Strengthening Organic Enforcement (SOE) Three Years Later: What Organic Businesses Should Be Paying Attention to Now

When the Strengthening Organic Enforcement (SOE) final rule entered full enforcement almost three years ago, much of the organic industry’s attention at that moment was focused on implementation. Many businesses had to obtain certification for the first time, adjust import procedures, strengthen traceability and recordkeeping, and develop a written Organic Fraud Prevention Plan (OFPP).

As the third anniversary of SOE approaches in March 2027, the conversation has fundamentally shifted. SOE is no longer primarily a deadline-driven compliance project. Instead, the systems created by the rule are now being used to provide greater visibility into organic supply chains, identify risk, and support coordinated oversight and enforcement.  

For organic businesses, the most important question that began as, “Did we implement the correct requirements?”, has now become: “Are the systems we put in place actually working?” In this article, we’re discussing how organizations can re-assess their SOE implementation with fresh eyes, as well as consider the efficacy of the systems they've put in place.  

From Implementation to Active Oversight

SOE expanded certification requirements, mandated electronic National Organic Program (NOP) Import Certificates, strengthened recordkeeping and traceability expectations, and increased the emphasis on risk-based supply chain audits, unannounced inspections, and fraud prevention.

During implementation, these changes may have felt like separate compliance obligations; however, since 2024's enforcement, their combined purpose functions within more defined parameters. For example, certification identifies accountable parties within the supply chain, and import certificates create structured shipment data. Traceability and mass-balance records connect products to transactions and inventories. Fraud-prevention plans identify vulnerabilities and controls. Together, these elements help operators, certifiers, and regulators evaluate risk and coordinate oversight more effectively. Organic compliance now means an operation can demonstrate control across all activities and supply chains.

Below we consider three significant considerations for assessing SOE implementation almost three years after initial enforcement.

1. Import data show what coordinated enforcement looks like.

Electronic NOP Import Certificates contain information about the product, origin, quantity, lot or batch identification, as well as the exporter and importer associated with organic shipments entering the United States. USDA’s National Organic Program is using this data to substantially increase their investigative and oversight activity. In coordination with U.S. Customs and Border Protection, USDA is actively using import-certificate data, document review, and risk-based sampling to guide stronger enforcement.

At the Port of Long Beach, for example, two shipments of organic-labeled pea protein were recently denied entry into the US. The USDA reported that one shipment lacked a certified NOP importer and valid NOP Import Certificate, while another tested positive for a prohibited substance. Together, the actions blocked more than 21 tons of product from entering organic commerce.

The Long Beach actions clearly illustrate the risk to the organic industry. Importers and exporters should therefore treat the NOP Import Certificate as part of a broader control process, not a standalone transaction.  

2. Accountability extends across the supply chain.

SOE significantly reduced the number of uncertified entities operating within organic supply chains. As a result, organic compliance reaches beyond the level of an individual farm, facility, or brand. The integrity of an organic claim depends on the connections between certified operations, the accuracy of transactional records, and the ability to trace products through the entire supply chain.

A valid organic certificate is only one part of that control system. Businesses also need a complete and verifiable audit trail connecting certified sources, lot information, incoming and outgoing volumes, appropriate labeling, and supporting transaction records. Higher-risk suppliers, products, and sourcing regions warrant proportionate review. Organic supplier management and organic compliance management now are expected to function in symbiosis, each complementing the other.  

3. Fraud-prevention and organic system plans must be living systems.

For many businesses, the initial challenge was creating an Organic Fraud Prevention Plan (OFPP) and incorporating it into the broader Organic System Plan (OSP). The challenge now is keeping those plans connected and current across all aspects of how a business actually operates.

Supply chains are dynamic systems subject to near daily changes and alterations. Businesses add products and suppliers, enter new sourcing regions, change logistics providers, experience commodity shortages, and respond to price volatility. Each development may alter where fraud or loss of organic integrity could occur.

An effective OSP should bridge written procedures and daily operations, taking into consideration changes at each critical control point. The OSP should reflect current responsibilities, product flows, suppliers, records, and sourcing risks. Supply-chain maps, vulnerability assessments, mitigation measures, and OSP procedures must be updated as meaningful changes occur and be tested to confirm that written controls work in practice.

When the documented system plan and actual practices diverge, a business is more likely to encounter traceability gaps, noncompliances, review and approval delays, or operational disruption. Passing an annual inspection is important, but a stronger objective includes managing a system that preserves organic integrity, surfaces problems early, and responds when conditions change.

Five Questions Organic Businesses Should Ask Now

In light of the above considerations, we’re thinking through five of the most important questions businesses should now be prepared to answer about their own SOE implementation. 

1. Has our organic supply chain changed since SOE implementation?

New suppliers, brokers, countries of origin, products, facilities, or logistics arrangements change the operation’s risk profile, and any such changes would likely require updates to the OSP or fraud-prevention controls. In this sense, businesses should consider not only whether these changes have been documented, but whether their effect on organic integrity has been evaluated and addressed. The addition of a new supplier, a new intermediary, or sourcing region, for example, may change certification, traceability, or fraud vulnerabilities even when the underlying product remains the same. The OSP should reflect these changes and remain updated.

2. Could we execute a trace-back quickly?

Organic inspectors are required to conduct mass-balance (“in-out”) and traceability (“trace-back”) audits during all annual on-site inspections. Trace-back or traceability audits help ensure that organic products and ingredients can be traced from the time of purchase through production, sale, and transport.  

An organic operation may hold records that do not reflect a usable audit trail, though. A practical, internal trace exercise can reveal disconnected systems, inconsistent identifiers, missing supplier documents, or unclear responsibilities. Select an actual organic lot or shipment and test whether your team can connect it through receiving, inventory, production or handling, and sale using the records that would be available during an inspection or investigation. The exercise should test not simply whether records exist, but whether they can be connected efficiently into a complete and understandable chain of custody.

3. Do our mass-balance records support our organic activity?

Mass-balance audits verify that quantities of organic product and ingredients produced or purchased are used, stored, sold, or transported by the operation. In this sense, inputs, production, inventory, losses, and sales should tell a credible and reconcilable story. Unexplained differences signal weaknesses that merit deeper review. Periodically comparing organic inputs with production, inventory, waste or loss, and finished-product sales can reveal discrepancies that routine record review may miss. When differences occur, the operation should be able to explain them through documented production, handling, inventory, or loss records rather than reconstructing the explanation when an auditor asks.

4. Does our Organic Fraud Prevention Plan (OFPP) reflect today’s risks?

Supply-chain mapping, vulnerability assessments, and mitigation measures should be revisited when meaningful changes occur in real time, not only during the annual certification cycle. Organic operations should be prepared to interrogate whether the vulnerabilities identified when the plan was created still represent the operation’s highest-risk areas today — and then confirm that any changes are reflected in an updated OFPP. Changes in suppliers, sourcing regions, commodity availability, pricing conditions, intermediaries, or logistics arrangements may introduce risks that were not present when the original assessment was completed.

5. Are the right people prepared?

Organic integrity is not solely the responsibility of the certification or quality team. Purchasing, receiving, production, inventory, logistics, import, and sales personnel may all maintain information needed to support compliance. Responsibilities and escalation paths should be understood before a problem arises. Employees should understand not only the procedures relevant to their role, but which changes or discrepancies need to be escalated. A supplier change, missing organic documentation, unexplained inventory variance, labeling issue, or import-document problem can become a compliance issue if the person who encounters it does not recognize its significance.  

Beyond Compliance: Building a Stronger Organic Control System

SOE raised the bar for oversight across the organic sector. Now, the opportunity is to use that higher bar to build stronger and more resilient supply chains.

Businesses that treat traceability, supplier verification, fraud prevention, import controls, and recordkeeping as continuous operational disciplines — rather than annual certification exercises — will be better prepared for regulatory scrutiny and potential supply-chain disruptions. They will also be better positioned to protect customer relationships and confidence in their organic claims.

While the goal in 2024 started as ensuring that SOE requirements were implemented, today's goal has evolved. Organic businesses must now demonstrate that the resulting organic control system remains current, connected, and effective.

Need additional support making sense of SOE?

SCS Global Services supports organic businesses assess certification scope, Organic System Plans, fraud-prevention controls, traceability practices, and operational changes that can affect continued compliance.  

If your supply chain has evolved since SOE implementation, or you’re unsure whether your current systems still meet today’s expectations, contact the SCS Global Services’ Organic Program to discuss your operation and where additional attention may be beneficial.

About the Author

Brandon Nauman is a food and agriculture business development leader with experience spanning organic agriculture, certification, sustainability, and commercial strategy. As Senior Director of Business Development at SCS Global Services, he works across the Food & Agriculture division to develop new markets, strengthen industry partnerships, and connect companies with certification and assurance solutions that meet evolving business needs. His career has given him experience on both the technical and commercial sides of certification, from working with organic producers to developing and scaling certification programs. Brandon brings a practical perspective on how standards and certification intersect with market access, risk management, sustainability, and growth.