Organic Insider: Oversight and Enforcement Update
The National Organic Program (NOP) is introducing the Organic Insider: Oversight and Enforcement Update, a new, periodic update that highlights NOP’s work in these areas.
This edition presents import data from the first full calendar year of the implementation of the Strengthening Organic Enforcement (SOE) Final Rule, along with an example of how NOP has used that data to prevent the importation of fraudulent products. It also provides an update on how NOP’s complaint investigations have strengthened the organic marketplace.
Presenting Data on 2025 Imports of Organic Products
March 19, 2026, marked two years since NOP began implementing the SOE Final Rule. The rule updated the USDA organic regulations to implement 2018 Farm Bill mandates and respond to industry requests for updates. The rule protects organic integrity by supporting strong organic control systems, improving farm-to-market traceability, increasing import oversight and authority and providing robust enforcement of the organic regulations.
Under the SOE Final Rule, all shipments of organic agricultural products imported into the United States must be associated with a valid NOP Import Certificate (NOP-IC). The certificate contains information about the origin, quantity and product type coming into the United States.
Many organic imports come into the United States under a Harmonized Tariff Schedule (HTS) code that is specific to organic products. Data on those imports are in the Foreign Agricultural Service’s GATS system. Not all organic imports have corresponding HTS codes. The NOP-IC data includes organic imports marked with conventional HTS codes as well, providing a more comprehensive picture of organic imports.
The full detailed data for organic imports in 2025, broken down by HTS code, is on NOP’s website. The following charts show high-level information about 2025 organic imports.
Top Country-Commodity Pairs, 2025
The percentages in the following chart indicate the value of the country-commodity pair as a percentage of the total value of organic imports of all commodities.
 Top Countries Exporting Organic Products to the United States, 2025
The percentages in the following chart indicate the percentage of total organic imports into the United Stares that came from that country.
 Top Organic Commodities Exported to the United States, 2025
The percentages in the following chart indicate the value of the commodity as a percentage of the total value of organic imports.
 Using NOP-IC Requirement to Identify Organic Fraud
The NOP-ICs gives NOP a new type of data we are using to focus our investigations and enforcement work. Last year, NOP focused on detecting and addressing problems with the data entered into NOP-ICs, as these problems could indicate potential violations. NOP identified irregularities in import data that led to investigations into two importers bringing in products from China. One imported high-value plant extracts and fruit and vegetable juices and the other imported frozen vegetables.
Both investigations found that these companies brought organic products into the country without the required NOP-ICs and then sold those products as organic. This violates the USDA organic rules.
In the first case, the importer could not verify that the imported products were actually organic. The importer’s certifier took enforcement actions and negotiated a settlement to bring the company back into compliance. During the investigation, the certifier also found that the company’s supplier had violated the organic rules. This led the importer’s certifier and the supplier’s certifier to work together on a broader investigation, which resulted in the supplier being suspended.
In the second case, the certifier issued noncompliances to the importer. The business then reexported the products that did not meet the requirements, so they were not sold to U.S. buyers. NOP also confirmed that the exporter has now started using valid NOP-ICs and that its certifier knows about the noncompliant export activity.
NOP will continue to use import data in 2026 for high-impact compliance assessments and enforcement actions where supported by evidence.
NOP Complaints Update—Another Path to Import Oversight
In addition to proactive surveillance and reviews of import data to detect potential violations of the organic regulations, NOP relies on complaints from the public, states and other federal agencies to initiate investigations.
For example, in 2025, NOP investigated a complaint from the California State Organic Program about a certified trader in Mexico. The complaint alleged that the trader sold organic raspberries to a large U.S. berry brand that tested positive for a substance prohibited by the USDA organic regulations. The affected lots were not eligible for sale as organic in the United States and 191 cartons of raspberries were destroyed before entering the marketplace.
After this incident, the trader conducted staff training to improve its supplier management system and implemented a residue testing program. The contamination happened at the certified grower of the affected raspberries, also located in Mexico. The operation used shared equipment to spray nonorganic onion fields with a substance not allowed for use in organic production. The operation did not adequately clean the equipment before using it on its organic fields. In response to an adverse action from its certifier, the grower entered into a settlement agreement. The agreement required the operation to surrender certification of the contaminated fields and have one additional inspection each year, along with other conditions to prevent the problem from happening again.
The following chart shows recent statistics from NOP’s review and closure of complaints. Cases in progress are based on allegations, complaints and surveillance. The presence of a case does not mean a violation has occurred.
 All of NOP’s oversight and enforcement serves our vision: Organic integrity from farm to table, consumers trust the organic label.
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