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ICR 202610-0581-004 · OMB 0581-0321 · Object 174161200.

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application/vnd.openxmlformats-officedocument.spreadsheetml.sheet
AMS-71 Grid
USDA MRP AMS National Organic Program
Calc
2026-10-13
2026-10-29
complete

Extracted Text

TITLE OF INFORMATION COLLECTION DOCUMENT

OMB NO.

0581-0321

DATE PREPARED

National Organic Program: Strengthening Organic Enforcement (SOE)

October 20, 2026
IDENTIFICATION OF REPORTING OR RECORDKEEPING REQUIREMENT

ANNUAL BURDEN
REPORTS

SECTION OF
REGS

DESCRIPTION

(A)

(B)

FORMS NO
NO OF
(S)
NO. OF
(If "none" so RESPONDENT RESPONSES
PER
state)
S
RESPONDENT

(C)

(D)

(E)

RECORDS

TOTAL
ANNUAL
RESPONSES
(Col. D x E)

HOURS PER
RESPONSE

TOTAL HOURS
(Col. F x G)

NO. OF
RECORDKEEPERS

ANNUAL
HOURS PER
RECORDKEEPER

TOTAL
RECORDKEEPING
HOURS (Col. I x
J)

(F)

(G)

(H)

(I)

(J)

(K)

Producers and Handlers (Operations)
205.103

Subpart B -- Applicability - certified operators maintain records
for not less than 5 years.

None

-

-

-

-

-

47,364

0.25

11,841

New Group of Handlers that were previously excluded from
205.400(b)
certification must get certified. Traders and brokers of organic
205.406(a)(1)(i);
products that faciliate the trade of, but do not directly produce,
205.201(a)(1) - (6),
process, or manufacture agricultural products, are now required to
205.401d
be certified as organic and must submit initial Organic System Plan
205.406(a)(3)
(OSP).

None

-

1

-

40

-

3,364

10

33,640

205.400(b) New operations that are required to be certified under current rules
205.406(a)(1)(i);
must now include a description of the new monitoring practices
205.201(a)(1) - (6), and procedures to verify suppliers in the supply chain and organic
205.401d
status of products received to prevent organic fraud in their initial
205.406(a)(3)
Organic System Plan (OSP).

None

-

1

-

1

-

-

-

-

205.400(b)
205.406(a)(1)(i),
205.201(a)(1) - (6),
205.401d
205.406(a)(3)

Currently certified operations (farmers and handlers) must now
include a description of the new monitoring practices and
procedures to verify suppliers in the supply chain and organic
status of products received to prevent organic fraud when they
update their OSP.

None

50,728

1

50,728

1

25,364

-

-

-

205.201(c)

In addition to paragraph (a) of this section, a producer group
operation’s OSP must describe its internal control system.

None

5,900

1

5,900

2

11,800

-

-

-

205.400(g)(5)

In addition to paragraphs (a) through (f) of this section, a producer
group operation must: Identify, prevent and address conflicts of
interest, and provide training on compliance with organic
regulations and ICS procedures to all personnel and members.

None

5,900

1

5,900

5

29,500

-

-

-

205.300(c)

Organic products produced in a foreign country and exported for
sale in the United States must ... arrive in the United States
associated with a valid NOP Import Certificate (Form NOP 2110NOP 2110-1
1, approved under 0581-0191) from a certifying agent. Persons
wishing to export organic products to the US must obtain a NOP
Import Certificate through their certifying agent.

3,856

4

15,424

1

7,712

-

-

-

205.300(c)

Upon receipt of the shipment, the organic importer of record must
ensure the shipment is accompanied by a verified NOP Import NOP 2110-1
Certificate.

1,350

59

80,109

0.1

8,011

-

-

-

29,930

7

195,387

0.1

19,539

-

-

-

-

205.400 Subpart E --Certification

205.300 Subpart D - Labels, Labeling, and Market Information

205.307

Labeling of bulk nonretail containers - domestic products.

None

205.507

Labeling of bulk nonretail containers - international products.

None

3,856

21

80,109

0.1

8,011

-

PRODUCERS and HANDLERS SUBTOTAL

50,728

-

433,557

-

109,936

50,728

Accredited Certifying Agents

-

45,481

205.402 Subpart E - Review of Application - Certifying agents
Agents upload all data for each operation into Organic Integrity
205.404(b);
Database and issue certificates of organic operation using federated
205.406(d)
organic certificate template for the first time.

None

75

676

50,728

1

25,364

-

-

-

205.501(a)(2-4), (67), (11)(v), (15) &
Subpart F - Accreditation of Certifying Agents - Form TM-10CG
(20-21); 205.503(a - Provide Policies, Procedures, Evidence of Expertise and Ability
b), (d)(1-2) & (c-e);
certification activities: New 1 hour of recordkeeping for new
205.504(a -e);
procedures & 5 new activities related to this rule.
205.510(a)(1-2);
205.642

TM-10CG

-

-

-

-

-

75

1

75

205.501(a)(10-13)

Certifying agents develop fraud prevention and reporting
procedures.

None

75

1

75

2

150

-

-

-

205.501(a)(4)-(a)(6)

Certifying agents develop procedures to demonstrate that they are
sufficiently staffed and that all persons who perform certification
review activities and on-site inspections (inspectors) are qualified.

None

75

1

75

1

75

-

-

-

205.663 Certifying agents develop mediation procedures as per 205.504(b).

None

75

1

75

1

75

-

-

-

205.501(a)(4)-(a)(6)

Certifying agents must demonstrate that all persons (500/75 =
6/3=2) who perform on-site inspections (inspectors) are observed
performing on-site inspections at least once every three years (2).

None

75

2

150

8

1,125

-

-

-

205.501(a)(4)-(a)(6)

New certifying agent reviewing staff (14% of current certifying
agent review staff - assumes an equal loss of personnel due to BLS
separation rates for ag inspectors) must have 40 hours of additional
training their first year. Certifiers are already offering at least 10
hours, so new burden hours are 40. Calculated as five (5) 8 hour
trainings

None

35

5

175

8

1,400

-

-

-

An NOP Import Certificate, or equivalent, must be associated with all imports entering the US. NOP accredited domestic and foreign certifying agents (46) or foreign accredited certifiers (32), must verify the quantities of product
being exported to and imported into the US. The NOP Import Certificate is electronic and generated on Customs and Border Protection's ACE system. (Form Approved 0581-0191).
USDA Accredited Domestic Based Certifying Agents with only
NOP 2110-1
domestic ops that do not import foreign produced product.

30

-

-

0.5

-

-

-

-

205.500(c)(2) USDA Accredited Domestic Based Certifying Agents with 8% of NOP 2110-1
Foreign Operations certified under USDA.

15

427

6,409

0.5

3,204

-

-

-

USDA Accredited Foreign Based Certifying Agents with 92% of
NOP 2110-1
foreign operations certified under USDA.

36,850

0.5

18,425

-

-

-

-

30

1,228

Foreign Accredited Foreign Based Certifying Agents with foreign
NOP 2110-1
operations that export to the U.S.

30

1,228

36,850

0.5

18,425

-

ACCREDITED CERTIFYING AGENTS SUBTOTAL

105

-

131,387

-

68,244

75

-

75

Inspectors
Inspectors - unannounced inspections conducted on 5% of
operations - 50% of those will count as full complete annual
inspections. 50% are partial inspections focused on following up
on specific concerns, so they are over and above the annual
inspection. These unnannounced inspections include the new
requirement for trace back and mass balance audits. The
inspections are calculated to take half the time as would be
required of a full inspection.

None

250

5

1,268

5

6,341

-

-

-

New inspectors (14% of current inspectors - assumes an equal loss
of inspectors due to BLS separation rates) must have 40 hours of
205.501(a)(4)-(a)(6) additional training their first year. Certifiers are already offering at
least 10 hours, so new burden hours are 40. Calculated as five (5)
8 hour trainings.

None

35

5

175

8

1,400

-

-

-

INSPECTORS SUBTOTAL

250

-

1,443

-

7,741

205.403(a)(3)

Foreign Governments

-

-

-

Recognition and Equivalence of foreign governments: AMS
establishes arrangements with foreign governments accrediting
their certifying agents to facilitate the international trade of organic
products per 205.500(c)-(d) and shall conduct peer reviews of each
trade arrangement periodically to verify that the foreign
205.511(a)-(e)
government’s technical requirements and conformity assessment
system, as applicable, continue to be at least equivalent to the
requirements of the Act, and will determine whether the
arrangement should be continued. Estimating one foreign
government peer review per year.

None

8

1

1

60

60

-

-

-

Recognition and Equivalence of foreign governments: AMS
establishes arrangements with foreign governments accrediting
their certifying agents to facilitate the international trade of organic
products per 205.500(c)-(d) and shall conduct peer reviews of each
trade arrangement periodically to verify that the foreign
205.511(a)-(e)
government’s technical requirements and conformity assessment
system, as applicable, continue to be at least equivalent to the
requirements of the Act, and will determine whether the
arrangement should be continued. All foreign governments with
whom we have trade arrangements need to maintain records.

None

8

-

-

-

-

8

10

80

FOREIGN GOVERNMENTS SUBTOTAL

8

1

1

60

60

8

10

80

TOTAL OF ALL PAGES

51,091

-

566,388

-

185,981

50,811

-

45,636

TOTAL

617,199

-

231,617

-

-

-

2026 INFORMATION COLLECTION RENEWAL- Strengthening Or
OMB NO. 0581-0321
REGS

REG Text

Previous
Approved
Burden

New Group of Handlers that were previously excluded from certification

205.400(b) 205.406(a) must get certified. Traders and brokers of organic products that faciliate
(1)(i); 205.201(a)(1) the trade of, but do not directly produce, process, or manufacture
(6), 205.401d
agricultural products, are now required to be certified as organic and must
205.406(a)(3)

134,560

submit initial Organic System Plan (OSP).

New operations that are required to be certified under current rules must

205.400(b) 205.406(a) now include a description of the new monitoring practices and procedures
(1)(i); 205.201(a)(1) to verify suppliers in the supply chain and organic status of products
(6), 205.401d
received to prevent organic fraud in their initial Organic System Plan
205.406(a)(3)

1,319

205.400(b)
205.406(a)(1)(i),
205.201(a)(1) - (6),
205.401d
205.406(a)(3)

22,363

(OSP)

TOTAL

Currently certified operations (farmers and handlers) must now include a
description of the new monitoring practices and procedures to verify
suppliers in the supply chain and organic status of products received to
prevent organic fraud when they update their OSP

158,242

RENEWAL- Strengthening Organic Enforcement (SOE)
Final Burden

Difference
Between New
and Previous
Burden

Reason For Change

-134560

New, previously exempt operations were only certified
at the outset of the rule. Additional new operations are
covered in the existing overall program collection (OMB
Control Number 0581-0191).

-1319

New, previously exempt operations were only certified
at the outset of the rule. Additional new operations are
covered in the existing overall program collection (OMB
Control Number 0581-0191).

25364

3001

Previously exempt operations that became certified
under the previous collection are now currently certified
operations that must maintain records.

25,364

-132,878

0

0

Type of
Change

ADJ

ADJ

ADJ