One Standard to Rule Them All, or Just Another Label?

By: Vigne Sridharan

Updated May 23, 2019

Photo by Mike Smith

In recent years, leaders in the organic sector around the world have debated how to best address challenges within the sector and define the next phase of organic agriculture, known as “Organic 3.0”.  (You can read about the history of this debate in our blog post on Organic 3.0.) How can we scale up organic agriculture in a sustainable way, while rewarding innovation and leadership within the sector?

One such effort in the United States is the new Regenerative Organic Certification (ROC), a standard that intends to go beyond the United States Department of Agriculture’s (USDA) organic standards.

The ROC is being put forth by the Regenerative Organic Alliance (Alliance), led by the Rodale Institute, Patagonia and Dr. Bronner’s.

The working definition of “regenerative” as described by Kevin Boyer, project director at the newly established Regenerative Agriculture Foundation, is “any system of agriculture that continuously improves the cycles on which it relies, including the human community, the biological community and the economic community.”

Jeff Moyer, executive director of the Rodale Institute says, in an interview with Civil Eats, that this concept encourages farmers to improve their practices in ways that the USDA’s organic regulations do not require.

“Organic is a fairly static standard. Once you become certified, you’re in the club and there’s no incentive to move beyond that or continuously improve,” Moyer says.

The Alliance created the Regenerative Organic Certification (ROC) in response to a number of factors, including the US National Organic Standards Board’s controversial vote to allow  hydroponics in the certified organic industry, and the Trump government’s decision to withdraw a stringent organic animal welfare rule.

Despite their frustrations with the National Organic Program (NOP), the Alliance still recognizes its importance and believes it should be strengthened.

“We want to continue to support the work of the NOP, but we believe there is an option for farmers who have been doing more than the program requires for decades to showcase the extra things they do” says Rose Marcario, CEO of Patagonia, in an interview. “Think of ROC as organic plus.”

“The ROC standard was created to fill the gaps left behind by current organic certification standards”, says David Bronner, a board member of the Regenerative Organic Alliance and CEO of Dr. Bronner’s, a natural soap brand. “I hope [they] will…restore the original intent of organic agriculture.”

Organic agriculture’s original intent, according to the Alliance, was informed by pioneers such as J.I. Rodale who believed in ecological processes, fair labour practices, a greater level of compassion for animals and a mandate to improve soil health. “Much of that got lost when the federal organic regulations were set,” says Bronner.

While US organic standards are set and enforced by the federal government, Canadian Organic Standards (COS) are developed and voted on by farmers and industry representatives through the Canadian General Standards Board’s Committee on Organic Agriculture. This process, managed by the Organic Federation of Canada,  involves extensive industry consultation and recommendations from independent working groups, and has allowed Canada to keep certain practices that are not part of the NOP (e.g. animal access to outdoors, hydroponics). However, some Canadian farmers still echo the disillusioned sentiments of the ROA.

“The COS should be stronger in emphasizing soil health and animal welfare. The word ‘organic’ has been watered down and only embodies some of the original principles of organic agriculture,” says Mike MacGillivray from Kirkview Farms, a 96-acre family farm operating on the principles of regenerative agriculture. MacGillivray is hopeful that a model such as the ROC will be adopted in Canada as well.  But if the COS is made more stringent, what does that mean for organic production and import? Thorsten Arnold, an OCO board member and representative on the Canadian Organic Value Chain Roundtable Task Force on Organic 3.0 explains the dilemma: “If the Canadian Organic Standards become more stringent, many organic farmers may price themselves out of the global market and reduce the area under organic production. This process would require a political battle within the organic sector, which may not be our goal.  The other option is to create a two-tier system like ROC that rewards farmers for going above and beyond the standards, but this may confuse consumers and have an impact on the organic brand. Ultimately, we need both mechanisms to have an impact.”

What is the Regenerative Organic Certification?

The three overarching goals of the ROC are to facilitate the adoption of practices that increase soil health to sequester carbon over time, increase animal welfare, and provide economic stability and fair labour conditions for farmers, ranchers and workers. It aims to create environmentally and economically resilient production ecosystems and communities.

The ROC is a tiered system, so users can attain different certification levels. Taking the  NOP as a baseline requirement, it adds criteria relating to soil health and land management, animal welfare, and farmer and worker fairness.

The framework provides a 4-year transition plan with the goal that any producer currently categorized as chemical, transitional organic, organic, or regenerative organic can eventually achieve a “gold” regenerative designation. According to the framework, this tiered approach enables producers to adjust and adapt their practices over time and allow for continuous improvement. It aims to reduce the necessity for multiple standards’ labels on food products by encompassing many of them in one ROC seal.

Mixed Reactions to the ROC

Although the sustainable agriculture community broadly supports the ROC framework, some have raised concerns regarding the redundancy of the ROC label and its potential to confuse consumers in a market already fraught with multiple labels.

General Mills, Inc., the fourth-largest producer of organic and natural foods, says in its ROC comments, that while they appreciate the framework’s holistic and comprehensive approach toward regenerative agriculture, they are concerned that “with a growing litany of environmental and social standards for food products, yet another eco label, with multiple tiers within, will further complicate the landscape of third-party labels for consumers.”

The Minnesota based multinational manufacturer acknowledged in their statement that “organic is a strong foundation of regenerative principles” but also raised concerns about “reserving ROC eligibility for a small subset of farmers who operate less than 1% of farmland in the U.S”.

The Organic Trade Association (OTA) echoed similar sentiments about the ROC label inciting consumer confusion around the meaning of “certified organic.”  They cautioned that the additional certification might lead to misconceptions that existing organic standards do not cover animal welfare and soil health. 

There is also debate about whether standards should be based on specific practices versus outcomes based standards. It has been argued that a practice-based standard acts as a box-ticking activity and curbs innovation whereas an outcomes-based standard would allow farmers the autonomy and creativity to employ techniques they feel appropriate to achieve a desired outcome. Currently, the ROC is largely practice- based, but it also incorporates baseline and ongoing soil testing to assess soil health.

Overall, much of the organic sector seems to agree that the ROC label could be beneficial but that there is more work to do in order to ensure its success and that of the organic sector as a whole. In the meantime, comments on the program also suggested a need for all parties to work collectively to strengthen the USDA’s existing standards.

How does the ROC compare to the US and Canadian Organic Standards?

The Canadian Organic Growers recently reviewed the ROC standards in a detailed comparison with the COS, looking at the specific language included in both. Below is their analysis:

Table 1. Soil Health and Land Management standards in the Regenerative Organic Certification (ROC) framework, as compared to the current version of the Canadian Organic Standards (COS).

Adapted from the Framework for Regenerative Organic Certification (August 2018: Pilot Program Version) and the Canadian Organic Standards (Organic production systems: General principles and management standards, CAN/CGSB-32.310-2015). Republished with permission from The Canadian Organic Growers Magazine.

Table 2. Animal Welfare standards in the Regenerative Organic Certification (ROC) framework, as compared to the current version of the Canadian Organic Standards (COS).

Adapted from the Framework for Regenerative Organic Certification (August 2018: Pilot Program Version) and the Canadian Organic Standards (Organic production systems: General principles and management standards, CAN/CGSB-32.310-2015). Republished with permission from The Canadian Organic Growers Magazine.

One of the major differences between the ROC’s framework and the USDA and CFIA’s organic standard is the practice of soilless growing systems. While these practices are completely prohibited in the ROC, hydroponics and aquaponics are permitted in the NOP and aquaponics in the COS.

Both US and Canadian standards prohibit the use of synthetic inputs, but allow rare exceptions in specific cases where organic input may not be available, such as for livestock bedding, enzyme substrate, or seeds. The ROC completely prohibits their use or the use of any additives derived from genetically modified sources under any circumstance.

The largest gap between standards is the farmer and worker fairness pillar. This pillar is considered by some to be unnecessary.  “It seems redundant to include specifications around worker fairness in the organic standards when existing Canadian employment regulations exist that hold all employees and workers to fairly  high standards” says Hugh Martin, former organic specialist lead at the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA). However, other OCO members, such as Thorsten Arnold, point out that many organic products found in the grocery store are imported from other parts of the world, where labour standards might not be as rigorous.  “As a vegetable producer, our main competitors are from the US. California’s organic producers rely heavily on undocumented labourers without any labour protection, as is common within the US. These products carry the organic label under the US-Canada equivalency agreement.”

A criticism of the Canadian Organic Standards is that some elements of the organic standards are more enforceable than others. While soil health and crop rotations are described in the Canadian Organic Standards as best practices, these criteria are particularly hard to inspect without more specific requirements.

There is a fine balance between creating specific standards with a high level of detail, and making it possible for a diverse group of producers to meet those standards. From the Canadian perspective, Martin says that it is difficult to set detailed federal standards for a country as expansive and agriculturally diverse as Canada. He cited the creation of the Standards Interpretation Committee as an attempt to provide clarification to those who require it.

The ROC criteria is exhaustive and detailed, in response to their creators’ sentiment that current federal standards are vague and unclear. However, Stuart McMillan, a Canadian producer taking part in the ROC pilot, describes that there is enough flexibility for regional adoption: “In our pilot conference calls, the many participants asked questions and raised concerns about how such a specific standard could be equally applied to grain farming in Canada, cocoa farming in Ecuador, wine in the US and oil palm in West Africa, but we all agreed that the goals could be adapted and attempted. We all felt that the goals were appropriate and we would make them regionally suited.”

What does ROC mean for the future of organic food?

Given the sentiments raised during the public comment period, the burning question then is whether the ROC label will gain traction with consumers and retailers and grow to achieve its founders’ goal of creating the highest bar for organic production in the US.

The Alliance hopes that ROC will become the “north star” label for the industry  and eliminate the need for multiple labels such as non-GMO, fair trade, animal welfare approved, and more.

However, many of the parties who participated in the ROC public comments period feel that the Alliance has work to do in a number of areas, from dealing with equivalencies to educating consumers to navigating enforcement, auditing and certification.

The Alliance’s next step is to run a pilot program with interested farmers and retailers, set to launch in the first quarter of 2019. Dr. Bronner’s and Patagonia Provisions are among 80 companies that applied to participate in the pilot program. NSF International will act as the ROC certifier during the pilot program with the aim to have other organic certifiers join once kinks are worked out.  OCO, along with a number of Canadian producers expressed interest in participating in the pilot program, but at the time we were told the program was limited to US producers. Update: The pilot has expanded to include producers from around the world, including Legend Organic Farm in Saskatchewan, which produces for Canadian-owned Nature’s Path.

It may be another year until the ROC seal begins to appear on products and among producers and potentially an additional year until the Alliance can accurately gauge consumer reaction. Would you welcome the idea of an all-encompassing seal?