The NOP Import Certificate

What You'll Learn

• What the NOP Import Certificate is, what it proves, and which regulatory requirement it satisfies
• Who initiates the request, who issues the certificate, and what system it must be generated in
• The required data fields and the difference between shipment-specific and standing certificates
• The process from exporter request to CBP-ACE filing and the importer’s final check
• The timing requirements and the most common errors that trigger flagged entries or NOP investigations
• How NOP uses import certificate data to monitor organic market volumes and detect fraud

The NOP Import Certificate is more than a filing formality. It is the documentary link between a specific shipment and the certifying agent who verified it, and the data it generates gives the NOP a verifiable, auditable record of every organic import entering the national market.

What the NOP Import Certificate Is

The NOP Import Certificate is an electronic document generated in the USDA Organic Integrity Database (OID) by the exporter’s certifying agent. It provides trackable, auditable proof that a shipment of organic agricultural products was verified as compliant by a certifying agent before the shipment left its country of origin. The certificate is then submitted to U.S. Customs and Border Protection (CBP) as part of the standard import entry filing.

The NOP Import Certificate is not a customs document generated by CBP. It is an organic compliance document. Its purpose is twofold: to demonstrate that a specific shipment’s organic status was verified at the source, and to create a data record that NOP can use to track the volume and origin of organic imports and detect discrepancies indicative of fraud.

Three regulatory requirements govern how the certificate must be generated and used:

1. The certified exporter must obtain the NOP Import Certificate data from their certifying agent before the shipment is exported from the originating country.¹
2. Only certifying agents accredited by the USDA, or foreign certifying agents authorized under an organic trade arrangement, may issue an NOP Import Certificate.¹
3. The importer must declare the shipment as organic to CBP by entering NOP Import Certificate data into CBP’s Automated Commercial Environment (ACE), and only certificate data generated through the Organic Integrity Database is valid for that purpose.²

An NOP Import Certificate must include the following data:³

• Organic standard the product is certified to
• Destination city and state in the U.S.
• Effective dates
• Country from which the product is exported
• Exporter name, address, and NOP ID
• Recipient name (importer of record) and NOP ID
• Name of the certifying agent issuing the NOP Import Certificate
• Total net weight of the shipment, or projected net weight if the certificate covers multiple shipments
• Number of containers
• Harmonized tariff code, when applicable
• Product name as it appears on the label
• Shipping identification, such as lot numbers
• NOP ID for the final handler of the product
• Certifying body of the final handler
• Any applicable remarks and compliance statements
• Unique numerical identifier for the NOP Import Certificate (NOP-IC number)

Annotated NOP Import Certificate Example

Shipment-Specific and Standing Certificates

An NOP Import Certificate may cover a single specific shipment, or it may cover multiple shipments across a defined time period and up to a specified volume ceiling.³ Either way, the certificate must be issued before the shipment departs the exporting country.¹ The certificate’s start date must be on or before the expected date of departure; the end date must be set to cover the expected date of arrival in the U.S., at most 12 months after the start date. For multiple shipments, project the date the last shipment will arrive at the destination. If 12 months is insufficient, an additional six-month extension is permitted after the initial 12 months.³

Certificates must be valid when the product arrives in the U.S. An expired certificate cannot be used to clear a shipment, regardless of what it covered when it was issued. Certifiers and exporters must build realistic transit time and buffer for unexpected delays into every certificate’s end date. Updating some information, including the end date, after issuance is permitted, but updates need to be done before the end date of the certificate.³ Talk to your certifier if you have concerns about the end date or need adjustments to the certificate, and do so before it expires, since a certifier generally cannot edit a certificate once its end date has passed.

Steps to the Import Process

The NOP Import Certificate follows a specific sequence from the foreign supply chain to U.S. government systems. The physical shipment and the electronic certificate move independently. There is no requirement that a physical copy of the certificate accompany the shipment.

Step 1: The Exporter Requests the Certificate

Before the shipment departs the origin country, the certified exporter submits export shipment data to their certifying agent and requests an NOP Import Certificate. All export documents (invoices, packing lists, bills of lading) must identify the products as organic at this stage. The exporter must request early enough to allow the certifier time to evaluate the request, generate the certificate, and for the exporter to deliver it to the importer before CBP’s filing deadlines.

Step 2: The Certifier Reviews and Issues the Certificate

The certifier reviews the request and determines whether the export complies with the USDA organic regulations. The certifier must have a documented organic control system for intaking and approving or rejecting NOP Import Certificate requests, and may request additional information before approving a request.⁴ The certifier issues the NOP Import Certificate through the OID only if the export is compliant, and may only certify amounts of product that are verified to be organic. For countries with organic equivalency arrangements, the certificate is generated in the Global Integrity Database rather than the USDA OID, but the data flows to the same NOP systems.

Step 3: Electronic Transfer to the U.S. Importer

The certifier electronically transfers the finalized NOP Import Certificate to the exporter, who then electronically transfers it to the U.S. importer. No physical copy is required to accompany the physical shipment.

That NOP import certificate needs to originate from the certifier in the country that it’s coming from before it’s shipped. So you can’t receive something and then go back and make the paper trail work. You need to do that work up front.

Step 4: CBP-ACE Filing and NOP Verification

The U.S. importer (or their designated customs broker) uploads the NOP Import Certificate data into CBP’s Automated Commercial Environment (ACE) as part of the standard import entry filing. The importer also verifies at this stage that the shipment is associated with a valid, finalized certificate.⁵ Product arriving without a valid import certificate must be immediately re-exported, destroyed, or donated (with restrictions).³

Step 5: Importer Cross-check

The importer confirms that the details of the shipment arriving in the U.S. match the details on the NOP Import Certificate before the product is received as organic.

Validating the Certificate

The OID generates NOP Import Certificates in draft status before they are finalized. Draft certificates carry “(draft)” appended to the certificate number and are not valid for trade under any circumstances. A finalized certificate must be in place before the importer submits the CBP-ACE filing.

The CBP-ACE system also generates automatic notifications for certain data problems, such as an organic tariff code entered without matching NOP Import Certificate data. Beyond those automatic flags, verifying each shipment against a valid certificate is the certified importer’s responsibility.

Paper import certificates may be issued only in limited circumstances when the OID system is unavailable, and are subject to a separate NOP procedure that applies to the issuing certifier.⁶ A certificate generated outside the OID is not a valid NOP Import Certificate for CBP filing purposes, regardless of how detailed or authentic it appears, except in limited circumstances when the NOP has alerted certifiers that the OID system is unavailable.⁶ A certificate is also only valid, in practice, when its data matches the CBP Entry Summary (Form 7501) filed for the shipment in ACE; a mismatch between the two will flag the entry.

What Makes an NOP Import Certificate Valid?

✓ Valid NOP Import Certificate	✗ Not a Valid NOP Import Certificate
Generated in the USDA Organic Integrity Database (or Global Integrity Database for trade partners)	Paper certificate not generated through the USDA Organic Integrity Database (except in certain limited circumstances6)
Issued by a USDA-accredited certifier (or certifier authorized under a trade arrangement)	Certificate generated by an unauthorized certifier
Carries a unique 21-character NOP-IC number (no “(draft)” in the number)	Draft certificate, NOP-IC application, or other documentation used prior to issuance
Issued before departure of the shipment from the origin country	Certificate issued after departure of the shipment from the originating country

Responsibilities by Actor

NOP Import Certificate: Review of Actions and Timing

Action	Responsible Party	Timing
Request NOP Import Certificate	Exporter	Before departure
Issue NOP Import Certificate in OID	Exporter’s Certifier	Before departure
Transfer NOP Import Certificate to Importer	Exporter	Before CBP filing deadline
Upload NOP Import Certificate data to ACE	Importer or Customs Broker	Per CBP filing requirements
Certify shipment is associated with a valid NOP Import Certificate	Importer	Upon receipt of shipment
Retain records for inspection	Both Exporter and Importer	For 5 years minimum7

Responsibilities of the Exporter:

• Submit the NOP Import Certificate request to their certifying agent before the shipment departs.
• Transfer the final NOP Import Certificate to the importer before the importer’s CBP filing deadline.
• Identify all products as organic on all export documents: invoices, packing lists, bills of lading, and CBP entry data.
• Maintain copies of all NOP Import Certificates and make them available for inspection by NOP and their certifier.
• Track cumulative volume for time-based certificates so shipments do not exceed the amount authorized on the certificate.
• Expect NOP Import Certificate records to be audited by their certifier during the annual inspection.

Responsibilities of the Importer:

• Receive the NOP Import Certificate from the exporter and retain a copy for records.
• Upload NOP Import Certificate data into CBP-ACE, or delegate this to a licensed customs broker, but the importer remains accountable regardless of who files with CBP.
• Verify that each shipment received is associated with a valid, finalized NOP Import Certificate, and that its data matches the CBP Entry Summary (Form 7501).
• Verify that the shipment has not been treated with a prohibited substance or irradiated since export.
• Maintain copies of all NOP Import Certificates and make them available for inspection by NOP and their certifier.
• Expect NOP Import Certificate records to be audited by their certifier during the annual inspection.

What Happens When a Shipment Arrives Without a Valid Certificate

The organic importer is responsible for confirming that every shipment received is associated with valid NOP Import Certificate data.⁵ When a shipment reaches a U.S. port without a valid certificate, the consequence is the same, no matter the cause. Whether the certificate expired in transit, carried a draft number, came from an unauthorized certifier, or was never issued at all, the product cannot be sold, labeled, or marketed as organic. It also cannot be relabeled and sold as nonorganic product to recover part of its value.³

This is not something the importer can fix after the fact. A certificate has to be issued before the shipment leaves its country of origin, so there is no way to obtain or extend one once the product has arrived. A shipment that shows up without valid certificate data will also flag the CBP entry against NOP’s records, which can pull the shipment into a compliance review. Notify your certifier rather than trying to resolve the situation informally, and document what happened and how the product was handled.

What the importer can still control is what happens to the product next. Three options are available, and each one has to be documented:³

• Re-export the product. Keep the shipping documentation for the outbound shipment, confirm the outbound quantity matches the bill of lading or packing list, and file CBP Form 7512 if the shipment is under CBP control.
• Donate the product. This option is available only to certified importers. Keep receipts from the receiving charity or nonprofit for the exact quantity shown on the bill of lading or packing list.
• Destroy the product. Keep a CBP Certificate of Destruction if the shipment is under CBP control, along with your own documented evidence that the product was disposed of.

None of these options recovers the organic value of the shipment, which is why prevention is the only real remedy. Confirming a finalized, valid certificate before the product ships, and setting end dates that account for transit delay, costs far less than losing an entire shipment at the dock.

How NOP Uses Import Data

The data flowing through the OID and CBP-ACE gives NOP a verifiable record of every organic shipment entering the United States, tied to a specific certified exporter and a specific certifying agent. NOP accesses CBP-ACE data and cross-validates it against certifier-approved data in the OID to monitor and identify indicators of potential fraud. This allows NOP to track market trends, identify anomalies in import volume by origin and commodity, and initiate traceability investigations.

Specific data quality problems that flag entries for NOP investigation include:

• Discrepancies between NOP-IC data and U.S. Customs import data, such as mismatches in final handler, exporter, or importer identity
• Incorrect or fabricated data in place of valid NOP-IC numbers
• Missing shipping identification that would connect the NOP-IC to a specific U.S. Customs entry

A typographic error in the NOP-IC number, or a name mismatch between the importer on the NOP-IC and the importer in the CBP entry, can trigger a review even when the underlying shipment is fully compliant.

Conclusion

The NOP Import Certificate is the documentary foundation of import compliance, linking a specific organic shipment to a verified certifier, a verified exporter, and a verifiable record in the Organic Integrity Database. Understanding the import process, the timing requirements, the required data fields, and the ACE filing obligation gives importers what they need to manage this without compliance errors that delay shipments or trigger investigations.

The most common problems are avoidable: draft certificates submitted to ACE, end dates set without accounting for transit delay, and data-entry mismatches between the NOP-IC and the CBP entry. Build a review step into your process before every filing, and keep your certifier current on the volume and timing of every import relationship. Ensuring that a valid NOP-IC is available for every import will protect your business.

Action Items

• Get import certificates in place before departure; a certificate issued after departure is not valid.
• Request import certificates early.
• Set certificate end dates conservatively, accounting for transit delay.
• Ensure “(draft)” is not included in the NOP-IC number.
• Match all NOP-IC data exactly.
• Make a plan for any imports arriving without a valid NOP-IC.
• Store records for five years.

Dig Deeper Resources

U.S. Department of Agriculture, Agricultural Marketing Service. Organic Integrity Database U.S. International Trade Commission. Harmonized Tariff Schedule of the United States