Public Comments

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October 19, 2026
U.S. Department of Agriculture
Agricultural Marketing Service
National Organic Program
1400 Independence Avenue, SW
Washington, D.C. 20250-0268
Re: Agency Information Collection Activities; Proposals, Submissions, and Approvals: National
Organic Program; Strengthening Organic Enforcement [AMS-NOP-26-1321]
Dear Madam/Sir,
These comments are submitted on behalf of Beyond Pesticides. Founded in 1981 as a
national, grassroots membership organization that represents community-based organizations
and a range of people seeking to bridge the interests of consumers, farmers, and farmworkers.
Beyond Pesticides advances improved protections from pesticides and alternative pest
management strategies that eliminate a reliance on pesticides. Our membership and network
span the 50 U.S. states, Commonwealths, territories, the District of Columbia, and the world.
We are writing in response to the U.S. Department of Agriculture (USDA) Agricultural
Marketing Service’s (AMS), through its National Organic Program (NOP), request for an
extension and revision of the information collection titled “National Organic Program:
Strengthening Organic Enforcement (SOE).”1 This extension is said “to allow AMS adequate time
to add the activities covered under this Strengthening Organic Enforcement... so that it may
continue to fully implement organic regulations and enforcement.”1
While Beyond Pesticides supports the continued collection of information necessary to
implement and enforce the National Organic Program’s Strengthening Organic Enforcement
requirements, the extension should not be treated as a substitute for action. Beyond Pesticides
endorses continuous improvement of organic standards, including scrutiny of substances
allowed in organic production.
Enforcement of Organic Standards
Organic agriculture is a holistic solution to the concurrent crises regarding public health,
biodiversity, and climate. As the harm to public health and ecosystems associated with
petrochemical pesticide and fertilizer use continues to be documented in the scientific

Beyond Pesticides
AMS-NOP-26-1321

literature, a national action is calling for standards governing organic land management
practices to be protected and strengthened.2,3
Organic maintains a unique place in the food system because of its high standards and
the ongoing opportunity for continuous improvement through transparency and public
involvement. As such, credible certification and enforcement are essential to ensuring that the
organic label retains its meaning.
In extending the current approval for one year and asking to continue collecting the
records and documentation needed to enforce organic certification requirements, including
documentation for imported organic products, USDA is ensuring that effective recordkeeping
and supply-chain traceability can prevent fraud, maintain accountability, and protect public
trust in the organic label. These steps are all crucial in implementing the existing Strengthening
Organic Enforcement rule and upholding organic integrity.
The issue, however, is that continuing paperwork requirements are not the same as
ensuring effective enforcement. Recordkeeping must be translated into action. As an example,
USDA must use supply-chain documentation to identify suspicious transactions, investigate
violations, and prevent fraudulent organic claims.
Summary
Beyond Pesticides and others—including organic and regenerative organic farmers and
advocates—have long argued that the Environmental Protection Agency (EPA) has failed to
consider the viability, productivity, and profitability of organic practices and product
alternatives to conventional pesticides. There is wide body of scientific literature documenting
adverse effects of toxic pesticides, while there are commercially available alternative
management practices and products, as defined by the Organic Foods Production Act (OFPA)
and implemented by the USDA’s National Organic Program, that offer a holistic solution.
Organic management practices and organic compatible products eliminate the hazards (and
risks) that EPA is accepting.
Beyond Pesticides urges USDA to ensure that these information-collection requirements
are implemented in a manner that supports meaningful enforcement, timely investigation of
suspected violations, and effective verification of organic claims. Documentation should be
complemented by appropriate inspections, supply-chain traceability, and pesticide-residue
testing where warranted. USDA should also ensure that the administrative burden associated
with these requirements does not undermine the resources available for effective oversight
and enforcement. Maintaining the existing information collection is an important element in
protecting organic integrity, but it must remain part of a broader commitment to rigorous
enforcement and continuous improvement of organic standards.

Beyond Pesticides
AMS-NOP-26-1321

Thank you for your consideration of our comments.
Respectfully,

Sara Grantham
Science, Regulatory, and Advocacy Manager

_____________________________________________________________________________________________________________________

United States Environmental Protection Agency (2026) Agency Information Collection
Activities; Proposals, Submissions, and Approvals: National Organic Program; Strengthening
Organic Enforcement. Available at: https://www.regulations.gov/document/AMS-NOP-261321-0001.
1

Beyond Pesticides (2026) Organic Integrity Is Up for Review before Public Board that Manages
Standards and Practices, Deadline Oct 1. Available at:
https://beyondpesticides.org/dailynewsblog/2026/09/organic-integrity-is-up-for-reviewbefore-public-board-that-manages-standards-and-practices-deadline-oct-1/.
2

Beyond Pesticides. Pesticide-Induced Diseases Database. Available at:
https://www.beyondpesticides.org/resources/pesticide-induced-diseases-database/overview.

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