U.S. Japan Organic Equivalence Arrangement

Questions and Answers

The U.S. has an “equivalence arrangement” with Japan. What does this mean?

This means that as long as the terms of the arrangement are met, organic products certified to the USDA organic standards or Japanese Agricultural Standards (JAS) may be sold, labeled, and represented as organic in both countries. As long as the operation is certified by a USDA or JAS accredited certifying agent, this arrangement facilitates access to each country’s organic market.

What are the origin requirements?

The arrangement is limited to products certified to the USDA or JAS organic regulations that are either:

  1. Grown or produced in the United States or Japan; or
  2. Have their final processing or packaging occur in the United States or Japan.

Does Japan accept the USDA organic seal? Does the U.S. accept Japan’s organic seal?

Yes. As a result of the trade arrangement, either organic seal may be used on products traded under the arrangement. Products traded under the arrangement must meet the labeling requirements in the destination country. See the details on the NOP and JAS websites:

When does this equivalence arrangement take effect?

The equivalence arrangement for plant and plant-based processed products became effective January 1, 2014. Equivalence for livestock products and processed products containing livestock ingredients is effective as of July 16, 2020.

Which products can be traded under the arrangement?

Plant or plant-based products. The arrangement includes organic plant, including fungi, and plant-based processed products of U.S. or Japanese origin.

Livestock products. The arrangement includes organic livestock products and processed products containing livestock ingredients of U.S. or Japanese origin. Livestock products or processed products containing livestock ingredients sold, labeled, or represented as organic in the U.S. must be derived from animals that have not been treated with antibiotics.

Other organic products. Alcoholic beverages and other products not regulated by the JAS law can enter the Japanese organic market.

Shipping USDA organic products from the U.S. to Japan

What is required to ship USDA organic products to Japan?

Products must be certified to the USDA organic standards, and must meet all Japanese organic labeling requirements, including compliant use of the JAS organic seal. Product shipments must also be accompanied by specific documentation described below.

What specific documentation is required for products traded under the arrangement?

All plant-based products, livestock products, and processed products containing plant and livestock ingredients exported from the U.S. to Japan must be accompanied by a USDA export certificate, also known as a TM-11. The TM-11 export certificate must be signed by a U.S. certifying agent and must include the following statement: “Certified in compliance with the terms of the U.S.-Japan Organic Equivalence Arrangement.” For products going to Japan, the last operator in the supply chain must be entered in the “Producer” box of the TM-11.

View the TM-11 export certificate and instructions (pdf) found on the USDA National Organic Program website.

Export certificates are not required for organic products not regulated by the JAS law, such as alcoholic beverages. However, alcoholic beverages labeled with the word “organic” in the Japanese language must be accompanied by an organic certificate that includes the name of the certified alcoholic beverage, the name and the address of the certified farm or brewery, the number and date of certification, the address and name of the operator, the country of origin, and the address and name of the certifying body.

How do U.S. operations obtain a USDA Export Certificate TM-11?

Certified operations should inform their certifying agent that they wish to ship products to Japan. View the list of USDA-accredited certifying agents approved to issue TM-11s (pdf) available on the USDA National Organic Program website

Can USDA organic products produced outside the U.S. be exported to Japan under this arrangement?

No. In order to be exported to Japan under this arrangement, USDA certified organic products must be produced within the U.S. or have their final processing or packaging occur within the U.S.

What is the JAS organic seal?

The JAS organic seal verifies that the product has met all requirements in the Japanese Agricultural Standards for organic products. The JAS organic seal and instructions for its use can be found on the JAS website.

Which products may carry the JAS organic seal?

All organic plant-based products, livestock products, and processed products containing plant and livestock ingredients must be labeled with the JAS organic seal if they are sold as organic in Japan.

Which products may not carry the JAS organic seal?

Products not regulated by the JAS law—such as alcoholic beverages—cannot be labeled with the JAS organic seal under the terms of the arrangement. They may be sold under the USDA Organic Seal if all other requirements are met.

Can a U.S. operation apply the JAS organic seal to their products?

Any plant-based products, livestock products, and processed products containing plant and livestock ingredients sold or labeled as organic in Japan must be labeled with the JAS organic seal. These products must be imported by a JAS-certified importer. The JAS organic seal may be applied using one of two methods:

Method 1. If a U.S.-based farm or business wishes to apply the JAS organic seal to their products in the U.S., they must contract with a JAS-certified importer.

Method 2. If the U.S.-based farm or business does not have a contract with a JAS-certified importer, a JAS-certified importer must apply the seal to the product once it arrives in Japan.

View a list of JAS-certified importers on the JAS website.

Are products in the USDA’s “made with organic…” labeling category included in the arrangement?

No. Japan does not have a “made with organic…” labeling category like the U.S. does. Only products with 95 percent or more organic content may be labeled as organic in Japan.

What about products in USDA’s “100 percent organic” labeling category?

Japan does not have a “100 percent organic” labeling category like the U.S. does. However, these products—and any product certified to be made with 95 percent or more organic ingredients—may be labeled “organic.”

Shipping JAS organic products to the U.S.

What is required to ship JAS-eligible organic products to the U.S.?

Products must be certified to the JAS organic standards and must meet all USDA organic labeling requirements (including compliant use of the USDA organic seal). Organic products must be associated with an electronic NOP Import Certificate completed by a certifying agent accredited by the USDA or Japanese government. The Import Certificate must include the following statement: “Certified in compliance with the terms of the U.S.-Japan Organic Equivalence Arrangement.” See below for more on NOP Import Certificates.

Can products not regulated by the JAS law be sold as organic in the U.S.?

Yes, if the product in question is certified to the USDA organic regulations by a USDA-accredited certifier and is outside the scope of JAS law, such as alcoholic beverages. Products within JAS law (plant-based products, livestock products and processed products containing plant and livestock ingredients) must be certified to JAS organic standards.

Can products that contain ingredients that are “in transition to organic” be traded under this arrangement?

The U.S. does not have an “in transition to organic” labeling category like Japan does. This means “in transition to organic” crops are not included under the arrangement. Additionally, livestock products or processed products containing livestock ingredients sold, labeled, or represented as organic in the U.S. may not be from animals fed “in transition to organic” crops.

Can organic products produced outside of Japan be exported to the U.S. under this arrangement?

No. In order to be exported to the U.S. under this arrangement, Japanese organic products must be produced within Japan or have their final processing or packaging occur within Japan.

How do JAS operators obtain an NOP Import Certificate?

JAS certified operations need to request that their JAS-accredited certifying agent complete the electronic NOP Import Certificate for the product that they wish to export. The certifying agent must issue the import certificate before the shipment departs the country of origin.

There may be instances where the exporters of products certified under Japan’s organic regulations are not certified because their exporting activities fall outside the scope of those regulations. Currently, this is permitted while the NOP works to address these regulatory differences under equivalence arrangements. In these cases, the certifying agent of the certified final handler issues the NOP Import Certificate and indicates that the exporter an “Uncertified Exporter” in the relevant information fields. USDA NOP-certified operations in Japan are subject to all NOP Import Certificate regulatory requirements.