My farm has been certified organic before there was even a national standard. Depending on where you live, it's not necessarily expensive to be certified. There is a federal program that reimburses 75% of your costs.
That said, there are plenty of reasons not to certify. I agree that if all you're doing is direct marketing, it's not needed. The <$5K sales exemption allows smaller growers a way to avoid certification.
But really the main reason I am seriously considering dropping my farm's certification is that it's becoming increasing difficult to comply with the changing interpretations of the regulations. Maybe if all you're doing is field cropping with rotations and cover crops for fertility you won't have much problem there. But if you use any external inputs in your organic system plan, you will someday get a letter from your certifier that product X is no longer allowable and you have to discontinue use immediately. It doesn't matter if stopping the use of the product destroys your crop, you have to stop with no advance notice. Then, if you decide you're just going to sell the crop as "conventional" you would not be able to ccertify that land for another 3 years because you used a product that yesterday was organic and today is not.
Certified naturally grown is a cute farmer pledge but carries no real enforcement mechanism and is largely people agreeing to something they could hardly understand, therefore not very meaningful. The farmer has to take a pledge that they are following all the NOP regulations. As I said above, the regs are in a constant state of reinterpretation and modification. The chief inspectors at certifying agencies are all at it fulltime, keeping abreast of all the changes. No peer farmer review program would ever be able to be fully knowledgeable of the USDA National Organic Program (NOP) regs to be able to certify another farm.
Here's an example. Let's say a farm uses chilean nitrate to supply nitrogen in a field. Is that organic or not? Under Certified Naturally Grown, the peer farmer who's reviewing your farm has to research the correct ways in which chilean nitrate may be used in crop production. Well the federal register will give you one place to look, but you would have to keep up on NOP bulletins for the complete information. The current NOP interpretation is that chilean nitrate can only 20% of the total nitrogen required to produce the crop. So if you have a field of mixed vegetables, the grower has to identify the crop in the field that uses the least amount of nitrogen to mature. Everything else in the field can only receive the same rate as the crop needing the least. It's obvious that a peer review would never in practice catch such a violation of the NOP standards. And even if it were caught, what's the enforcement? If you cheat under CNG, who's going to sue you to stop using the label? If you cheat under NOP, USDA yanks your certification and you can be fined. They have enforcement people.
My bottom line criticism is that CNG claims its farmers are following NOP rules, but none of the farmers are really fully knowledgeable enough to know for certain. Without a written organic systems plan that can get reviewed by the experts, it's not able to meet NOP rules. Record keeping and expert verifiation the fundamental basis of organic certification. Anything else is believing what a farmer tells you.
With CNG being pretty low in meaning, why not make up your seal and just use that instead? Then you don't even need another farmer to come over and see what you're doing. Call it Certified Natural By J Kunkel.
If you want a "close enough" certification for marketing purposes, CNG fits the bill. But don't think you'd have a smooth transition to NOP certification after you get a CNG stamp of approval.