A Matter of Timing: When to Certify Organic Livestock

brown hen on green grass during daytime

Timing is key when you’re considering certifying livestock for the first time. Learn how to set yourself up for success.

The first step to certifying livestock is to certify the land where the livestock you intend to certify will be housed before you apply for livestock certification. Livestock need to be managed on certified organic land, which means you can’t go about certifying cattle, chickens, or another species before your farm is certified. This means certifying any land you manage where livestock feed will be produced–including pasture–and any part of your farm to which your livestock will have access. Many farmers and ranchers choose to certify their farm first, then request the livestock for certification the following year with their farm’s annual renewal paperwork. Just like requesting certification for a farm, requesting livestock for certification requires that you complete an Organic System Plan or “OSP.” There are separate OSPs for crop production and livestock production.

If you already have livestock, any mammalian livestock must complete a transition before they can be included on your organic certificate. For dairy animals (those that will be milked), the transition period lasts one year. During that year, dairy livestock may consume feed produced on land that is organic or on land that was in its third year of transition. Meat or fiber (wool) animals must be managed organically from the last third of their gestation for their particular species. For example, if you raise beef cattle with a typical gestation of 283 days, the cow must be under organic management for at least the last 95 days in order to give birth to an organic calf. If you raise poultry, the birds must be managed organically from the second day of life.

What does it mean to manage an animal organically? In a nutshell, it means that the animal is housed on certified organic land, consumes certified organic feed, and is not given any prohibited substances. If you raise ruminant livestock, it also means that the animals have access to pasture for the entirety of the grazing season in your region and that a minimum of 30% of their daily dry matter intake comes from pasture during the grazing season (with some exceptions). If you raise poultry, it also means that those birds have access to the outdoors throughout the year (with exceptions). Raising organic livestock also means that the animals have the ability to engage in natural behaviors, are given appropriate preventive & emergency medical care (even if it may jeopardize their organic status), and are afforded year-round access to the outdoors, shelter, fresh air, clean water, and direct sunlight. Finally, rearing organic livestock means that individual animals or (in the case of poultry) flocks of animals are identifiable in some way that allows the farmer or rancher to maintain individual animal health records or flock health records. Specifics about the organic livestock requirements can be found in the National Organic Program Final Rule–7CFR Subpart C, § 205.236 thru § 205.240–linked here:


herd of cattle standing on green grass

Here are some general recommendations for those seeking livestock certification:

1.) Familiarize yourself with the livestock requirements before starting your herd’s transition to ensure you’re following all of the livestock requirements during your transition.

2.) Consider certifying your farm first in all cases. For those certifying dairy animals, it is possible to certify the farm and the dairy herd at the same time, but consider the following before undertaking simultaneous crop and dairy certification:

  • Once you receive dairy certification you may no longer feed crops produced during the third year of transition and you must begin feeding 100% organic feed. Will the timing of your farm certification mean that you have sufficient harvested feed to give to your dairy herd once certified?
  • If you will not have sufficient certified organic feed harvested at the time you receive livestock certification, you will have to purchase organic feed. Is there sufficient quality organic feed near you?

3.) Complete a Livestock Organic System Plan and dry matter calculation worksheet (in the case of ruminant livestock) to make sure you’re meeting all the requirements. Can you successfully complete these forms? If not, you are likely not ready to request certification. An Organic System Plan is just that–a plan that spells out how you will manage your livestock enterprise. Your plan is what your organic certifying agency will use to determine whether or not your operation meets the basic requirements of the organic regulations. If your plan is incomplete, your certifying agency will not have sufficient information to grant certification. Be sure to submit all of the documents in the Livestock Checklist you receive from OneCert to ensure a timely certification.

4.) Have you considered how you intend to market your livestock or livestock products? It makes little sense to go to the extra expense to certify livestock if, for example, you intend to sell organic beef but there is no certified organic slaughter facility near you. Likewise, how will you sell organic milk if there is no organic creamery that picks up milk in your area? It pays to consider these questions first.

Consider the following two scenarios and how the timeliness of your request to certify organic livestock matters:

Scenario 1: Jim wants to sell certified organic free-range turkeys. He purchases day old chicks and has them shipped to his farm. He buys organic feed for the chicks. Once they are fully-feathered, he releases them in a grassy, 5 acre outdoor enclosure. Jim schedules a slaughter date for the birds in early November so they will be ready for the holidays. The slaughter facility is certified organic. Jim completes a Livestock Organic System Plan and requests certification for the birds in late September. Can Jim get his turkeys certified?

Unfortunately, no. In this scenario, Jim failed to certify his land before beginning to manage turkeys on it. Recall that poultry need to be managed organically from the second day of life–meaning on organic land, among other requirements. Jim’s farm needed to be certified before the turkey chicks arrived there. In addition, Jim’s certification request came very close to the slaughter date. Even if Jim’s farm was already certified, the certifying agency would need to perform a compliance review of Jim’s Organic System Plan first, send out an inspector to verify the plan, and perform a final review of Jim’s turkey-rearing enterprise prior to the early November slaughter date. In other words, the certifying body has about six weeks to certify the turkeys before they go to slaughter. This is likely not enough time for the inspection and review process considering the difficulty of scheduling a qualified livestock inspector on short notice.

Scenario 2: Sarah wants to certify her small 50-cow dairy herd. Last year she certified her farm in early July, which includes 100 acres of pasture and some crops that she grazes following harvest–usually bean or wheat stubble and alfalfa/grass hay fields. Sarah decided to wait until she had certified her farm before she began transitioning her dairy herd. For the first six months of their transition she fed her herd crops she harvested prior to her July certification date in addition to grazing them on her certified organic pastures. For the remaining six months, she fed all organic feed. Sarah made sure her herd met the access to pasture regulations by completing a dry matter intake calculation form prior to the start of the grazing season with her planned feeding information. Sarah completes a Livestock Organic System Plan and sends it in with the certification renewal paperwork for her farm. Can Sarah certify her dairy herd?

Barring any use of prohibited substances or prohibited practices, it sounds like Sarah is on the right track to certify her dairy cows. Her cows went through their entire transition on a certified organic farm with access to certified organic fields and she fed them a mix of 3rd year transitional and certified organic feed during that time period, which complies with the regulations for dairy transition. She also made sure that she was not feeding too much by completing the dry matter intake calculation forms to confirm her cows would get at least 30% of their dry matter intake from pasture during the grazing season.

Scenario 3: Terry wants to certify his beef cattle herd. The cows in his herd have lived on his organic pastures for many years and have consumed hay Terry grows himself on his organic land during the winter. Terry applies for certification of his livestock in May when he submits his farm’s annual certification renewal paperwork. He intends to certify the calves born earlier in the year–in January and February. An inspector visits Terry’s farm for the annual farm inspection in early July and inspects the livestock in addition to the farm. During the inspection, Terry indicates that in the last year he hasn’t ear-tagged his cattle or kept records of things like cows who received medicines, when cows gave birth, or when certain cows were administered anti-parasite treatments. Can Terry successfully certify his beef herd?

Many farmers lament it, but record-keeping is a huge part of proving that your practices are organic. Though Terry was on-track to be granted certification for his beef herd, his failure to keep records of his husbandry practices will sink his chance to certify his calves this year. Terry will be denied certification because he doesn’t have any records to identify his cows, their calves, or when cows received treatments that may bar their calves from receiving certification. However, Terry can begin keeping records now and request the certification of next years calves if he applies for certification again next May and can show next year’s inspector that he can demonstrate the organic handling of his cow herd beginning with at least the last third of their gestation period.

The most important piece of advice anyone can give to a farmer or rancher considering the certification of a livestock enterprise is to communicate with a certifying agency about your plans. OneCert can provide you with information that will maximize your chances for success and minimize costly or time-consuming errors that may set back your transition goals. So when is the best time to communicate with a certifier about transitioning? At least a year prior to your intended application date, contact and asking general questions about the certification process and time lines associated with certification. This simple task will help you to codify the steps you need to take to achieve your certification goal in a trouble-free way.

white and brown chicken on green grass during daytime