Transition to Certified Organic Milk Production

eOrganic authors:

Sarah Flack, Sarah Flack Consulting Service

Lisa McCrory, Earthwise Farm and Forest

Before You Transition: Make a Plan

The following guidelines are based on the National Organic Program (NOP) final rule (United States Department of Agriculture [USDA], 2000). Farmers planning to make the transition to organic dairy production should consider all of the following areas, as well as the time and investment that will be required for compliance with certification requirements.

A farmer interested in making a transition to organic production should create a transition plan which includes a timeline from the day that organic practices have been implemented to the day that the farm will ship organic milk. This process takes a minimum of one year and can take up to three years, depending on the farm, current farming practices, and when the last prohibited substance was applied. Fields can be transitioned to organic on a field-by-field basis with each field required to be free of prohibited inputs for 36 months before the first organic harvest. Dairy animals will require a 12-month transition which may overlap with the third year of the land transition. In some situations, the farm may choose to purchase a herd of certified organic dairy animals instead of transitioning an existing herd.

Before starting the transition process, it is important to find an organic milk market and decide which organic certification agency to use. The certifier will provide an application and/or Organic System Plan (OSP) as well as record-keeping forms to document the transition to and management of organic production. During the initial application process, the certifier will require one years worth of production and management documentation of the livestock and three years worth of production information for the land. Following the initial transition and first year under certification, the certifier will continue to require an annual OSP and records of management and materials used on the farm.

It is important to choose an organic certification agency early to make sure the certification process can be completed on time. The certifier can provide information about the requirements, record-keeping forms, and a list of inputs and materials allowed. All accredited certifiers are required to provide sufficient information to persons seeking certification to enable them to understand and comply with the requirements. Since there are regional differences in available inputs, climatic conditions, agronomic practices, and so forth, it is always a good idea to work with a certifier who is knowledgeable about the local conditions, practices, and inputs used.

Shippers or processors that buy organic milk may have contract or production requirements in addition to the NOP final rule. Be sure to learn about their requirements before selecting an organic milk buyer and going through the USDA organic certification process. It is important to know that certification does not assure an organic milk market. A contract with an organic milk buyer or organic milk market should be established prior to making investments in the transition and certification process.

Dairy Herd Transition Guidelines

During the 12-month transition period, all animals must be managed according to the NOP. This requires that all feed be certified organic, that all animals over the age of 6 months meet the pasture standard, and that all feed supplements, medications, health management practices, and livestock housing meet the organic standards. There is an allowance where farmers may use, in addition to certified organic feed, their own feed grown on their own land in its third year of transition. This home-grown feed may only be fed during the 12-month livestock transition period.  

Once the transition is completed and the herd is certified, the standards require that all dairy animals be under organic management from the last third of gestation. For farms also seeking certification of dairy cattle for meat or slaughter stock, only those animals managed organically from the last third of gestation will qualify.

Livestock Feed

For the 12 months prior to selling organic milk, all feed must be 100% certified organic or harvested the farm's third year transitional land (i.e., land where a prohibited substance was last applied 24 to 36 months ago). The 100% organic feed ration includes forages and grains as well as any agricultural products that are used as carriers or bulking agents in feed supplements (eg., oat bran, etc.).

The provision for feeding farm-raised, third-year transitional feed is only allowed for herds in transition. Once the herd is certified and the farm is shipping organic milk, feed from transitional land cannot be fed. For this reason, it is important to time the transition to have silos, bins, and hay storage empty of transitioned crops, and full of certified organic crops prior to the completion of the transition process.

During the transition, all purchased grains and forages must be certified organic. "In-transition" organic feed (managed organically for 24-36 months) cannot be purchased from other farmers and fed to a dairy herd during transition.

All purchased grains and forages must be certified organic. "In-transition" organic feed (managed organically for 24-36 months) cannot be purchased from other farmers and fed to a dairy herd during transition. You must keep all receipts and organic certificates as documentation of your organic feed purchases, making sure that the receipts provide the seller’s name, transaction date, a copy of the seller’s certificate of organic status, and the amount of feed purchased.

Keep all receipts and organic certificates as documentation of organic feed purchases, making sure that the receipts provide the seller’s name, transaction date, a copy of the seller’s certificate of organic status, and the amount of feed purchased. These documents will be required to allow the certifier and inspector to verify that the herd has been fed only organic feed.

All feed supplements, including minerals and salt, must include 100% certified organic feed ingredients or materials on the National List. In addition, they must be pre-approved for use by the certifier. Antibiotics, GMO-derived products, animal by-products, artificial colors/flavors, synthetic flowing agents, and synthetic preservatives are not permitted in any feed products. If a supplement contains soy oil, wheat middlings, or molasses, for instance, these are agricultural products and must be certified organic. The certifier may provide a list of approved products and suppliers. The Organic Materials Review Institute (OMRI) also provides a list of approved inputs for crops, livestock, and processing. 

There is currently no approved organic milk replacer, so calves must be fed organic milk along with other certified organic feed.

The organic standards on pasture define pasture as a crop and require that farms have a pasture plan in their OSP. The standard requires that during the grazing season, all animals over 6 months of age must receive an average of at least 30% of their dry matter from pasture. Grazing season length will vary regionally. There are specific record-keeping requirements in the organic standards which relate to grazing, feeding, and dry matter intake calculations.

Livestock Living Conditions

Organic livestock producers must establish and maintain year-round livestock living conditions which accommodate the health and natural behavior of animals. These include year-round access for all animals over six months of age to the outdoors and, during the grazing season, requires pasture. When housed, the livestock living conditions require that the bedding be dry and clean, and that when roughages are used as bedding, that they be certified organic.

Outdoor areas must be managed to prevent run-off of wastes and water contamination. There are exemptions that allow producers to provide temporary confinement due to specific situations like inclement weather, risk to soil and water quality, healthcare treatement, breeding, and milking.

Livestock Health Care Products

The organic standards require that the producer establish and maintain preventive health care practices. The standard states that this includes selection of appropriate species and types of livestock, feed rations, appropriate housing, pasture, and sanitation. It also includes conditions that allow for exercise, freedom of movement, and reduction of stress.

Dairy farmers must follow organic health care requirements during their one-year transition prior to shipping organic milk. This means that all health care products with synthetic ingredients are prohibited for use, unless they are specifically included on the National List of synthetic materials allowed for use in organic livestock production. The organic standards allow physical alterations such as dehorning as needed to promote the animals welfare and in a manner that minimizes pain and stress. Docking the tails of dairy cattle is not allowed.

Non-GMO vaccines and biologics are allowed in addition to medications on the National List. Some of the materials on the List have restrictions including milk withholding, and some are prohibited for use in slaughter stock. All health care materials must be listed in the OSP and approved by the certifier prior to use.

It is prohibited for a producer to withhold treatment to maintain organic status of an animal. If an animal is treated with a prohibited product, the milk and meat from that animal can no longer qualify as organic and the animal must be sold as non-organic or tracked and managed as non-organic. Records should be kept including vet visit records and health treatments administered as well as records of deaths and culling.

Animal Identification and Inventory

An animal identification and inventory system is not specifically required in the organic standards. However the organic standards do require that all certified operations maintain records which fully disclose all activities and transactions in sufficient detail as to be readily understood and audited. During the annual inspection, the inspector will usually do an audit of some or all of the livestock to verify the identification system, animal records and number of animals. Some certifiers will provide farms with livestock record keeping forms, however most of the computerized record keeping systems will have enough detail in them to allow an audit of the herd records during the annual inspection. When animals are purchased, the invoices and organic certificates should be kept and made available during the next inspection.

Dairy Livestock as Organic Meat

If part of the farm plan is to sell cull cows, young stock, or steers as organic meat, all slaughter animals must have been organic from the last third of gestation. This means that the mother cow had to have been on the certified operation, fed and managed organically, for the last three months before the slaughter animal was born. If third-year transitional feed is being used to feed the herd, the young stock born that year would not be eligible for organic meat sales. Dairy animals that were transitioned to organic can never be sold as organic meat, but they can give birth to organic meat animals and produce organic milk. Dairy animals that were given parasiticides can never be sold for organic meat.

Field Practices

Fields, including pastures, qualify as organic if at least three years have passed since the last application of a prohibited pesticide, herbicide, synthetic fertilizer, or any planting of fungicide-treated seeds or GMO crops. If some fields qualify as organic, but others have had recent applications of prohibited products, the farm may still be able to get certified.

The feed from fields that have not yet completed their three-year transition would be considered non-organic transitional feed. First- and second-year transitional feed can be sold on the conventional market or fed to non-organic livestock, such as bull calves to be sold for non-organic meat, or horses. Records documenting the sale or use of transitional and other non-organic crops should be maintained. Third-year transitional feed can be fed ONLY during the one-year whole herd transition year.

Risks of Commingling and Contamination

The organic standards require that the organic operations have measures to prevent the commingling of organic and non-organic products, and to protect organic products from contact with prohibited substances. For farms, this may create the need for buffers on the edges of some fields, and it may also create a requirement that equpment which may become contaminated by non organic crops or prohibited materials be cleaned between use.

If an adjoining farm, golf course, development, or other land user applies prohibited substances to their land, an adequate barrier/distance between the certified crops and the neighboring land needs to be in place. The buffer needs to be sufficient to prevent prohibited substances from contacting the organic crops. The organic certifier can provide detail on the distance needed for buffer zones, depending on the risk of contamination, taking into consideration physical barriers, slope, prevailing winds, substances used by the neighbor, and methods of application. If buffer zones are needed, crops grown in those areas cannot be used for organic feed or sold as organic.

If harvest equipment, seeders, sprayers, spreaders, or other equipment are used for both organic and non-organic production, they will need to be cleaned so that organic crops will not be contaminated with prohibited substances or non certified feed. For some types of equipment, this can be done by sweeping or manually cleaning. Other equipment may require washing or a purge. A record of this cleanout should be kept and made available to the inspector during the organic inspection.

Soil Fertility and Crop Production Inputs

The NOP regulation states, "A producer must select and implement tillage and cultivation practices that maintain or improve the physical, chemical, and biological condition of the soil and minimize soil erosion" (USDA, 2000; 7 CFR 205.203(a)). The regulation also states that the producer must use management practices to prevent crop pests, weeds, and diseases including crop rotation, sanitation, and cultural practices. It allows the use of predator species for pest control, development of natural habitat for predator species, and non-synthetic controls such as traps and repellants. It allows the control of weeds through mulching with fully biodegradable materials, mowing, mechanical cultivation, and grazing.

Soil fertility should be managed through  rotations, cover crops, manure, compost, plant residues, and the application of approved soil amendments. Approved soil amendments include non-synthetic minerals such as manure, rock phosphate, and naturally mined lime, so long as they do not contain synthetic additives AND are not on the list of non-synthetic substances prohibited for use. The organic standards also include a list of synthetic substances allowed for use in organic crop production. Use of a prohibited material will disqualify that field from organic production for three years.

All soil fertility inputs, pest control or weed control materials must be listed in the OSP and approved by the certifier prior to use. Records of use should be maintained and product labels or purchase records should be kept and made available during the organic inspection.


Producers of organic crops are required to use certified organic seed if it is commercially available. Conventional, untreated seed may only be used if organic seeds are documented as not being commercially available. Documentation must be kept to verify that any non-organic seed used has not been treated with synthetic fungicides/insecticides, is not genetically modified, nor inoculated with a GMO nitrogen-fixing bacterial inoculant.

Crops grown from treated seeds cannot be sold as organic and the use of treated seeds disqualifies the field from organic production for three years. Seed treatments, such as non-GMO legume inoculants and natural clay-based pelletizing materials, can be used, provided they are approved for organic use.

Records of seed purchase including commercial availability documentation, statements of non-GMO status, and documentation that they are untreated should be kept and made available during the organic inspection.

Milk Handling and Sanitation

All types of milking systems are allowed including hand, bucket, stanchions, and parlors. The milking system cleansers, sanitizers, and teat dips should all be listed in the OSP and should be approved by the certifier prior to use.


The authors thank Harriet Behar and staff at Midwest Organic and Sustainable Education Service (MOSES), Nicole Dehne and staff at Vermont Organic Farmers, LLC (VOF), and Jim Riddle at University of Minnesota, for their contributions to this article.

References and Citations


Published January 21, 2009

This is an eOrganic article and was reviewed for compliance with National Organic Program regulations by members of the eOrganic community. Always check with your organic certification agency before adopting new practices or using new materials. For more information, refer to eOrganic's articles on organic certification.