Appraising the administrative burden of USDA organic certification

A descriptive analysis of Notice of Noncompliance data




Organic Food, Organic Certification, Notices of Noncompliance, Administrative Burden


Many of the challenges organic producers and pro­cessors experience are caused by how organic standards compliance is monitored and enforced—in particular, the administrative procedures that are mandated to verify that operation practices meet organic certification requirements. In this policy analysis, we examine noncompliance documenta­tion and verification by accredited certifiers under the U.S. Department of Agriculture (USDA). Lev­eraging a novel and unique compilation of “Notice of Noncompliance” letters issued to organic pro­ducers and processors, we find a preponderance of administrative violations, relative to substantive ones. We discuss how the finding may help explain contemporary transformations in the organic mar­ket, as larger agri-food entities’ capacity to absorb the administrative costs that frustrate smaller oper­ations may contribute to organic market “conven­tionalization” and consolidation.


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Author Biographies

David P. Carter, University of Utah

Assistant Professor; Programs of Public Affairs, Department of Political Science

Ian T. Adams, University of South Carolina, Columbia

Academic Affiliate; Department of Criminology and Criminal Justice

Seth Wright, University of Utah

Ph.D. Candidate; Department of Political Science

Tyler A. Scott, University of California, Davis

Associate Professor; Department of Environmental Science and Management



How to Cite

Carter, D., Adams, I., Wright, S., & Scott, T. (2022). Appraising the administrative burden of USDA organic certification: A descriptive analysis of Notice of Noncompliance data. Journal of Agriculture, Food Systems, and Community Development, 11(2), 235–242.