Regenerative Organic Certification

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

By: Vigne Sridharan

Updated May 23, 2019

New sprouts emerging from soil

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.

Three pillars of regenerative organic: soil health, animal welfare and social fairness

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.

Graphic showing the 4-year path to certification under the Regenerative Organic standardsThe 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).

  Regenerative Organic Certification Canadian Organic Standards
Cover Crops Use of cover crops on an annual basis and/or perennial crops across all producing acreage is required for Silver and Gold.Land maintains adequate cover year-round. Roots remain in the ground (if possible), otherwise, maintenance of dead/rolled cover crop and/or leaves is required. The soil fertility and biological activity shall be maintained or increased, through:a) crop rotations that are as varied as possible and include plough-down, legumes, catch crops and deep-rooting plants;

b) incorporation of plant and animal matter, including composted animal and plant matter and non-composted plant matter, specifically legumes, plough-down crops or deep-rooting plants within the framework of an appropriate multiyear rotation plan.

Crop Rotations Operations use crop rotations. For both annual and perennial systems, crop rotations are implemented to provide for pest management.Silver: Three-crop rotation or use of perennial system. Gold: Seven-crop rotation or use of perennial system.
Tillage Tillage should be infrequent and only occur when necessary. Tillage should never be deeper than 10 inches, except during preparation/planting of certain perennials (i.e. orchards, vineyards, etc.).Gold: No-till practices must be incorporated, with no more than one tillage operation (no deeper than 10 inches) every three years for annual crops. Tillage and cultivation practices shall maintain or improve the physical, chemical and biological condition of soil, and minimize damage to the structure and tilth of soil, and soil erosion.
Rotational Grazing Animals are used in high concentrations for brief periods of time (i.e. mob grazing). Pastures are divided into paddocks, with animals moved regularly. Stocking rates determined according to Demeter Biodynamic standards. Not addressed
Soilless Practices Aquaponics, hydroponics, and other soilless practices are not eligible for ROC. Exceptions are made for plants intended to be grown in water, such as water cress and certain ornamentals. Hydroponic and aeroponic productions are prohibited.
Container growing Container growing where crops are never integrated into a field for the majority of a crop’s life is not eligible for ROC. Container systems permitted.Soil used in a container system, with the exception of transplants, shall provide nutrients to plants continuously, contain a mineral fraction (sand, silt or clay) and an organic fraction, and support life and ecosystem diversity.
Manure sources The operation aims for self‐sufficiency in its manures and fertilizers. Importation of certain fertilizers may only be used as demand dictates and must be approved under USDA Organic standards.Manure can be directly deposited by rotationally grazing animals.

The use of liquid manure is not permitted.

Animal manure produced on the operation shall be used first, then organic manure from other sources may be used.If organic manure is not commercially available, non-organic manure is permitted from operations that do not tightly confine animals or deny them light. Organic operations should make it a priority to use manure obtained from transitional or extensive livestock operations, not from landless livestock production units or from livestock operations that use genetically engineered (GE) ingredients and/or GE derivatives in animal feeds.
Imported Nitrogen and Phosphorus In general, an operation does not import more than 36 lbs N/acre and 31 lbs P/acre over the crop rotation/cultivated area annually. The organic matter produced on the operation shall be the basis of the nutrient cycling program.Fertility recommendations and applications shall be based on observed, diagnosed and documented deficiencies.
Biodiversity Invasive plants and animals are to be monitored and managed.No hunting, fishing or gathering of rare or endangered species on the property, or harm to the species’ habitat. Not addressed
Wastewater and Waste Direct discharge of untreated wastewater into natural waterways or soil is prohibited.Burial or open burning of waste on site is not permitted. Not addressed
Synthetic Chemicals Substances not permitted under USDA Organic or equivalent standard are prohibited for pest control, weed control, fertilizer, or other application.Pesticides that are highly toxic to pollinators, as defined by Xerces Society’s “Toxicity of Common Organic-Approved Pesticides to Bees” are not allowed. Substances not included on the Permitted Substances List are prohibited for pest control, weed control, fertilizer or other applications.

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).

  Regenerative Organic Certification Canadian Organic Standards
Feed for Monogastrics Feed shall be from organic sources; Silver and Gold levels require a portion of feed to be from regenerative organic or on-farm sources. Feed shall be from organic sources.Pigs and poultry shall receive some vegetable matter besides grain.
Feed for Ruminants At least 50% of diet should be grass/forage/baleage/hay, with higher proportions for Silver and Gold levels (100% grass-fed for Gold certification). At least 60% of diet should be from hay, fresh or dried fodder, or ensiled forages (with minimum long-fibre requirement).Herbivores (adults) require at least 30% of their total forage intake to be grazed forages, with greater proportions during high forage growth periods.
Forced Feeding Forced feeding is not permitted, except for life-saving purposes. Forced feeding of ducks and geese is not permitted.
Access to the Outdoors Livestock should generally live, eat and sleep outdoors on pasture. Shelter may be provided by natural features or buildings.Shelters for avian species include perches for roosting and sleeping. Access to outdoors is required but livestock can be housed in barns.Requires appropriate resting and bedded areas to meet needs of animals and sufficient space to express normal patterns of behaviour.
Environment & Shelter Chickens require mobile coops that are moved to fresh grass regularly at least once per week during the grazing season. Chickens can be in a fixed building with access to pasture. If in mobile coops they must be moved at least every 4 days.
Temporary Confinement Livestock may be confined for a maximum of 2 hours to collect manure or milk dairy animals. Exceptions made when health or safety of animals is threatened.Operations do not use any type of temporary of permanent confinement that restricts mobility – cages, crates, tie stalls. Tie stalls are allowed in existing dairy barns but not in new construction.
Lighting Animals have exposure to natural light and are not exposed to artificial light for more than 16 hours. A minimum period of 8 hours of continuous darkness must be provided. Exposure to natural light required.  If artificial light is used, total duration of light shall not exceed 16 hours; must provide 8 hours of continuous darkness.
Physical Modifications Operations do not use the following methods: beak trimming; dehorning and de-budding; branding. Beak trimming allowed when necessary to control problem behaviour having negative impact on birds.Dehorning and branding allowed with requirements for age, methods and use of analgesics.
Health May not withhold medical treatment from a sick animal to preserve certification status.Vaccines are used for prevention of disease. In an emergency must use antibiotics if necessary to save life or prevent suffering on recommendation of vet.

Animal must be segregated; milk from treated animals may not be fed to calves.

May not withhold medical treatment from a sick animal to preserve organic status.Vaccines are used for prevention of disease. In an emergency must use antibiotics if necessary to save life or prevent suffering on recommendation of vet.

Animal must be segregated.  Products from sick animals or those undergoing treatment may not be fed to organic livestock.

Slaughter Specific details for pre-slaughter handling and slaughter/stunning methods that result in immediate insensitivity. Stress, injury and suffering shall be minimized
Transportation Transportation time is less than 13 hours. Food and water is not withdrawn for more than 12 hours prior to slaughter. Duration as short as possible. Requirements for feed, water and rest if transportation exceeds 5 hours.

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?

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