Organic Certification with Hugelkutur

Hoping someone may have an answer.

Can you become ‘Certified Organic’ when raising in raised hugelkultur beds?  Are there stipulations?

Also, can Certification be earned if using rainwater as the water source?

It's going to depend on your certification authority you may have to wait 3 years after creating the beds, but if you can show that the wood comes from an organic area you might be able to skip that.  Organic certification isn't about common sense it's about paper trails. For me here rainwater depends on what I am watering, potatoes sure, lettuce no.
Personally for my sales certifying organic costs way to much to bother with.

I work in the organic sector and it is my impression that most certifiers would allow both of these things, with some minor caveats/exceptions. As Skandi said it does depend on your certification authority. In the US, all certified organic operations are certified to the same set of regulations, which can be viewed in full here: https://www.ecfr.gov/current/title-7/subtitle-B/chapter-I/subchapter-M/part-205?toc=1.*

Sections 205.202-206 of the regulations are about land requirements, soil management, etc. Section 205.202 basically says that there can have been no prohibited substances applied to the land within 3 years, as Skandi referenced. All soil inputs do NOT need to be certified organic though (since for example, things like minerals cannot be certified organic since they are not agricultural products). Inputs for crop production must be either synthetic materials listed in 205.601 or nonsynthetic materials NOT listed in 205.602 (and must follow any restrictions listed in these sections). Some certifiers might ask for documentation that the wood used was not treated in the prior 3 years, however I think most would just view it as a nonsynthetic material not listed on 205.602 and allow it without additional documentation.

The regulations have no specifics re: irrigation. Section 205.200 of the regulations states "Production practices implemented in accordance with this subpart must maintain or improve the natural resources of the operation, including soil and water quality." which is about all the regs have to say about water. Because of this vagueness, this is an area where a bit more variation is seen between certifiers - I believe some might require water testing for irrigation, while others might only require it for washing crops, and some might not ask for water tests at all - but all would want some information on how your management system maintains or improves water quality.

Skandi, you are definitely not alone in not thinking it's worthwhile to get certified. There is a lot of paperwork (more in the first year, a bit less on an ongoing basis) and you're right that it is NOT about common sense. I usually explain it as a marketing tool, and one that's right for some operations but not others - many smaller operations especially do not find certification worth the cost and/or time. In the US, there is an exemption so that operations making under $5,000 in gross organic sales per year do not need to be certified to make organic claims (though still need to follow all the regs and be willing to have their records audited). The US also has a cost share program which reimburses 50% of certification fees up to $500 per year per scope of certification (the scopes are crops, livestock, wild crops, and handling and you can get more $ back the more scopes you are certified for). The exemption and the cost share program are both designed to help smaller operations get into organic production and certification if they want to. I'm not sure whether the EU has equivalent or similar programs. My view is if you have direct relationships with your customers and enough sales without certification, it's probably not needed, whereas if you are doing larger scale production, trying to make more sales, and selling wholesale, retail, for use in processed products, etc. then having the organic label (backed up by 3rd party verification) can be worthwhile.

Hope that's helpful and not too confusing - I tried to explain it clearly without making it too long, but it is kind of complicated. I'm happy to attempt to answer more questions re: organic certification if anyone is interested.


*Slightly longer explanation re: variation between certifiers: However, just as different lawyers or judges may interpret certain laws differently, different organic certifiers may interpret some sections of organic regulations differently. I would describe it as fairly standardized but with some minor differences in interpretation - because of this, you should always reach out to your certifier (or potential certifier) prior to implementing changes to your management to verify whether they are allowed. All US certifiers must be accredited by the NOP (National Organic Program), which is part of the USDA - basically this means individual farms/operations are monitored by the certifiers, and then the certifiers themselves are audited and regulated by the federal government to try to maintain consistency across certifiers and make sure certifiers are upholding the regulations.

TY both for your responses!

I'll add just one more note to this.  Not only does it depend on your certifying agency/entity, but that agency will vary in terms of whether they'll guide and support your efforts to tweak anything that needs tweaking, versus just giving you a "yes/no" answer.   We went through the organic certification process a number of years ago with our state ag agency, which had an in-house organic certifying department.  I wanted to keep things local.  What I didn't realize is that they were, at the time, also woefully under-budgeted, which slowed everything down, loaded up the staffmembers with too much work, and also ruled out repeat site visits.  We were given the option to fix our minor issues and then re-apply (by paying a new fee - ouch!) or just wait until the next year to try again.  That ruling didn't come until September, and it's a one-calendar-year-to-the-next certification.

We opted not to try for that calendar year.  We found out later that had we gone with one of the national-level certifying agencies, they can accommodate stuff like repeat visits, offering guidance on how to tweak, fix and/or improve things to green-light the inspection, etc.   We will go through the certification process again, and when we do it'll be with one of the national-scale associations.  Oregon Tilth is one that operates nation-wide and just happens to be regional for us anyway, with a very strong track record of working with growers and livestock owners.  There are other such organizations.

If you are close enough to be filling out the paperwork, start talking to other folks in your area who are already certified (even if it's not hugelkulture).  Most certified organic growers are very happy to talk to other prospective certified organic growers.  See which certification entity they went with, and how much that entity was/was not able to hold their hand for the process.  Rest assured that it's a lot of hoops to jump through, and for a lot of good reasons.  It's supposed to be a challenge to get that certification.  Just remember that some certification entities are better funded/staffed to help you get there.

I hope you go for it.  Please let us know what you learn a long the way.
Kathryn Kerby
frogchorusfarm.com
Snohomish, WA