Unfortunately, no, your NOP certification is not enough if you want to ship product into the European Union (EU). Almost every country has their own set of organic standards and regulations that all incoming organic products must adhere to. 

The European Union Organic Standards and Regulations (EU 2092/91) establish a list of standards for the production and handling of organically produced products entering Europe. Although the basic principles of organic production are very similar in both the United States and Europe, there are some major differences that anyone seeking this verification should note.

Under the EU, just like the NOP, you must use organic seed. However, under the NOP, if the seed you wish to use is not available in the quantity, quality or variety you need and you have documentation that you have attempted to find this seed but could not, then you are allowed to use nonorganic, untreated non-GMO seed. The same rule applies for the EU standards with one major difference. The EU requires that you obtain written prior approval for the use of the nonorganic seed from your certifying agency. This must happen prior to planting.

Another big issue with EU is the use of manure and compost. Only manure or compost coming from an on-farm source, an off-farm certified organic source, or an off-farm, nonintensive (not factory) source is allowed. What exactly qualifies as a "factory farm?" This has been the source of much-heated debate among producers, processors and certifiers alike. The EU definition states that, "… by-products from livestock farming, such as farmyard manure, may be used if they have come from livestock holdings producing in accordance with these [organic] guidelines. … Factory farming sources are not allowed. Factory farming indicates industrial management systems that are heavily reliant on veterinary and feed inputs not permitted in organic agriculture." EU standards and regulations give very specific guidelines for animal husbandry, including stocking rates and living conditions. Access to pasture land, or free range area, is very important. It is a good idea to check with your certifier before using any off-farm manure, so that they may verify its compliance with these standards.

The list of allowed substances varies slightly between the NOP and EU as well. Therefore, as with manure, you should check with your certifying agency before using any product. The NOP and EU both share the standard that states that any land treated with a prohibited substance must undergo a full 36-month transition before it can be eligible for organic certification. You may use a product on your crops that is allowed under the NOP but prohibited under the EU, thereby making any field to which that product was applied ineligible for EU verification for three years. 

I suggest checking with your buyer as early as possible to determine what markets they might be going into. If there is a chance that they might send your product to Europe, complying with the EU standards from the beginning will make things much easier if you need to obtain EU verification in the future.

You can access the National Organic Program Standards and the EU 2092/91 Standards and Regulations by visiting the following Web sites:

http://europa.eu.int/comm/agriculture/qual/organic/index_en.htm

http://www.ams.usda.gov/nop/indexIE.htm

Please send me your questions. Although I cannot personally answer them all, submissions will be reviewed and questions selected at random for this publication.

Send inquiries to Maralee Maldavs at mmaldavs@uniminds.com

Maralee Maldavs is the standards and materials specialist at OCIA International: http://www.ocia.org