Legal Registration

by Kelsey McKee

The organic movement has both a local focus and a global reach, which is true for OMRI as well. At our office in Eugene, Oregon, we review input products that are manufactured across town, and purchased by local farmers who market their bounty through Community Supported Agriculture (CSA) programs. We also review input materials from halfway across the globe that may be used to grow such novelties as the tropical dragon fruit or mid-winter strawberry. In total, the OMRI Products List© contains products from over 30 countries, including Australia, India and the U.S.—just to name a few. All OMRI Listed® products have been evaluated for compliance with the USDA National Organic Program or the CFIA Canadian Organic Regime regulations; however, there are many other local or national regulations that may apply to products depending on where they are sold.

Acknowledging the global reach of the National Organic Program (NOP) and Canadian Organic Regime (COR), and the widespread use of OMRI Listed products, OMRI in 2017 revised its review criteria for products subject to Environmental Protection Agency (EPA) or Pest Management Regulatory Agency (PMRA) regulations. Specifically, OMRI Listed certificates no longer identify products that are not registered for use as pesticides in the U.S. or Canada. Most products that aren’t EPA registered are not intended for sale in the U.S., and therefore are not subject to EPA registration. Similarly, pesticides that are not registered with the PMRA in Canada are generally not intended for sale in Canada.

Even inputs that are registered at the federal level in the U.S. or Canada may be further regulated by the state, province, county or city in which they are sold and used. For example, the city of Vancouver, Canada, has established bylaws to further restrict pesticide use within its local community. Each of the 30 countries where OMRI Listed products are manufactured may have a similar hierarchy of regulatory requirements. And that’s just for pesticides! Crop fertilizers and livestock feed additives may also be subject to additional regulations based on where they are sold and how they are used.

OMRI is not an expert in the specific registration requirements that may apply to the thousands of OMRI Listed products in the marketplace. Input suppliers are responsible for complying with the regulations that apply to their products, wherever they are sold. The OMRI Standards Manuals© and OMRI Policy Manual© define the scope of OMRI’s review, which is limited to OMRI policies and standards as based on the NOP or COR standards. For compliance with the organic regulations, OMRI Listed products must be used according to their use class, listing category and applicable restrictions, and use must be approved by an accredited organic certifier. In addition, certified operators are responsible for using OMRI Listed products in a legal manner, consistent with label use instructions and in compliance with applicable governmental regulations.

Whether you are on a farm packing boxes of produce for the local community, or at a facility processing organic products for export across the globe, you can rely on the OMRI Listed seal to identify compliant materials. But depending on where you are, the regulations that apply to the use of OMRI Listed products may be different. Read labels carefully, and check in with the applicable governmental authorities with any questions about legal uses for OMRI Listed products.

This article first appeared in the winter 2017 issue of the OMRI Materials Review newsletter. It was reviewed and updated in November 2019 by Technical Director Doug Currier.