On June 3^rd, the National Organic Program (NOP) published a letter to organic certifiers clarifying that the Organic Food Production Act (OFPA) requirements for a 3-year transition-to-organic period “apply to all container systems built and maintained on land,” a clarification that the Organic Farmers Association has been advocating for.

Container production is a growing part of the hydroponic industry, which can involve completely covering the ground in plastic and growing the crops in pots. Hydroponic production has raised many questions in the organic community about whether it can receive the organic label since it does not include the use of soil—a bedrock of organic production. Organic farmers polled by the Organic Farmers Association have strongly stated that hydroponics cannot be organic. Organic farming is rooted in the soil. Soil is important because it recycles nutrients as crops decompose and sequesters carbon, preventing it from being released into the atmosphere and contributing to climate change. Not only does nutrient recycling in soil reduce the need for any fertilizer inputs that organic farming does not use, but soil is necessary for storing carbon.

NOP’s letter follows its 2018 statement that hydroponic farms using organic inputs could become certified organic. Until NOP published its clarification, it was unclear whether container farms could be held to a three-year transition-to-organic period that other transitioning farms are expected to adhere to, since this time frame is based on the goal of working pesticide residues out of the soil. While we are pleased the NOP did maintain the organic principles and letter of the OFPA law in this question, we are concerned that it was ever a question.

Now that the NOP has confirmed that container production should be held to the same three-year transition and that container systems must also be responsible for “maintaining or improving natural resources,” we hope that the NOP will continue to uphold the standards uniformly across production standards and not allow individual certification agencies to develop their own interpretations of the standards that allow for inequities in the organic label nationwide—a concern that motivated the organic community to develop the USDA NOP program in 2001. We do need uniform standards and enforcement—but if the NOP does not make sure we are all operating under the same standards it is confusing for consumers and hurts us all in the end.