Frequently Asked Questions About Product Review

OMRI Listed product suppliers must notify OMRI in writing 60 days prior to implementation of any Product Changes listed in the OMRI Policy and Standards Manual Section 2.9. Company or Product Change requests can be submitted electronically on the OMRI website here. Product Change Report Forms can be found when you log into the website and navagate to the Individual Forms and Checklists page in the right hand Applicant Menu. To request a product change during the initial product review, click here.

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.

If your product is a liquid fertilizer with a nitrogen analysis or label claim of greater than 3% nitrogen, the product must undergo one announced and one unannounced inspection annually. One announced inspection is conducted prior to the product being listed on the OMRI Products List and one unannounced inspection is conducted sometime in the first year after the product is added to the OMRI Products List. These two inspections will occur every year that the product 's OMRI Listing is renewed. OMRI requires a deposit of $3,000 annually to cover the cost of these inspections. The deposit generally covers the cost of the inspections and any amount paid over the cost of the inspection is refunded. For more information about inspections, please see the OMRI Policy and Standards Manual or contact OMRI.

In addition, random inspections are done on 1% of all OMRI Listed products annually. Most of these inspections are done as a stream of commerce sampling (buying the product and sending a sample into a lab), but can be done at a manufacturing facility as well. The random inspection is a part of OMRI’s ISO65 accreditation procedures and there is no additional cost for the inspection.

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 declare on their Checklist and Instructions if their final product or any of thier ingredients is or is not produced by Genetic Engineering. 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 146 -149 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.

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.

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.

1. 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.
2. 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.

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.

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.

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 order an application kit. 

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.

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. You would still list the growth media on the Total Ingredient List, but you would enter 0% in the amount column to indicate the growth media is completely removed from the final product. Water (or moisture) does not count as an ingredient while calculating the fee.

A multi-ingredient product has more than one ingredient in the final product. This means the Total Ingredient List will have two or more ingredients that are greater than 0% in the final product. For example, a blended fertilizer with blood and bone meals is a multi-ingredient product because the product contains multiple ingredients.

Each ingredient should be expressed on the Total Ingredient List provided in your Application Kit. There are examples of both single and multi-ingredient Total Ingredient Lists when you log into the website and navigate to the Individual Forms and Checklists page in the right hand Applicant Menu. There is also an example Compost Application on the Application Support Downloads page.

OMRI product review fees are based on the ingredients listed on the Total Ingredients List (or on the EPA CSF Form 8570-4 for pesticides). 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.

If a product undergoes a change in formulation as defined in the OMRI Policy and Standards Manual at §2.9.5 during the review process, the applicant is required to submit a Reformulation Fee of $215 and all documentation regarding the change. 

Other changes, such as changes to the product name or product label usually do not incur a fee. For an up to date list of all fee amounts, see the Review Cost page.

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.