New framework allows limited use of imported organic inputs for value addition and re-export, while preserving India’s NPOP Certification Integrity

In a significant policy move aimed at strengthening India’s position in the global organic products trade, the Agricultural and Processed Food Products Export Development Authority (APEDA) has unveiled a new framework permitting the import of USDA National Organic Program (NOP)-certified organic ingredients for processing and value addition in India, exclusively for re-export to the United States. The move addresses a long-standing challenge faced by India’s organic processing industry—access to certified organic raw materials that may not be available domestically in sufficient quantity or quality for export-oriented manufacturing. At the same time, APEDA has sought to ensure that the flexibility does not dilute the integrity of India’s National Programme for Organic Production (NPOP), which remains the country’s primary organic certification framework.

The new procedures, notified on June 24, 2026, come into effect immediately and create two distinct pathways for exporters. The first route allows Indian organic processors to import NOP-certified organic ingredients for value addition or manufacturing of products intended for re-export to the US, provided the imported component does not exceed 30 per cent of the final product composition. This provision extends the scope of an earlier advisory issued in February 2025 by explicitly permitting the use of imported organic ingredients in both multi-ingredient and value-added single-ingredient products.

Under the framework, products containing up to 30 per cent imported NOP-certified ingredients can continue to be certified under NPOP, provided the remaining ingredients comply with Indian organic standards. Such products may carry the designation “made with organic ingredients” under NPOP labeling norms, while their NOP certification for the US market will continue to follow USDA requirements. For India’s organic exporters, the significance lies in the operational flexibility this creates. Processors can now bridge temporary shortages of certified organic raw materials without disrupting export commitments to one of the world’s most lucrative organic food markets.

The second and more consequential provision concerns Special Economic Zones (SEZs).

APEDA has introduced a controlled derogation mechanism allowing NPOP-certified processing units located in SEZs to import NOP-certified organic ingredients even when the imported component exceeds the 30 per cent threshold. The measure effectively creates a dedicated export-processing channel designed specifically for the US market. However, the authority has placed extensive safeguards around this flexibility.

The provision is applicable only to NPOP-certified processing units operating within SEZs and is strictly limited to products intended for re-export to the United States. Products manufactured under this arrangement cannot be sold in the Indian domestic market and cannot be exported to any country other than the US. To qualify, processing units must possess valid certifications under both NPOP and NOP standards and maintain complete traceability of imported ingredients from entry into India through final export. Imported products must be accompanied by valid USDA NOP certificates issued by accredited certification bodies.

APEDA has also mandated strict segregation of imported organic materials from other organic raw materials throughout the manufacturing process. Separate transaction certificate modules will be maintained for such products to ensure accountability and prevent commingling with conventional NPOP-certified production streams. The regulatory architecture reflects a balancing act between trade facilitation and certification credibility.

Rather than granting blanket recognition to USDA organic standards, APEDA has explicitly characterized the arrangement as a limited, conditional and transaction-specific derogation. The authority has clarified that the measure does not constitute equivalence or mutual recognition between NPOP and NOP systems. NPOP remains India’s primary certification framework and all manufacturing, packaging, labeling and export requirements under NPOP continue to apply. Perhaps the most notable aspect of the policy is its transitional character.

One of the prerequisites for availing the derogation is that producers or production units in the exporting country must initiate the process of obtaining NPOP certification. Since overseas NOP-certified producers generally do not possess NPOP certification, APEDA is providing a temporary window to facilitate the transition. The exemption has therefore been structured as a bridge rather than a permanent arrangement. Imported products benefiting from the derogation will ultimately be required to obtain NPOP certification within the stipulated conversion period—two years for annual crops and three years for perennial crops.

This approach signals India’s intention to gradually expand the global footprint of the NPOP certification ecosystem rather than relying indefinitely on foreign certification systems. The framework also introduces an online registration mechanism. SEZ units seeking to import NOP-certified organic ingredients must register on a dedicated portal and upload all relevant documentation. Details of imported ingredients and processed export consignments will be digitally tracked, enabling authorities to monitor volumes, usage patterns and compliance.

The policy is further backed by mandatory risk-based inspections and surprise audits by certification bodies. APEDA has made it clear that violations of the prescribed procedures will attract sanctions under NPOP regulations. Importantly, the relaxation is not open-ended. The derogation has been capped at a maximum period of three years and is subject to periodic review. APEDA has indicated that future continuation will depend on several factors, including domestic availability of organic products, export demand trends, actual import and export performance, certification progress and the status of international negotiations.

From a trade perspective, the move is likely to be welcomed by India’s organic food exporters, particularly companies engaged in processing, blending and value addition for the US market. The United States remains one of the largest destinations for organic food products globally, and the ability to source certified organic ingredients internationally could improve supply-chain flexibility and enhance export competitiveness. At the same time, the extensive safeguards embedded in the framework suggest that regulators are keen to avoid any perception that India’s organic standards are being diluted. The emphasis on traceability, certification migration, transaction-specific approvals and periodic review indicates that APEDA views the arrangement as a carefully controlled trade facilitation mechanism rather than a fundamental change in organic certification policy.

The broader message from the notification is clear: India is seeking to position itself not only as a producer of organic goods but also as a global hub for organic processing and value addition. By permitting controlled imports of certified organic ingredients while retaining the primacy of NPOP standards, policymakers are attempting to strike a balance between export competitiveness and regulatory credibility. For India’s rapidly expanding organic sector, the new framework could represent an important step toward deeper integration with global organic supply chains—particularly in the high-value US market—while preserving the integrity of the country’s domestic certification ecosystem.

— Suchetana Choudhury (suchetana.choudhuri@agrospectrumindia.com)