USDA Organic Import Certificates After SOE: What a Sri Lankan Organic Shipment Needs
Compliance snapshot
- Since 19 March 2024, each organic shipment entering the United States must be tied to an electronic NOP Import Certificate generated in the USDA Organic INTEGRITY Database (USDA AMS, Electronic Organic Import Certificates).
- The exporter’s certifier issues the certificate. The US importer or customs broker files its 21-character number in CBP’s Automated Commercial Environment (ACE) with the entry.
- USDA matches ACE entry data against INTEGRITY, so a number that is missing, over-quantity or tied to a lapsed operation is flagged before the paperwork reaches a human.
- Silk Foods Ceylon holds USDA Organic on selected SKUs, confirmed per SKU, and organic lots ship with the import certificate the destination requires.
- This post covers the US side only: how the certificate works and what to ask a Sri Lankan supplier. It is for importers and brand buyers writing a first organic purchase order.
On 19 March 2024 the Strengthening Organic Enforcement (SOE) rule stopped being a rulemaking and became a gate at the port. The rule had been published in the Federal Register on 19 January 2023, with a 14-month runway (Federal Register, Strengthening Organic Enforcement final rule, 2023). The market it protects is not small: US sales of certified organic products reached USD 76.6 billion in 2025 (Organic Trade Association, 2026 Organic Market Report). For a Sri Lankan botanical or spice, that market now opens on a document issued before the container is packed.
This piece takes one slice of the topic. The wider picture, including Canada and the three certification routes, sits in the organic equivalence guide for Canadian and US botanical importers. Here the question is narrower: what exactly is the certificate, and what does a supplier in Matale have to do for it to exist?
What does the Strengthening Organic Enforcement rule change for imports?
The SOE rule changed three things at once. It made the import certificate electronic and mandatory. It pulled intermediaries such as importers, brokers and traders into certification where they previously sat outside it. And it linked the certificate data to customs entry records so USDA can check one against the other.
Before the rule, an organic import into the US could travel with a paper certificate that was optional in many cases. The legacy paper form, NOP 2110-1, was converted to an electronic format on 19 March 2024 and can now be created only by an accredited certifier in INTEGRITY (USDA AMS, NOP 2110-1).
The shift sounds administrative. It is closer to a change in who holds the evidence. The buyer’s word, the supplier’s invoice and a scanned certificate PDF no longer carry the organic claim across the border. A database record does.
Who issues the NOP Import Certificate, and who files it?
The certifier of the foreign exporter generates the certificate in INTEGRITY. The US importer or customs broker then files the certificate number in ACE as part of the entry. No other party can create it, and a supplier cannot produce one by itself.
| Step | Party | What happens |
|---|---|---|
| 1 | Certified exporter or final handler (Sri Lanka) | Requests the certificate from its own certifier for the consignment |
| 2 | USDA-accredited certifier | Generates the electronic certificate in INTEGRITY, one per commodity or HTS code |
| 3 | Exporter | Passes the certificate number to the US importer |
| 4 | US importer or customs broker | Files the 21-character number in ACE under the OR2 option; no document upload to ACE is needed |
| 5 | USDA AMS | Matches ACE entry data to the INTEGRITY record and flags mismatches |
Source: USDA AMS, Electronic Organic Import Certificates and Strengthening Organic Enforcement FAQ, 2026.
The “one per commodity or HTS code” line matters for mixed orders. A container carrying organic moringa powder and organic coconut spread is two certificates, not one, and each number goes into the entry. Per the AMS FAQ, a certificate can cover a single shipment or a longer period such as a season, so a buyer on a repeat programme should ask which pattern the supplier’s certifier uses.
Certification snapshot: what sits on each side of the border
- Supplier side: USDA NOP certification of the exporter or final handler, with the SKU on the certificate scope
- Certifier side: the electronic import certificate, issued in INTEGRITY
- Buyer side: the importer’s own organic certification where SOE requires it, plus the ACE filing
- Not covered: a supplier cannot file for the buyer, and a buyer cannot request the certificate from the supplier’s certifier
Why do first organic shipments get held?
Almost never because the product is wrong. They get held because two records disagree. USDA’s matching looks for certificates not authorised in INTEGRITY, quantities above what the certificate allows, and entries tied to operations no longer certified (Federal Register, 2023). Each of those is a paperwork event, and each one can be prevented before the purchase order is signed.
The recurring causes are easy to list:
- The SKU named on the commercial invoice is not on the supplier’s certificate scope.
- The certificate was requested for a different quantity than the packed lot.
- The commodity is under one HTS code on the entry and another on the certificate.
- The importer has no certificate number to file because nobody requested it before sailing.
- The supplier’s USDA certificate lapsed between order and shipment.
Item five is the quiet one. A certificate is a dated record, and a four to six week organic lead time plus four to five weeks of sea freight to the US means the order date and the arrival date sit in different months. The check that matters is the certificate’s status on the day the certificate is requested, which the buyer should ask the supplier to confirm in writing.
Which documents travel with a Sri Lankan organic lot?
An organic consignment from Silk Foods Ceylon (SFC) ships with the standard pack plus the organic evidence. Pricing basis is FOB Colombo, with CFR and CIF on request.
| Document | Needed for | Notes |
|---|---|---|
| Commercial invoice and packing list | Every shipment | SKU names should match the certificate scope wording |
| Bill of lading or air waybill | Every shipment | Sea freight to the US takes 4 to 5 weeks |
| Certificate of origin | Every shipment | Issued for the consignment |
| Phytosanitary certificate | Where the destination requires it | Product-dependent |
| COA | On request | Lab tests such as pesticide residues, heavy metals and microbiology run through an external laboratory on request |
| NOP Import Certificate number | Organic lots into the US | Generated in INTEGRITY by the exporter’s certifier |
The COA and the organic certificate answer different questions. A COA says what is in the lot. The import certificate says the lot may be sold as organic. Buyers who read one as a substitute for the other tend to find out at entry.
What should a buyer ask a supplier before the first organic purchase order?
Put the questions in the RFQ, not in a follow-up after the quote lands. The procurement desk at Silk Route Ventures (SRV) sees the same gap repeatedly: the commercial discussion is complete, and nobody has asked which certificate scope the SKU sits on.
Buyer’s checklist: US organic documentation before the first PO
- Ask which SKUs are on the supplier’s current USDA certificate scope, and confirm your SKU is one of them.
- Send the exact label wording and ask the supplier to match it to the certificate scope.
- Ask which certifier holds the file and who requests the import certificate.
- Agree the quantity and HTS code the certificate will be requested against.
- Confirm in writing who is importer of record and who files the ACE entry.
- Check whether your own business needs organic certification under SOE as importer, broker or trader.
- Ask for the certificate number before the vessel sails, not after.
A rhetorical aside belongs here: the cheapest line in the whole supply chain is the one that says “please confirm the certificate scope”. It costs a minute at quotation and saves a container at the port.
One boundary stays fixed. SRV does not act as importer of record and does not file ACE entries for buyers. That is the importer’s regulated duty. What the supplier owes is accurate scope, a timely certificate request and a number the buyer can file.
How does this fit a Ceylon spice or botanical programme?
For buyers building an organic line, the certificate is one input among several. Spec, grade and origin come first, and the Ceylon spices supplier range shows what the Matale facility handles. Organic status is then confirmed SKU by SKU, because organic is never a category-wide claim. For Ceylon cinnamon powder and moringa powder, the certificate scope is the first thing to check, not the last.
Silk Foods Ceylon runs under BRCGS and FSSC 22000 V6 at Matale, and the BRCGS scope covers herbal and plant-based powders rather than spices, so for spice products the relevant food-safety certificate is FSSC 22000 V6. Buyers who want the full map of organic routes will find it in the buyer’s guide to organic certifications, and those weighing how the same discipline works for coconut can read the VCO organic certification chain.
Frequently asked questions
What is an NOP Import Certificate?
It is the electronic certificate generated by an accredited certifier in the USDA Organic INTEGRITY Database for each organic consignment entering the US. It replaced the optional paper NOP 2110-1 form on 19 March 2024, and the importer or customs broker files its 21-character number in CBP’s ACE with the entry.
Who requests the certificate for a Sri Lankan shipment?
The certified exporter or final handler requests it from its own USDA-accredited certifier. The certifier generates it in INTEGRITY, one per commodity or HTS code, and the exporter passes the number to the US importer for filing. The buyer cannot request it directly from the supplier’s certifier.
Does one certificate cover repeat shipments?
It can. According to the USDA AMS Strengthening Organic Enforcement FAQ, a certificate may cover a single shipment or a longer period such as a growing season. Buyers on repeat programmes should ask the supplier which pattern its certifier applies, and confirm the quantity limit on the record.
Does Silk Route Ventures supply USDA Organic botanicals and spices?
Yes, on selected SKUs, confirmed per SKU. Silk Foods Ceylon holds USDA Organic and EU Organic on selected SKUs alongside BRCGS and FSSC 22000 V6, and organic lots ship with the import certificate the destination requires. Commercial orders start from 100 kg per SKU, dried herbs from 25 kg, and organic orders run 4 to 6 weeks from PO to dispatch.
How Silk Route Ventures can help
Silk Route Ventures (SRV) supplies bulk Ceylon spices and botanicals to specialty brands and importers in the United States, with USDA Organic and EU Organic on selected SKUs, confirmed per SKU. The Silk Foods Ceylon (SFC) facility in Matale holds BRCGS and FSSC 22000 V6, and every organic consignment travels with the import certificate the destination requires. Commercial orders start from 100 kg per SKU (25 kg for dried herbs, trial quantities from 10 kg), samples are free for evaluation (you cover the courier), and organic orders take 4 to 6 weeks from PO to dispatch. Before the RFQ closes, the trade desk will send the certificate scope for the SKU you are considering. Contact us to send an inquiry or request a sample.
Related reading: organic equivalence for Canadian and US botanical importers.
Sources
- USDA Agricultural Marketing Service, “Electronic Organic Import Certificates,” National Organic Program, (2024). Retrieved 2026-11-03. https://www.ams.usda.gov/services/organic-certification/international-trade/Electronic-Organic-Import-Certificates
- USDA Agricultural Marketing Service, “NOP 2110-1 - NOP Import Certificate,” (2024). Retrieved 2026-11-03. https://www.ams.usda.gov/resources/nop-2110-1
- USDA Agricultural Marketing Service, “Strengthening Organic Enforcement Frequently Asked Questions,” (2026). Retrieved 2026-11-03. https://www.ams.usda.gov/rules-regulations/strengthening-organic-enforcement/faq
- Federal Register, “National Organic Program (NOP); Strengthening Organic Enforcement,” final rule, 19 January 2023. Retrieved 2026-11-03. https://www.federalregister.gov/documents/2023/01/19/2023-00702/national-organic-program-nop-strengthening-organic-enforcement
- Organic Trade Association, “U.S. Organic Marketplace Achieved Significant Growth in 2025,” 2026 Organic Market Report, (2026). Retrieved 2026-11-03. https://ota.com/about-ota/press-releases/us-organic-marketplace-achieved-significant-growth-2025