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Miles McEvoy

Deputy Administrator, USDA-AMS-NOP
1400 Independence Ave., S.W. 
Washington, DC 20250


Dear Deputy Administrator McEvoy,


We are the Board of Directors of the Organic Crop Improvement Association (OCIA).  We represent the producer, processor, and handler members of the Organic Crop Improvement Association International.  OCIA functions in the United States as a network of chapter and direct members, and as a USDA National Organic Program accredited certification agency (ACA), that provides certification services to more than 9,000 people in North, Central, and South America, as well as Asia.


We are writing to you in order to relay our serious concerns regarding the issue of the organic certification of hydroponic production by the NOP.  We have attempted to relay our concerns through the appropriate channels within the NOP. We have voiced our concerns to the NOSB.  We do not feel that we have received an adequate response to these major concerns, and so we are writing to you.


Currently, a situation exists, within the NOP, which we feel is causing serious harm to the national organic standards, consumer’s confidence in the standard, and the organic community as a whole.  Mexico, Canada, Japan, New Zealand, and 24 European countries, (including Holland, England, Germany, Italy, France, and Spain) all prohibit hydroponic vegetable production to be sold as organic in their own countries. The NOSB (National Organic Standards Board) has formally recommended that the United States join the international community in this common definition of organic produce. The USA is very isolated in the decision to allow “organic hydroponic.”  In 2010, the NOSB submitted a recommendation to the NOP that hydroponic production NOT be certified as organic.  At the present time, the NOP is allowing hydroponic production to be labeled as certified organic.  This position is in direct conflict with the formal recommendation from the NOSB.

 The link to the NOSB Recommendation to the NOP on soilless production:


Over the life of the NOP, the issue of hydroponic production has been vigorously debated, studied, and analyzed.  The current recommendation by the NOSB may be considered the “final” outcome on the issue of hydroponic production and the organic certification thereof.


We are in concurrence with the NOSB’s finding that the current NOP standards do not and should not be used to encompass non-terrestrial plant production.  By doing so, the NOP is undermining their credibility with all concerned parties, but of most concern, they are losing the initial confidence consumers have placed in the USDA Organic label.


As evidenced over the last twenty years of regulatory and legislative activity (for example COOL and the NOP), and culminating in recent voter initiatives and legislative activity regarding the labeling of GMO usage in food, consumers have a strong interest in “where and how” their food is produced.  From our perspective, this trend will continue to intensify and grow.  We have seen the evidence for this in the strong growth of the organic share in the retail sector.


Now is the time for the USDA/AMS/NOP to act.  Several viable options exist for the NOP;

1. creation of specific standards within the NOP covering hydroponic production,

2.  creation of a new and separate standard, with its own label, (USDA Organic—Hydroponically produced), or

3. a formal finding by the NOP that new organic hydroponic production will not be allowed, import of such production will be discontinued, and current domestic production will be discontinued after a reasonable amount of time. 


We would greatly appreciate a response regarding our concerns and await your reply.






Kevin Koester, Board President, on behalf of the OCIA International Board of Directors

  • Kevin Koester, President, USA

  • Jack Geiger, First Vice-President, USA

  • Steve Elliot, Second Vice-President, USA

  • Demetria Stephens, Secretary, USA

  • Terry Sheehan, Treasurer, CAN

  • Dale Maass, Chair, USA

  • Jeff Kienast, USA

  • Lyle Hamann, CAN

  • Susan Linkletter, CAN

CC:   Mr. Tom Vilsack, USDA Secretary of Agriculture

CC:   Anne L. Alonzo, Administrator of the AMS



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