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. This arrangement eliminates the need for organic operators to have separate organic certification to both the United States (U.S). and Japan standards, which avoids a double set of fees, inspections, and paperwork.
What are the origin requirements?
This equivalence is limited to country-to-country trade. For plant and plant-based products (excluding alcohol beverages) and livestock products, the arrangement is limited to products certified to the USDA or JAS organic regulations that are either:
Grown or produced in the U.S. or Japan; or
Have their final processing or packaging occur in the U.S. or Japan.
For alcohol beverages, the arrangement is limited to products certified to the USDA or JAS organic regulations that are either:
- Produced in the U.S. or Japan; or
- Have their final processing and packaging occur in the U.S. or Japan.
This means that the transshipping or pass-through of organic alcohol beverages from a third county where only storage, bottling and/or labeling occurs in the U.S. or Japan would not be permitted. The final processing, including the blending of alcohols, must 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:
- U.S.- https://www.ams.usda.gov/rules-regulations/organic/labeling
- Japan - https://www.maff.go.jp/e/policies/standard/specific/organic_JAS.html
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 became effective on July 16, 2020. Equivalence for alcohol beverages became effective on October 1, 2025.
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, and excludes alcohol beverages.
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.
Alcohol beverages. The arrangement includes organic alcohol beverages of U.S. or Japanese origin. Alcohol beverages sold, labeled, or represented as organic in the U.S. must be processed without the use of sulfites. Japanese wine processed using sulfites may be sold, labeled, and represented as “made with organic grapes” in the U.S. if it is processed only using sulfites and other non-organic substances in accordance with 7 CFR part 205.605. U.S. wine processed using sulfites in accordance with 7 CFR part 205.605 may be sold as “organic” in Japan if it complies with all terms of the arrangement.
Other organic products. USDA certified wines labeled as “made with organic grapes”, livestock feed, and other products not regulated by the JAS law can enter the Japanese organic market outside of the equivalence arrangement.
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, processed products containing plant and livestock ingredients, and alcohol beverages sold, labeled, or represented as “organic” that are 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.
TM-11 export certificates are only required for organic products traded under the organic equivalence arrangement; products not regulated by the JAS law, such as wine labeled as “made with organic grapes,” do not require a TM-11.
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 USDA Export Certificate, Form TM-11 (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 plant and plant-based products and livestock products must be produced within the U.S. or have their final processing or packaging occur within the U.S. For USDA certified organic alcohol beverages, their final processing and packaging must 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, processed products containing plant and livestock ingredients, and alcohol beverages must be labeled with the JAS organic seal if they are sold or represented as organic in Japan.
Which products may not carry the JAS organic seal?
Products not regulated by the JAS law—such as wine labeled as “made with organic grapes” and USDA organic livestock feed—cannot be labeled with the JAS organic seal under the terms of the arrangement. They may be sold with the USDA organic seal only if all other USDA organic requirements are met. For instance, wines labeled with a “made with organic grapes” claim cannot use the USDA organic seal.
Can a U.S. operation apply the JAS organic seal to their products?
Any plant-based products, livestock products, processed products containing plant and livestock ingredients, and alcohol beverages 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. USDA-NOP certified grape wines processed with added sulfites (listed under 7 CFR part 205.605) that are labeled as “organic” for export only to Japan must:
Display the JAS seal and may not use the USDA organic seal;
Be produced and processed with 100% organic grapes;
Meet all other USDA-NOP requirements for wine “made with organic” grapes;
Be produced only with food additives listed in the appendix B of the Japanese Organic Processed Food Standards (JAS1606); and
Not be labeled as “organic” in the United States.
Can USDA certified wine with added sulfites still be exported to Japan outside of the equivalence arrangement and be labeled and sold as “made with organic grapes”?
Yes. USDA certified wines made with added sulfites (in accordance with 7 CFR part 205.605) may continue to be exported to Japan outside of the equivalence arrangement since the Japan organic standards do not regulate a “made with organic” certification category/claim. These products:
May not use the USDA or JAS seals or be represented as “organic.”
Must be produced with 100% organic grapes.
May be processed with added sulfites in accordance with 7 CFR part 205.605.
Must meet all other USDA-NOP requirements for wine eligible for the “made with organic” grapes claim.
- May use the USDA NOP-accredited certifier logo on the product label so long as the certifier logo does not misrepresent the product as “organic.”*
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, if products meet all USDA organic requirements for the 100% organic labeling category, products may be labeled as 100% organic.
Can organic certifier logos be used on products certified under the USDA organic regulations that are exported to Japan under the equivalence arrangement? What about exports of certified products that fall outside the equivalence arrangement?
Yes. This is acceptable for organic products that are exported under the equivalence arrangement. For products exported outside of the equivalence arrangement, the certifier logo may be used so long as it does not misrepresent the product as “organic.”* When the USDA seal is used on the label, the certifier logo may not be displayed more prominently, per 7 CFR § 205.303(a)(5).
* MAFF has granted a grace period until March 31, 2027, allowing U.S. "made with organic grapes" wine exported to Japan outside of organic equivalence arrangement to continue to display certifier logos that include the regulated the term "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). JAS organic alcohol beverages sold, labeled, or represented as organic in the U.S. must be processed without the use of sulfites. JAS organic wine processed using sulfites may be sold, labeled, and represented as “made with organic grapes” in the U.S. if it is processed only using sulfites and other non-organic substances in accordance with 7 CFR part 205.605.
Organic products must be associated with an NOP Import Certificate issued by a certifying agent accredited by the Japanese government. The NOP 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. Products within JAS law (plant-based products, livestock products, processed products containing plant and livestock ingredients, and alcohol beverages) 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.
For JAS-certified organic alcohol beverages, their final processing and packaging must occur within Japan.
How do JAS operators obtain an NOP Import Certificate?
JAS certified operations need to request that their JAS-accredited certifying agent issue a NOP Import Certificate for the product that they wish to export. The certifying agent is responsible for issuing the import certificate only after they have verified compliance with the terms of the U.S.-Japan organic equivalence arrangement and before the shipment departs from the country of origin.
There may be instances where the exporters of products certified under Japan’s organic standards 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 is an “Uncertified Exporter” in the relevant information fields. USDA NOP-certified operations in Japan are subject to all NOP Import Certificate regulatory requirements.