Frequently Asked Questions About Product Review
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What is the difference between the OMRI Products List and the OMRI Generic Materials List?
The OMRI Products List consists of individual products sold by suppliers that have undergone the OMRI review process and have been found to conform to the National Organic Program Standards. This list can be searched online, downloaded from our website and is also available as a printed publication.
The OMRI Generic Materials List is a list of generic materials describing whether and how each material complies with the National Organic Standards. The Generic Materials List is divided into three main sections: Crop, Livestock and Processing. Within these three sections, products are further separated into Use Classes:
Crop Fertilizer and Soil Amendments (CF)
Crop Management Tools and Product Aids (CT)
Crop Pest Weed and Disease Control (CP)
Livestock Feed Ingredients (LF)
Livestock Health Care (LH)
Livestock External Parasiticides and Pesticides (LP)
Livestock Management Tools and Production Aids (LT)
Processing Agricultural Ingredients and Processing Aids (PA)
Processing Non-agricultural Ingredient and Processing Aid (PN)
Processing Pest Controls (PP)
Processing Sanitizers and Cleaners (PS)
Processing Container s and Packaging Materials (PC)
Finally, within each Use Classes there are the Generic Material Categories. Products that are reviewed and listed on the OMRI Products List under a specific use Class and Generic Material Category.
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
2649 Willamette Street
Eugene, OR 97405-3134 USA
Where can I get more information on organic food production in the United States?
Why is OMRI not USDA accredited as an organic certifier?
Agricultural products that are outputs of organic farms or processors (such as foods, fibers and feeds) can be USDA “certified organic.” Most input products (such as fertilizers, pesticides, additives, etc.) are ineligible for organic certification. However, inputs must be approved prior to use on a certified organic operation. OMRI reviews input products to verify that they meet the organic standards for use on organic farms or in organic processing. OMRI is recognized by the USDA NOP as a reputable 3rd party input reviewer in Policy Memorandum 11-4 in the NOP Handbook. In addition, OMRI is accredited under the International Organization for Standardization (ISO) Guide 65 by the USDA Grading and Verification Division. USDA auditors confirm on an annual basis that OMRI adheres to the policy and standards set forth in the OMRI Policy and OMRI Standards Manuals, and by the U.S. organic standards. OMRI Listed products can use language such as “for organic use” or “for organic production” to communicate compliance with organic rules.
Does my product qualify as a Repackaged Product?
If you would like to sell an OMRI Listed product under a different product or company name and you are not modifying the original OMRI Listed product in any way (including adding water), your product may qualify as a Repackaged Product. To be considered a Repackaged Product, you must hold the original OMRI listing, or purchase the product directly from the OMRI Listed supplier or an authorized distributor. Your product would also need to be listed in the same OMRI Class as the original product.
Does OMRI have an expedited application process?
No. The best way to have your application reviewed quickly is to submit a complete application. This includes submitting completed forms and all supporting documentation for the final product and each ingredient as specified in the Application Kit. Complete applications are processed as quickly as possible in the order in which they are received. Applicants are encouraged to contact the OMRI Application Specialist at (541) 343-7600 X 105 or at email@example.com prior to submitting their application packet to confirm that the application is complete.
How should I present my completed application packet to OMRI?
OMRI prefers emailed applications. However we also accept applications that are mailed or faxed. If you do choose to mail your application please DO NOT use staples, binders, dividers or page protectors. We scan all documents into our database and store all files in confidential file cabinets. OMRI staff must remove all of these extraneous items for the application materials to be scanned and to fit in the cabinets.
Whether you are submitting by email, fax or mail be sure to include all applicable items as indicated by the Checklist and relevant Product Report from your Application Kit. Include a cover letter with any necessary explanations or comments.
• To submit your application electronically, simply attach the cover letter and all applicable documents (either as a single document or as multiple separate attachments) to your email. Send your application packet electronically to firstname.lastname@example.org. You can make a payment via PayPal or by credit card when you login to your account on the OMRI website or you may use the Payment Form included in the Application Kit. You can also contact the OMRI Administrative Specialist at (541) 343-7600 ext. 100 to submit payment over the phone.
• Using public mail service (USPS), send your application to: Organic Materials Review Institute PO Box 11558 Eugene, OR 97440-3758
• Using a private courier service, such as FedEx or UPS, send your application to: Organic Materials Review Institute 2649 Willamette Street, Eugene, OR 97405-3134 USA
I have already ordered the Application Kit. How can I receive extra copies of the application forms?
If you have already ordered an Application Kit, you will have received a user name and password in an email. If you also requested a hard copy Application Kit you should have received it in the mail as well.
Additional forms and checklists can be found on the Individual Forms and Checklist link located in the right hand Applicant Menu available when you log into the website. In addition the OMRI Policy Manual and OMRI Standards Manual can be found using the Manuals and Review Standards link, also located in the right hand Applicant Menu. If you are having trouble accessing these documents, please contact OMRI.
If you need additional forms mailed to you, please download and fill out the Application Kit Order Form.
Is there a list of consultants who can help with the application to OMRI?
While OMRI does not endorse or recommend any particular consultant, we maintain a list of consultants that have interest in helping with OMRI applications. Many have helped or have been involved in submitting applications to OMRI in the past. You may find the list of consultants here.
One of my ingredient suppliers is not willing to provide me with information about their formula or manufacturing process. How can I move forward?
OMRI has a system for handling confidential information from third parties. A Third Party 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 $215.00, and the completed agreement, before the third party information is submitted. The Third Party Agreement is subject to a yearly renewal fee of $130.
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 them. However, OMRI may require official laboratory analysis to be submitted with the application for some product types. The Product Report form included in the Application Kit will indicate whether lab analysis is required. When this is the case, you will need to send your product to a reputable third party laboratory to have the analysis performed.
For help locating a lab to do the analysis, see the Partial List of Analytical Labs that OMRI maintains.
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. Examples include “potting soil,” “fish meal” and “salt.” The specific categories used by OMRI are published as the OMRI Generic Materials List, searchable online, or in the OMRI Canada Standards Manual for review to Canadian Organic Standards .and are included within the OMRI Standards Manual (and addendum), and are searchable online. Products are listed in the OMRI Products List according to their category. When applying for a product to be listed by OMRI, choose the one material listing that best fits your product. Categories are a useful way for buyers to find a specific type of product.
What products are required to undergo an inspection?
OMRI performs three different types of inspections- High Nitrogen Liquid Fertilizer (HNLF) inspections, For-cause inspections and Random surveillance.
If your product is a High Nitrogen Liquid Fertilizer (defined as 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 per USDA policy. 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 an annual fee of $3500 for a new product and $1500 for repackaged products to cover the cost of these inspections. For more information about the cost of these inspections see the Review Cost webpage. More information about inspections can be found in the OMRI Policy Manual or you are welcome to contact us at (541)343-7600.
Additionally, For-cause inspections and/or stream of commerce sampling may be conducted when there is cause to do so. More information about these types of inspections is available in the OMRI Policy Manual section §5.2.
Finally, random surveillance is preformed on 1% of all OMRI Listed products annually. Random surveillance consists of either stream of commerce sampling (buying the product and sending a sample into a lab for analysis), or through an inspection at the manufacturing site. Random surveillance is a part of OMRI’s ISO accredited procedures, and there is no additional cost for these tests or inspections.
Are laboratory tests are required for my product?
Lab results are only required with applications for listing in the Use Classes “Crop Fertilizers and Soil Amendments” or “Crop Management Tools and Production Aids.” Required tests must be included with the application and may include Fecal coliform and Salmonella, Heavy Metals, and Nutrient levels. OMRI now requires N-P-K test results for all applications in the Crop Fertilizer and Soil Amendments class. Other specific categories, such as acid stabilized liquid fish products, require pH testing, while processed manure products require moisture level tests. For information on which tests are required, see the Product Report-Crop form in your application packet. The Review Standards for Lab Analyses sheet also provides specific information about acceptable results and how results should be reported.
If you need further clarification, please call OMRI’s Application Specialist at (541) 343-7600 x105. For help locating a lab to do the analysis, see the Partial List of Analytical Labs that OMRI maintains.
Lab analysis reports must be labeled in a way that is consistent with the product name, include the methods and units used, and must be less than a year old.
Are there any products that OMRI will not review?
OMRI reviews input products for use in organic crop, livestock and processing production. However, some input products may be considered out of OMRI's scope for various reasons. Here is a list of product types that are considered to be out of scope for OMRI to review:
- Machines or other types of devices.
- Products that are not relevant to the organic standards, for instance products that are intended for aquaculture systems, bug spray for humans, or beauty care products. A product such as cat litter would be considered out of scope unless the label had a specific agricultural use that complies with the organic regulations.
OMRI’s Review Program routinely encounters difficult technical issues for which industry experts are consulted for guidance and interpretation of the organic standards. When a product review has an issue that is outside of OMRI's or other 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, the application is forfeited and OMRI will refund the application fees. In certain cases where interpretation is needed from the NOP or another regulatory body before making a decision, OMRI designates an unresolved issue as “Beyond Resolution,” and will no longer accept applications that pertain to that particular issue until the issue becomes resolved by the NOP or another applicable regulatory body.
The following are current issues that OMRI considers to be Beyond Resolution:
ISSUE #1: Soy Protein Isolate
Use Class: Crop Fertilizers and Soil Amendments (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 or not this type of isolation causes a chemical change to the soy protein such that the isolate would be considered synthetic.
ISSUE #2: Passive pheromone dispensers
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 may be considered passive pheromone dispensers.
Can I use Genetically Modified Organisms (GMO) in my product?
OMRI refers to the U.S. National Organic Standards definition of genetic engineering at Title 7 Part 205.105 (e) and 205.2 Excluded Methods for review of input materials and processes. Ingredients that meet this definition are not allowed in OMRI Listed products or in certified organic production:
"Directly produced products or ingredients that are 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 Product Report form (included in the Application Kit) whether their final product or any of its ingredients are produced by genetic engineering (GE). In most circumstances, the use of genetically engineered organisms or products of genetically engineered organisms are prohibited in any form or at any stage in organic production, processing, or handling.
When specific criteria are met, a GE material is reviewed as a 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 in the OMRI Standards Manual. Please see the Decision Tree Flowcharts for questions about the use of GE materials in OMRI Listed products. Applicants receive a copy of the OMRI Policy and Standards Manual with their Application Kit.
Do I need to know the manufacturing process for all of my ingredients?
Generally, if an ingredient is nonsynthetic, you will need to submit a manufacturing process that verifies the nonsynthetic nature of the ingredient. You do not need to submit the manufacturing process for any permitted synthetic ingredients or any currently OMRI Listed® products. If you are required to submit a manufacturing process and can not get this information from the manufacturer, OMRI and the manufacturing company may enter into a third party agreement where the manufacturer may share that information directly with OMRI to preserve confidentiality.
How can I get my product listed?
We have a whole page dedicated to that very topic...
How do I determine whether my product or ingredient is synthetic or nonsynthetic?
The USDA National Organic Standards define synthetic as follows:
"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."
Determining whether a substance is synthetic can be a very technical task. OMRI recommends following these steps to help you determine whether a substance is synthetic:
- Search for your substance in the OMRI Generic Materials List online, or in the printed copy. (if you are using the printed version be sure to check the OMRI website for the any updates). The Generic Materials List specifies for each substance whether synthetic or nonsynthetic versions of the substances are permissible for use in organic agriculture or organic food processing. The OMRI Generic Materials List is organized into three sections based on the product's intended use: CROPS, LIVESTOCK, and PROCESSING & HANDLING. Look for the “Use Class” that is specific to your products intended use.
- If you do not find the substance in the appropriate section of the OMRI Generic Materials List, or if you are still unsure whether your particular ingredient/product would be considered synthetic, look at the National Organic Program's website for the "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 OMRI's appliation resources, 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.
What are OMRI's policies for product labeling?
OMRI policies for product labeling are described in §2.7 and §4.2.2 of the OMRI Policy Manual. Here are some tips...
- Company and product name on the label (or in bulk sales documentation) must match the information submitted on the application materials and listed on the OMRI Products List.
- The terms "USDA Organic," "certified organic," and "NOP organic" cannot be used unless the product is a food or fiber that is certified organic by an accredited certification agency. In all cases, the phrases "for organic use" and "for organic production" are permitted on OMRI Listed products. See the table below for specific rules.
- Processing Sanitizers and Cleaners (Class PS) products which contain any ingredient that is not on the National List of allowed nonagricultural substances at 205.605 must provide product users with use instructions (on product label or other information conveyed with the sale of the product) which include demonstrably effective methods to prevent contact between organic food and prohibited substance. Such instructions should include dilution and application rates and intervening events as applicable.
Specific rules for using the term "organic" on labels for products in the following classes identified by their two letter code in this table, the following rules should be observed:
|CF, CT, LT, LH, PS, PN||None beyond the general rule noted in the OMRI Policy Manual section 2.7.1.|
|CP, LP, PP||Must conform to rules promulgated under the Federal Insecticide, Fungicide and, Rodenticide Act and specifically PR Notice 2003-1 for products used in the USA only.|
|LF, PA, PN||"Organic" is permitted with proof of relevant organic certification on the final product|
What are the OMRI Standards?
OMRI publishes the OMRI Generic Materials List with the OMRI 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 National Organic Standards). A separate OMRI Canada Standards Manual is available for review to Canadian Organic Standards. Suppliers receive a copy of the OMRI Generic Materials List with the OMRI Standards Manual when they order an Application Kit.
What is an OMRI Class?
Classes are part of the OMRI classification system that groups products with similar end use attributes. This helps to determine which standards are applied when reviewing the product for organic use and assists buyers in finding appropriate products. Applicants complete a Product Report form (which is included in the Application Kit) specific to the Use Class you are applying for.
The OMRI Product Use Classes are:
Crop Fertilizers and Soil Amendments (CF)
Crop Pest, Weed, and Disease Control (CP)
Crop Management Tools and Production Aids (CT)
Livestock Feed Ingredients (LF)
Livestock Health Care (LH)
Livestock External Parasiticides and Pesticides (LP)
Livestock Management Tools and Production Aids (LT)
Processing Agricultural Ingredients and Processing Aids (PA)
Processing Non-agricultural Ingredient s and Processing Aids (PN)
Processing Pest Control (PP)
Processing Sanitizers and Cleaners (PS)
Processing Containers and Packaging Materials (PC)
For more information on the OMRI Product Use Classes, see the OMRI Generic Materials List.
What is required to request an additional class of use for my product listing?
When a company wishes to have a currently OMRI Listed or an applying product listed under an additional class of use, the following documents and payment need to be submitted to OMRI:
- For products that are already OMRI Listed or in the process of being reviewed:
- Product Change Report for the additional use class.
- Product Report (If the product is listed under Processing Sanitizers and Cleaners, and the supplier wants to also list the product under Crop Management Tools and Production Aids, the supplier completes any item on the Product Report-Crop, which was not submitted with the original application).
- For new applications submit:
- Product Information form. This form must be from the same company and have an identical product name as the OMRI Listed or applying product.
- On the Application Fee Worksheet fill in the amount of additional category/class additions and payment of $215 for additional use class/category you wish for OMRI to review.
- Product Report (see above for details)
If you have any questions, please contact OMRI Application Specialist at 541-343-7600 x105.
What is the difference between a single ingredient product and a multi-ingredient product?
Single ingredient products contain only one ingredient or feedstock. For example, if limestone was simply mined from the earth it would be considered single ingredient (non-added impurities would not count as a second ingredient in this instance). Water (or moisture) does not count as an ingredient while calculating the fee, but its percentage in the final product should be included on the Total Ingredient List. Products that consist of a single multi-ingredient product that is already OMRI Listed are also considered to be a single ingredient. This is different from a repack as it may contain water and/or be listed in a different use class.
A multi-ingredient product contains two or more ingredients or feedstocks (including ingredients that are OMRI Listed). These include products that consist of previously formulated multi-ingredient products that are not already OMRI Listed®. For example, a blended fertilizer with blood and bone meals that is not already OMRI Listed and is being packaged is a multi-ingredient product because the product contains two separate substances. Another example is if OMRI Listed Product A is mixed with OMRI Listed Product B.
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 charges a product fee based on whether a product is single ingredient or multi-ingredient with the exception of water and OMRI Listed products. For a full explanation of fees, please see the Review Cost page.
Will OMRI securely guard the confidentiality of my formula and ingredient sources?
Yes, OMRI takes matters of confidentiality very seriously. OMRI policies on confidential information are outlined in section 1.6.1 of the OMRI Policy Manual. Confidential materials are clearly separated from public materials (Supplier Application Form and Product Application Form), and are never released to the public
What are OMRI review standards for compost products?
Applications for compost products must include lab results for pathogens and heavy metals. Composts which have levels above the pathogen threshold will be listed as in a category which has the same restrictions as 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 the Review Standards for Lab Analyses information sheet in your Application Kit (you need to be logged in to the OMRI website to follow the link provided). Depending on the compost type, additional requirements may apply. See compost requirements by category on pages 80-81 of the OMRI Generic Materials section of the OMRI Generic Materials List and in the table below.
If you have ordered an Application Kit, then you can login to the website and access advanced application support materials such as a completed Example Compost Application. The Sample Compost Application is an excellent reference for applicants applying for a product review of a compost product.
|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
|Compost – in-vessel or static aerated pile (plant and animal materials)
|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|
What if I want to reformulate during the initial review of my product?
If a product undergoes a change in formulation as defined in the OMRI Policy 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.
What is the difference between the OMRI status of "Allowed" and "Allowed with Restrictions" on the OMRI Products List?
Allowed products are composed solely of ingredients listed on the OMRI Generic Materials List as allowed. 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. All products must be used as directed on their labels. While Allowed products may be used in certified organic production for the listed Use Class and Category, 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 applications in the order in which they are received. Upon receipt, a Review Program Assistant will pre-review the application to ensure that all forms are complete. If they are not complete or clarification is needed, then the applicant will be contacted via email. Once the pre-review stage is complete, an OMRI Product Review Coordinator will be assigned to the product. This person is the primary contact for any questions about the progress of the product application from that day forward. The reviewer may ask for additional information relevant to the review of the product.
Once the application is complete, the reviewer prepares a summary and a recommendation for the application. The OMRI Review Panel then studies the summary and recommendation, and either 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.
If the panel approves the application, OMRI issues a certificate and an approval letter. Also, OMRI includes the product on our website list search, and in the quarterly supplement to the printed OMRI Products List. Every January, OMRI prints the OMRI Products List in full, which will include your products that have been approved. Finally, the OMRI Listed® seal is licensed to the company for use in association with the product.
How long does the review take?
The length of time for a product to complete the review process varies according to the type of product. OMRI does not guarantee the length of time needed to complete a review of an application. Repackaged product applications and Product Changes can be reviewed in as little as one month. The average review time for new product applications is three to four months, or less if the application is complete. Incomplete applications often take longer than the average. OMRI reviews applications in the order in which they are received. We can not guarantee the length of time it will take to review an application. However, we 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 of the required information. Please contact the Application Specialist if you have any questions at email@example.com or (541)343-7600 x 105.
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