Agriculture Environment Policy Update

Can “Certified Transitional” Incentivize Organic Farming?

Did you know a farm has to be organic for three years before it can be Certified Organic? First-year AFE student Ariella Sela makes the argument for a USDA-backed Transitional Certification to help grow the organic food industry in the U.S.

Organic sales in the United States are just shy of $50 billion and have continued to climb since 1997, the year the Organic Trade Association (OTA) began tracking them[i]. Unfortunately, we may not be able to sustain this growth, as there is a considerable shortage of domestic supply, with only about 1% or about 5 million acres of U.S. cropland and pasture that is certified organic[ii],[iii]. If we care about organic agriculture, how do we work to increase our domestic supply? Enter: transitional organic. This refers to the process of converting conventional cropland and pasture to organic land. Using the National Certified Transitional Program to ease the economic barrier for farmers to transition will change the game for the amount of organic food and fiber that comes out of this country.

In order to apply for organic certification, farmers must comply with United States Department of Agriculture (USDA) organic standards for three years. Three whole years. This means that even if farmers implement high-cost and labor-intensive organic practices such as hand weeding and pest removal, their products cannot be labeled as organic nor can they receive organic price premiums for three years. This delayed return on investment is a key barrier keeping farmers from converting to organic.

To address this issue, the USDA and OTA launched the National Certified Transitional Program (NCTP) in January 2017. This program certifies farms that use organic methods on land that has not yet reached the three-year threshold for organic certification. This certification aims to create a market for products that come from transitioning farms and provide oversight to the transition process[iv]. However, about a year after the program’s announcement, the Chief of the USDA’s Audit Services Branch, Jeffrey Waite, announced that the  National Certified Transitional Program was withdrawn without any explanation. Before the USDA could even determine whether or not this program would be successful, it was rescinded.

A transitional certification would allow farmers to market and sell their products as Certified Transitional goods for a premium price. This could work in two ways. First, buyers such as food manufacturers, will purchase Certified Transitional raw materials for use in their processed goods. Second, these buyers will lock down contracts now for goods they will purchase once the land is transitioned. If the certification works as planned, it has the potential to build long-term capacity for organic supply chains. While there are other government-sponsored programs to address organic certification costs, they are not comprehensive. For example, the Organic Certification Cost Share Program (OCCSP) reimburses producers or handlers of agricultural products obtaining or renewing their organic certification, covering only up to 75% (a maximum of $750) of the costs[v]. While certainly useful, the program only reimburses expenses paid during the year the farm achieves certification, not the two years prior. Equipment, materials, supplies, transitional certification fees, late fees and inspections necessary to address regulatory violations are ineligible for reimbursement[vi]. OCCSP also does not provide premiums producers might receive for certifying their products as Transitional.

Before this government-sponsored transitional program was even announced, the private sector had started to work on a consumer-facing Certified Transitional label. Kellogg’s Kashi brand and Quality Assurance International (QAI), a third-party organic certifier, certified both farms and products that contained ingredients from transitioning farms as transitional organic. This came in the form of a green “t” seal on the front of Kashi’s Dark Cocoa Karma Shredded Wheat Biscuits cereal. This product featured the first commercially sold product with a Certified Transitional ingredient: hard red winter wheat. The USDA could not get behind this consumer-facing seal for a variety of reasons, including the possible dilution of the value of organic certification[vii],[viii].


While Kashi and Quality Assurance International were the first, many other third parties now offer their own version of a transitional certification. These labeling schemes can be inconsistent between certifying organizations and rely too heavily on the value of their own certification to punish farms for evading Certified Transitional regulation. A USDA-sanctioned transitional standard that stops at the farm, meaning no consumer-facing seal, would create harmonization and consistent oversight over each of these programs to prevent bastardization. According to an article published in The New Food Economy, Nate Lewis, Director of Farm Policy at the Organic Trade Association, stands by an official USDA-approved national standard being more enforceable and having greater consequences since the USDA has the power to fine, audit for fraud, and implement disciplinary measures[ix].

Skeptics fear that some farmers may never fully transition to organic production and simply use the transitional certification to access premium markets[x],[xi]. Dr. Tim Griffin, Associate Professor in Nutrition, Agriculture, and Sustainable Food Systems at the Friedman School of Nutrition Science and Policy at Tufts University, isn’t so sure about any type of official transitional certification in the marketplace, especially one issued by the government. Griffin notes that “implementing and monitoring [this type of a certification] would be very problematic” and may undermine the value that certified organic farmers have been bringing to the table for years. In fact, the Organic Dairy Producers Alliance threatened to sue the USDA over the transitional certification for adulterating the value of their organic products. This lawsuit is rumored to have been one of the main reasons why the USDA took no further action on Certified Transitional[xii],[xiii],[xiv].

Griffin also says that for some sub-sectors such as dairy, funding for organic transitioning may also come from private industry. This begs the question of whether or not the public sector is the only avenue to pursue this type of program. According to Christina Skonberg, a Senior Sustainability Analyst at General Mills, the multinational food manufacturer recently invested in the transition of 34,000 acres of conventional farmland in South Dakota to certified organic by 2020 for use in their line of Annie’s organic packaged foods once the land’s transition is complete. “This is a long-term contract and we’re hoping that this kind of guarantee helps minimize uncertainty and buffer risk for the farmers operating the land”, says Skonberg. General Mills is pursuing this project without a transitional certification. But this is one extraordinary case[xv]. Will other food companies rise to help meet this ever-growing demand for organic agriculture?

Though not without its downsides, an official government-regulated Certified Transitional program could be a tremendous advantage to growing the U.S. organic industry at large. It would help supply more products that consumers are demanding: food free from synthetic pesticides, herbicides and artificial ingredients. While organic agriculture isn’t perfect, it largely works to improve the soil in which crops are grown and provides many environmental benefits[xvi]. Transitional, even in its name, supports long-term thinking, rather than just working toward short-term market gains. While plans for a government-issued transitional certification are currently on hold, Griffin says that “at the USDA, nothing’s ever completely dead,” so something like this may pop back up in the future. Only time will tell.


[i] McNeil, M. (2018, May 18). Maturing U.S. organic sector sees steady growth of 6.4 percent in 2017 | OTA. Retrieved March 31, 2019, from

[ii] USDA ERS – Documentation. (2016, September 22). Retrieved March 31, 2019, from

[iii] USDA National Agricultural Statistics Service. (2017, September). Certified Organic Survey, 2016 Summary. Retrieved March 31, 2019, from

[iv] McNeil, M. (2017, January 11). USDA approves new transitional certification program to foster organic growth | OTA. Retrieved March 31, 2019, from

[v] USDA Farm Service Agency. (n.d.). Organic Certification Cost Share Program (OCCSP). Retrieved March 31, 2019, from Organic Certification Cost Share Program (OCCSP) website:

[vi] USDA Farm Service Agency. (2017). Organics Fact Sheet: Organic Certification Cost Share Program, October 2017. Retrieved March 31, 2019, from

[vii] What is Certified Transitional Farming? – Kashi | Transitional Trade. (n.d.). Retrieved March 31, 2019, from

[viii] Fusaro, D. (2017, October 3). A Certified Transitional Organic Program Remains in Limbo. Retrieved March 31, 2019, from Food Processing website:

[ix] Fassler, J. (2017, February 28). Less than 1% of U.S. farmland certified organic. Why don’t more switch? The New Food Economy. Retrieved from

[x] Mirenda, J. (2017). Organic Trade Association USDA Certified Transitional Program | OTA. Retrieved March 31, 2019, from

[xi]Organic Trade Association USDA Certified Transitional Program Factsheet. (2016, June 27). Retrieved March 31, 2019 from

[xii] Golbitz, P. (n.d.). Expanding the U.S. Organic Grain Sector: Challenges and Opportunities. Retrieved from

[xiii] Fusaro, D. (2017, October 3). A Certified Transitional Organic Program Remains in Limbo. Retrieved March 31, 2019, from Food Processing website:

[xiv] Mathews, R. (2017, April 5). Western Organic Dairy Producers Alliance Stalls USDA/OTA National Certified Transitional Program (NCTP). Retrieved March 31, 2019, from Cornucopia Institute website:

[xv] Halloran, A. (2018, March 19). General Mills is transitioning 53 square miles of South Dakota farmland to certified organic. Retrieved March 31, 2019, from New Food Economy website:

[xvi] Food and Agriculture Organization of the United Nations. (n.d.). Organic Agriculture: What are the environmental benefits of organic agriculture? Retrieved March 31, 2019, from

Ariella Sela is a first-year MS/MPH student in Agriculture, Food, and Environment at the Friedman School. She is deeply interested in understanding what it takes to scale sustainable agriculture in order to improve social, environmental, and economic outcomes in the United States and around the world. She comes to Tufts after working as a consultant, specializing in corporate sustainability reporting for companies across the food value chain.

The Friedman Sprout is a monthly student run newspaper that aims to serve the student population at the Friedman School of Nutrition Science and Policy, prospective students, and alumni. Our mission is to report on newsworthy information that affects the Friedman community including nutrition research, food policy, internship and volunteer opportunities, as well as school events. Our editorial slant is that of sustainability in food and nutrition.

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