New Organic Feed Bill Mandates Annual Residue Testing and Reporting on Bulk Imports

The Organic Imports Verification Act of 2025 is the government’s latest attempt to close a potential loophole in the organic food supply chain, specifically targeting what cows, chickens, and other livestock eat. This bill mandates new annual reporting and a risk-based testing system for chemical residues found in imported organic animal feed. If a shipment of this feed fails the residue test, it can no longer be sold or advertised as organic, period.

The Organic Supply Chain Gets a New Gatekeeper

For most people, "organic" means a clean product, but keeping that promise gets complicated when you look at how much of the feed used by U.S. organic farms is imported. This bill focuses specifically on “covered organic feedstuff,” which means any organic feed shipped in bulk—think loose grain in a ship hold, railcar, or super sack. If the feed is pre-packaged, it’s not covered by this new system, which is a detail worth noting. The Secretary of Agriculture will now have to work with Homeland Security to create an annual, risk-based plan for testing these bulk imports for prohibited chemical residues. This means they’ll focus their testing resources where they think the danger of contamination or fraud is highest.

What Happens When the Feed Fails the Test?

This is where the rubber meets the road for importers and the organic industry. Every year, the Secretary must test the feedstuffs identified on the risk list. If any shipment tests positive for a prohibited substance above the allowed level, that specific shipment immediately loses its organic status. It cannot be sold, labeled, or advertised as organically produced. For the importer, this is a huge financial hit, as they lose the premium price associated with organic certification. For domestic organic farmers, this is a layer of protection, ensuring the high standards they follow are not undercut by cheaper, potentially fraudulent imports. Consumers benefit by having more confidence that the organic meat and dairy they buy were raised on genuinely organic feed.

The Transparency Question

While the goal of verifying organic standards is solid, there are practical concerns about how this will roll out. The bill requires the Secretary to submit an annual report to Congress detailing all the residue testing results, methods, and follow-up actions. This transparency for Congress is good. However, Section 4 explicitly states that the annual list of imported feedstuffs targeted for testing will not be made public. This lack of public disclosure for the annual testing targets means the agencies have significant discretion in deciding who gets tested and when. For importers, this could create uncertainty, and for the public, it means less visibility into how the “risk-based” system is actually prioritizing enforcement. It’s a classic trade-off: keeping the testing list secret might prevent bad actors from gaming the system, but it also reduces public oversight of the enforcement process.