What It Would Take for Us to Be Certified Organic

We are not certified organic.

Revival Mill is looking at what USDA organic certification would take, and we want to do that in the open. This article lays out what the seal requires, how it is enforced, what the research says, and the questions we are still working through.

The standard

Organic is a federal standard, not a slogan

On a U.S. food label, "organic" has one legal meaning. Any farm or business that uses the word has to meet the same national rules.

1

Defined by law

The Organic Foods Production Act of 1990 and USDA regulation 7 CFR Part 205 set one national meaning for the word.

2

Verified every year

A USDA-accredited certifier reviews each operation's organic system plan and inspects it on site every year.

3

Enforced by USDA

The National Organic Program can suspend or revoke certification and act against sellers who are not certified.

The standard

Four label tiers, and only two may carry the seal

The wording on the front of the package tells you how much of the product is certified organic. Percentages are by weight, not counting water and salt.

100%

100% Organic

Every ingredient and processing aid is certified organic.

USDA seal allowed
95%+

Organic

At least 95 percent certified organic content.

USDA seal allowed
70%+

Made with Organic

Names up to three organic ingredients or food groups.

No USDA seal
Under 70%

Ingredient list only

Organic items may be marked in the ingredient list.

No USDA seal

A stone-ground flour milled only from certified organic grain, with nothing added, would fall in the first tier. That is the label we would be working toward.

The standard

What organic production rules out

36

months

with no prohibited substances applied to the land before an organic crop is harvested.

  • 1
    Never allowedGenetic engineering, ionizing radiation, and sewage sludge.
  • 2
    The National ListNatural substances are allowed unless prohibited. Synthetic substances are prohibited unless specifically listed.
  • 3
    Organic seedOrganic seed and planting stock are required when commercially available.
The standard

Who must be certified

Farms and businesses selling $5,000 or less of organic product a year are exempt from certification, but the exemption comes with limits.

Claim or activity Certified operation Exempt, $5,000 or less
Must follow organic production rulesYesYes
May use the word "organic"YesYes
May display the USDA sealYesNo
May say "certified organic"YesNo
May sell it as an ingredient in another company's organic productYesNo

Handlers that sell more than $5,000 of organic product must be certified, and that includes businesses that repackage or relabel it. For a mill, grinding or rebagging certified grain is handling, so the mill itself needs its own certification. Buying certified grain is not enough.

Enforcement

How the seal is protected

  1. 1

    Plan and inspect

    Every certified operation keeps an organic system plan and is inspected each year.

  2. 2

    Test residues

    Certifiers must test at least 5 percent of the operations they certify every year.

  3. 3

    Pull the claim

    Residue above 5 percent of the EPA tolerance means the product cannot be sold as organic.

  4. 4

    Look it up

    Anyone can check an operation in the USDA Organic Integrity Database.

Since March 19, 2024, the Strengthening Organic Enforcement rule has required brokers and traders to be certified and every organic import to carry an NOP Import Certificate. USDA calls it the largest update to the organic regulations since the 1990 law.

Enforcement

Why traceability matters for grain

$142 million

in grain sales from 2010 to 2017, most of it conventional corn and soybeans sold as organic.

U.S. Attorney's Office, Northern District of Iowa, 2019

  • 1
    The weak link was a brokerFederal prosecutors called it the largest organic fraud case in U.S. history.
  • 2
    Brokers now need certificationThe 2024 enforcement rule closed that gap.
  • 3
    Buyers can verifyAsk a supplier for its certificate and confirm it in the Integrity Database.
Research

What the research shows

Studies agree on residues. They disagree on nutrition and health, so we are giving you both sides.

Studies agree

Fewer pesticide residues. A Stanford review found organic produce had about a 30 percent lower risk of residue contamination (Smith-Spangler, 2012).

A review of 343 studies found residues about four times less often in organic crops (Barański, 2014).

Still debated

Nutrition. The Stanford review found no strong evidence that organic food is more nutritious. The larger 2014 review found more antioxidants and less cadmium in organic crops.

Cancer risk. A French study of 68,946 adults linked frequent organic eating to about 25 percent lower risk. A UK study of 623,080 women found no overall reduction, and the American Institute for Cancer Research does not recommend organic food for cancer prevention on this evidence.

Market

A growing share of what people buy

$76.6B

U.S. organic sales in 2025

6.8%

growth in 2025, about double the comparable market

6.1%

organic share of all U.S. food sales

Source: Organic Trade Association, 2026 Organic Market Report.

Our next steps

What certification would mean for Revival Mill

These are the questions we are working through. We will post what we learn.

  • Grain supply. Can we buy certified organic wheat and sorghum in the varieties we mill, with certificates we can verify?
  • The mill. If we mill both organic and conventional grain, how do we clean, separate, and record each run so the two never mix?
  • The paperwork. What goes into our organic system plan, and what records does an annual inspection expect?
  • The cost. What do certification fees come to, and how much does federal cost share offset?
  • The labels. Until certification is in place, we will not describe what we mill as organic.

Certification in Texas

The Texas Department of Agriculture is a USDA-accredited certifier for producers, processors, distributors, and retailers.

75%

of certification fees can be reimbursed through federal cost share, up to $750 per scope, for 2025 and 2026. Applications for both years are due December 31, 2026.

Sources

Where these facts come from

  1. 7 CFR Part 205, National Organic Program, Electronic Code of Federal Regulations
  2. Labeling Organic Products, USDA Agricultural Marketing Service
  3. Organic Production and Handling Standards, USDA AMS
  4. Do I Need to Be Certified Organic?, USDA AMS
  5. 7 CFR 205.310, Products of an Exempt Operation, Cornell Legal Information Institute
  6. Strengthening Organic Enforcement Final Rule Fact Sheet, USDA AMS
  7. NOP 2613, Responding to Pesticide Residue Testing, USDA National Organic Program
  8. Field of Schemes press release, U.S. Attorney's Office, Northern District of Iowa, 2019
  9. Organic Certification Program, Texas Department of Agriculture
  10. Organic Certification Cost Share Program, 2025 and 2026, USDA Farm Service Agency
  11. 2026 Organic Market Report, Organic Trade Association
  12. Smith-Spangler et al., Annals of Internal Medicine, 2012
  13. Barański et al., British Journal of Nutrition, 2014
  14. Baudry et al., JAMA Internal Medicine, 2018
  15. American Institute for Cancer Research commentary, 2018

Information current as of November 2026. Rules, deadlines, and market figures change; check the linked sources for the latest.