Action Alerts

November 11, 2019: Urge USDA to support Origin of Livestock Rule

It's time to close organic dairy loopholes and maintain high organic integrity. 

IOA is asking all certified organic farmers to stand with U.S. certified organic dairy farmers and submit comments to the USDA in support of a strong final Origin of Livestock Rule (OOL).  Not only is this important to dairy farmers—it is important to all organic farmers that rely on a strong organic label that maintains consumer trust.

Family organic dairy farmers across the country have suffered greatly over the past few years, partially because the USDA has failed to close regulatory loopholes that have allowed mega-dairies to skirt the rules (by continually transitioning conventional dairy animals) and have flooded the milk market causing lower prices to farmers.  Consumers have caught wind of these mega dairies and have questioned the integrity of the organic label.   We cannot let that happen!  We must fight for strong standards. 

All comments are due to USDA by December 2.

Please tell USDA that you support the proposed OOL rule

You may submit comments on this proposed rule via the Federal eRulemaking Portal at can access a copy of the proposed rule, previous public comments received, and instructions for submitting public comments by searching for docket number AMS-NOP-11-0009.

Comments may also be sent to: Paul Lewis, Standards Division, National Organic Program, USDA-AMS-NOP, 1400 Independence Ave. SW, Room 2642-So., Ag Stop 0268, Washington, DC 20250-0268; (202) 260-9151 (fax).

Individual comments to the USDA are best.   If you submit a form comment, they will count all carbon copies as one comment.   Please take 5 minutes to support organic dairies with a comment using the below template.  


INTRO:  A short introductory paragraph about you and your farm.  What do you grow, how long have you been certified, why organic integrity (strong standards) are important to you.

SUPPORT FOR THE RULE:  A statement that clearly puts forward your support for the OOL final rule.  You can use the below talking points:

  • I strongly support the proposed rule on Origin of Livestock Rule and its immediate implementation.
  • The OOL rule is needed to uphold consumers’ expectations about organic dairy by specifying that organic dairy animals must be raised organically from the last third of gestation or be raised organically for one year if transitioning a conventional herd to organic, which is allowed only once.
  • Once a distinct herd is transitioned to organic, all animals must be raised organically from last third of gestation
  • Cycling of dairy animals in and out of organic production is prohibited.
  • USDA should honor farmer-comments and strengthen, not weaken, the proposed rule.
  • The delay in issuing a final rule has resulted in economic harm for organic dairy farmers from low pay prices caused by an oversupply of organic enabled and encouraged by loopholes in the rule.
  • Rulemaking is critical to bring consistent enforcement, maintain a level playing field to all organic dairy producers, and uphold strong organic integrity for all organic farmers.

CLOSING:  A closing statement that reaffirms your support for the 2015 proposed Origin of Livestock Rule and asks for immediate or swift implementation.

Thank you!


The organic community has been working with USDA to improve the standards and transparency for transitioning dairy animals to organic milk production since 2013.  In 2015, USDA released a proposed rule seeking comments from the dairy industry on improving those standards.  1570 comments were received by USDA at that time, and almost all (99%) supported the regulation that would limit herd transition to a one-time event.  

IOA is an organization member of Organic Farmers Association, which has advocated for strong Origin of Livestock standards in their discussions with Congress and has asked USDA for consistency in applying OOL standards. This summer, OFA worked with Congress to include language in the FY20 Agriculture, Rural Development, Food and Drug Administration and Related Agencies Appropriations bill telling USDA to implement the FY15 Origins of Livestock final rule in 180 days.  In the Spring of 2019, Organic Farmers Association Farmer-Members passed this policy:

OFA SUPPORTS an immediate implementation of the Final Origin of Livestock Rule and asks the USDA to prioritize the following prior submitted comments in the writing of the Final Rule:

  1. A producer as defined by USDA NOP may transition bovine dairy animals into organic production only once.
  2. A producer is eligible for this transition only if they convert an entire established non-organic dairy operation to organic production at the same geographic location within a defined 12-month period. Once that transition has started, other non-organically certified animals cannot be added to the herd.  
  3. This transition must occur over a continuous 12-month period prior to production of milk or milk products that are to be sold, labeled, or represented as organic.
  4. A producer must not transition any new bovine dairy animals into organic production after the end of the 12-month transition period.
  5. A producer is not eligible for the exemption if it has been used by a Responsibly Connected person who has a 20% or more ownership share in their legal entity.
  6. The certifying entity will file an organic system plan prior to the start of transition and the transition process is overseen by the certifier as part of their accountability.
  7. Transitioned animals must not be sold, labeled, or represented as organic slaughter stock or organic bovine dairy animals.
  8. If organic management of the dairy animal, starting at the last third of gestation or at any other time it has been organic, is interrupted, the animal cannot be returned to organic certification.
  9. Split bovine conventional and organic milking herds at the same location are prohibited.
  10. Once the regulation is finalized all entities will be required to immediately meet the requirements of the Final Rule. There will be no implementation period.

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