The length of time it takes for OMRI to review a Change Report varies based on the complexity of the change. Generally, administrative changes (e.g., label updates) take less time to review than technical changes, such as changes to a product’s formulation or manufacturing process. 

Most Change Reports are processed in the order in which they are received. Due to a large number of reviews, it is currently taking longer than usual for reviews to begin. In order to help applicants understand what to expect, OMRI updates the table below weekly with information about expected wait times.

Table last updated December 16, 2024  

Once the review begins, you will be contacted if any additional information is needed. The best way to expedite the review is to submit a complete Change Report with all supporting documentation, and to respond quickly and completely to any requests for more information from OMRI staff. 

Per §2.9 of the OMRI Policy Manual, OMRI Listed suppliers are responsible for notifying OMRI at least 60 days prior to the release of any product affected by a change.  

While OMRI does not endorse or recommend any particular consultant, we maintain a list of consultants that have interest in helping with OMRI applications. Many have helped or have been involved in submitting applications to OMRI in the past. You may find the list of consultants here.

Products that are currently OMRI Listed® to one standard can be reviewed to additional standards (U.S. National Organic Program or Canada Organic Regime). See the Review Cost page for the most current information about fees associated with review to additional standards.

OMRI reviews input products for use in organic crop, livestock and processing production. However, some input products may be considered out of OMRI's scope for various reasons. Here is a list of product types that are considered to be out of scope for OMRI to review:

• Devices, technologies or services. 
• Products that are not relevant to the organic standards, for instance bug spray for humans, or beauty care products. A product such as cat litter would be considered out of scope unless the label had a specific agricultural use that complies with the organic regulations. Products intended for use in aquaculture are out of scope for reviews to the NOP or COR standards.
• Products that are more appropriate for an organic certifier to review, including: 
  • Products in the NOP Processing and Handling Scope that are certified organic by a USDA accredited certification agent, or that would be required to be certified organic in order to be used in organic processing (e.g., fruit coatings that contain agricultural materials not on the National List or food-contact soap produced from certified organic oils). 
  • Sanitizers, disinfectants and other cleaners that do not appear on the National List that are intended for facility use (e.g. surfaces, equipment, etc.). These cleaners may be permitted for certain uses by organic certifiers, provided that measures are taken to prevent contact with organics crops, livestock or other products. 
  • Facility pest controls that do not appear on the National List. These materials may be permitted under specific circumstances by organic certifiers, provided that measures are taken to prevent contact with organic products.

OMRI’s Review Program routinely encounters difficult technical issues for which industry experts are consulted for guidance and interpretation of the organic standards. When a product review has an issue that is outside of OMRI's or other current written standards, OMRI’s policy is to place the product under “Unresolved” status for a maximum of 275 days while OMRI gathers evidence to help guide the review. If OMRI is unable to resolve the issue within the given timeframe, the application is forfeited and OMRI will refund the application fees. In certain cases where interpretation is needed from another regulatory body before making a decision, OMRI designates an unresolved issue as “Beyond Resolution,” and will no longer accept applications that pertain to that particular issue until the issue becomes resolved by the applicable regulatory body.

The following are current issues that OMRI considers to be Beyond Resolution, based on NOP standards:

ISSUE #1: Passive pheromone dispensers
Use Class: Crop Pest, Weed, and Disease Control (CP)
Passive pheromone dispensers are eligible to use List 3 inert ingredients under 7 CFR 205.601(m). The definition is generally considered to include twist ties, ropes, coils and other retrievable dispensers where the active pheromone is not in contact with the crop. It is unclear if formulations that are applied to the crop and are not possible to retrieve may be considered passive pheromone dispensers.

ISSUE #2: Nonylphenol ethoxylates (CAS# 9016-45-9, 26027-38-3)
Use Class: Crop Pest, Weed, and Disease Control (CP), Crop Management Tools and Production Aids (CT), Livestock External Parasiticides and Pesticides (LP), Processing Pest Control (PP) and Processing Sanitizers and Cleaners (PS)
Polyoxyethylene nonylphenol (CAS# 9016-45-9) and p-nonylphenol, ethoxylated (CAS# 26027-38-3) are types of nonylphenol ethoxylate (NPE) identified as List 4 inert ingredients in the 2004 EPA List of Inerts which are permitted at 7 CFR 205.601(m). However, OMRI understands that linear NPEs identified with CAS# 9016-45-9 and 26027-38-3 are incorrectly identified, and that commercially available forms should be identified by a List 3 CAS number that denotes a branched structure. OMRI will no longer list products reporting the use of CAS# 9016-45-9 or 26027-38-3, pending clarification from the National Organic Program.

ISSUE #3: Whey from cows treated with rBGH
Use Class: Livestock Healthcare (LH)
The OMRI Generic Materials List© includes a category for Colostrum/Whey Antibodies which explicitly prohibits whey from cows treated with recombinant Bovine Growth Hormone (rBGH). However, it is unclear whether this prohibition is consistent with the Excluded Methods (GMO) Decision Trees in the OMRI Standards Manual©. This issue is pending further review of OMRI’s policies for reviewing Colostrum/Whey Antibodies used in livestock production. 

ISSUE #4: Novel ammonia production
Use Class: Crop Fertilizers and Soil Amendments (CF)
The OMRI Generic Materials List© explicitly prohibits synthetic ammonia products including anhydrous ammonia, aqua ammonia, ammonia forms of micronutrients, ammonia nitrate, ammonia phosphate, ammonia sulfate, and ammonia soaps. However, a novel production method using anaerobic digestion technology may yield a similar soluble ammonia product as those listed above. It is currently unclear whether ammonia products produced by such novel technology are considered synthetic or nonsynthetic using NOP Guidance 5033-1.

ISSUE #5: Use of tetrapotassium pyrophosphate (TKPP) or synthetic potassium carbonate as extractants for humic acid products.
Use Class: Crop Fertilizers and Soil Amendments (CF), Crop Management Tools and Production Aids (CT) 
Humic acids are included at §205.601(j)(3) of the National List with the annotation “naturally occurring deposits, water and alkali extracts only.” Section 205.601(j)(3) does not provide details on which alkali extracts are compliant, but NOP Policy Memo 13-2 identifies several allowed extractants, including potassium hydroxide, sodium hydroxide, ammonium hydroxide, and nonsynthetic materials. In accordance with NOP Policy Memo 13-2, OMRI has developed standards to ensure that the amount of synthetic alkali extractant used does not constitute fortification of the humic acid material with a synthetic plant nutrient source. Currently, these standards are used when either potassium hydroxide or ammonium hydroxide are used as extractants. However, OMRI staff, with assistance from our Advisory Council, have been so far unable to develop criteria to differentiate between fortification and extraction uses of tetrapotassium pyrophosphate (TKPP) or synthetic potassium carbonate. Pending further standards development regarding how to evaluate fortification when these materials are used, OMRI will not review humic acid products extracted with TKPP or synthetic potassium carbonate.

ISSUE #6: Chlorine materials used as direct livestock drinking water treatments
Use Class: Livestock Management Tools and Production Aids (LT)
It is unclear whether chlorine materials are allowed for direct livestock drinking water treatment in organic production. Chlorine materials appear at §205.603(a)(10) with the annotation “disinfecting and sanitizing facilities and equipment. Residual chlorine levels in the water shall not exceed the maximum residual disinfectant limit under the Safe Drinking Water Act.” However, NOP Guidance 5026 further explains that “Residual chlorine levels in the water in direct food or animal contact (for example, drinking water) should not exceed the maximum residual disinfection level.” 

Due to disagreement in the organic sector about how to interpret the regulation, OMRI has submitted a petition to the NOP requesting an annotation revision that clarifies whether chlorine materials are allowed for direct treatment of livestock drinking water. Pending a response, OMRI will not review chlorine materials for use as a livestock drinking water treatment. Chlorine materials that have facility or equipment uses continue to be listed with a corresponding restriction according to the current National List annotation. 

It is possible for an input to comply with multiple organic standards at once and maintain OMRI Listed status under those standards. It is worth mentioning that applications for review to the U.S. National Organic Program (NOP) or Canada Organic Regime (COR) standards continue to be accepted in English only.

OMRI Use Classes describe the final uses for products under the organic standards, such as “Crop Fertilizers and Soil Amendments” (CF) or “Processing Pest Controls” (PP). Some products may be used in multiple ways by an organic producer. For example, a crop fertilizer is sometimes also used as a livestock feed ingredient. In those cases, the company may wish to list the same product under multiple Use Classes or Categories on the OMRI Products List©. When a company wishes to have a product listed under an additional Use Class, the following information and all fees need to be submitted to OMRI:

•  For products that are already OMRI Listed® or in the process of being reviewed:
  • Use our online application system to apply for review under the additional standards. You can indicate in the application that the product is already OMRI Listed and the formulation is identical. 
• For new applications:
  • Use our online application system to apply to have your product OMRI Listed. You will be able to choose as many Use Classes as you like, and will be asked questions specific to each Use Class. 

If you have any questions, please contact OMRI's application support team at 541-343-7600 x105 or apply@omri.org.