviews and approves material inputs to organic agriculture to determine whether they are allowed under US organic rules. If they are, then OMRI assists with the promotion of those inputs by licensing our seal of approval, OMRI Listed®, and includes them in our directory viewed and trusted by thousands of organic farmers and gardeners throughout North America.
How do I maintain my product listing?
Annual Renewal Suppliers need to renew product and supplier listings and submit renewal fees annually to remain on the OMRI Products List. The annual renewal process ensures that OMRI Listed products continue to meet OMRI Standards and allows OMRI to maintain accurate listing information.
Three Year Reviews OMRI Listed products undergo a full periodic re-review once every three years. Three year reviews are conducted according to the same procedures for new product reviews, except that no product review fee is charged. Three year reviews are currently on hold until further notice.
Notification of Company and Product Changes OMRI Listed product suppliers must notify OMRI in writing 60 days prior to implementation of any Product Changes in the OMRI Policy and Standards Manual Section 2.9. Company or Product Change Report Forms are provided to each OMRI Listed Supplier with their annual renewal packet and are available on the OMRI website at www.omri.org/suppliers/forms.
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