Exporting organic products to the USA under NOP (USDA)

The largest market for organic products

In 2025, sales of organic products in the USA reached 76.6 billion dollars, of which 70.1 billion were food sales. Sales of organic food are growing almost three times faster than the food market as a whole. US buyers are actively looking for products that are not produced locally in sufficient quantities. Among them are herbs, spices and essential oils, in which Bulgaria has traditions and proven quality.

What is NOP

The National Organic Program (NOP) is part of the Agricultural Marketing Service (AMS) of the United States Department of Agriculture (USDA). Its rules are laid down in US law (7 CFR Part 205). Only a product that meets them may be sold as "organic" and bear the USDA Organic logo.

The EU-US equivalence arrangement

Since 2012, the EU and the USA have mutually recognised each other's organic production and control systems as equivalent. In practice:

• no separate NOP certification is needed - the certificate under Regulation (EU) 2018/848 issued by a recognised control body in the EU is sufficient;
• the arrangement covers plant products, wild-collected products, products from animals and processed products;
• the product must be produced in the EU or finally processed or packaged in the EU. It may also contain imported ingredients certified under EU rules.

Important: products produced outside the EU (for example in North Macedonia) and only traded through the EU do not automatically fall within the scope. Each specific case must be assessed.

Additional conditions ("critical variances")

The arrangement provides for several requirements that go beyond the EU Regulation and must be met when exporting to the USA:

• Antibiotics: products from animals treated with antibiotics cannot be sold as organic in the USA. This affects dairy products, meat, eggs and honey. When exporting organic products of animal origin to the USA, an additional certificate attesting that no antibiotics were used is also required, in accordance with Delegated Regulation (EU) 2021/2304. It is issued at the operator's request by the relevant control body after verifying that the requirement has been met. The additional certificate supplements the certificate under Regulation (EU) 2018/848 and does not replace the NOP import certificate.
• Wine: to be labelled as "organic" and bear the USDA Organic logo in the USA, wine must be produced without added sulphites and meet the US requirements for composition and labelling. If sulphur dioxide is added, it may be labelled as "made with organic grapes", provided that the total sulphite content, including naturally occurring sulphites, does not exceed 100 ppm and all the grapes used are certified organic. In this case the USDA Organic logo is not permitted. For both categories, the substances used are checked for compliance with 7 CFR 205.605. The label is subject to verification by the control body and to the required approval of the US Alcohol and Tobacco Tax and Trade Bureau (TTB).
• Excluded products: aquaculture products (fish, mussels, etc.) and salt are not within the scope.

The import certificate under NOP (NOP Import Certificate)

Since 19 March 2024, with the introduction of the USDA rule on strengthened enforcement (Strengthening Organic Enforcement), every shipment of organic products to the USA must have an electronic import certificate. It is issued by the exporter's control body in the USDA database (Organic INTEGRITY Database). The certificate contains a statement that the product is certified under the EU-US arrangement.

For exporters certified by us, Balkan Biocert issues these certificates. Before issuing the certificate, we check:

• whether the product is included in your certificate under the EU Regulation;
• the quantities and traceability of the lot - from the raw material to dispatch;
• compliance with the additional conditions of the arrangement;
• the shipment details: product, customs code (HTS), quantity, buyer, dates.

One certificate is issued per product or customs code (HTS). The exporter provides the certificate to the importer, who must be certified under the USDA organic rules by a USDA-accredited certification body. The certificate data and number are submitted in the US customs system ACE by the importer or their customs representative.

Labelling

• Products intended for end consumers must meet the US labelling requirements, including the categories "100% organic", "organic" (at least 95% organic ingredients) and "made with organic..." (at least 70%).
• The label states "Certified Organic by Balkan Biocert" and the code BG-BIO-02.
• The USDA Organic logo and/or the EU organic logo may be used if the conditions for them are met.
• For bulk shipments, the packaging is marked as organic, with the lot number and details linking it to the accompanying documents.

Important: do not dispatch the shipment before a valid NOP Import Certificate has been issued. Since 1 October 2025, organic shipments arriving in the USA without such a certificate cannot be released for sale by relabelling them as conventional. The options provided for are re-export, destruction or donation under the conditions set by the US authorities.

The price of export certificates is published in our price list, with separate rates for the first ten certificates and for subsequent ones.

The regime is changing - ask us

The rules for trade between the EU and the USA are being renegotiated, and the labelling and documentation requirements are being updated. Before concluding a contract with a US buyer, confirm with us which regime applies to your products at the time of export.

This text is a summary for information purposes. The USDA rules (7 CFR Part 205), the EU-US equivalence arrangement and Regulation (EU) 2018/848 are binding. Sources: USDA AMS - International Trade Policies: European Union; USDA AMS - Electronic Organic Import Certificates; OTA - Organic Market Report 2026.