Marketing the Certifier’s Role:
What Does Consumer Perception Tell Us?

By Jonathan Austin

The marketing of organic products in the United States is regulated by the U.S. Department of Agriculture (USDA) National Organic Program (NOP), which has promulgated regulations governing the production, handling, processing and labeling of most organic products. A primary aspect of the regulation is the requirement that those offering organic products for sale must have their compliance with the 2002 USDA regulations certified by a third-party certifying agent accredited by the USDA. Once certified, products can be labeled as organic, and can carry the USDA seal, as well as the certifier’s seal.

Because the USDA accredits more than 90 domestic and foreign certifying agents, attempting to select a certifier can be a complicated proposition that raises a host of questions, including those about the certifier’s level of experience, their commitment to excellent customer service, and the cost of the certifier’s services. Sophisticated businesspeople investigating organic certification have additional questions, and one that arises with some regularity is whether or not there is any marketing advantage to be gained by choosing one certifier over another. Or, put another way, do consumers recognize and prefer some certifiers over others, such that retail customers will, when given the choice, prefer to buy products carrying the seal of some certifiers rather than those carrying the seal of other certifiers?

The question bears some serious consideration, for if true, the selection of a certifier is an opportunity to create additional marketing value, and one that, given the increasing competition in the organic marketplace, should not be passed up. However, to answer this question one must take a short detour through the history of the organic industry, recognize the differences in the current marketplace and review the known data on the subject.

The Certifier and the Certifier’s Seal: Pre-NOP
The question of consumer loyalty or preference for certain certifiers over others arises partially from the history of organic agriculture and food processing in the U.S. From the early 1970s when organic ideals began to be valued by consumers until the implementation of the NOP final rule in 2002, the marketing of organic products was largely unregulated. With some notable exceptions, certifiers had a state or regional affiliation which continues to the present day and which is reflected in names such as Oregon Tilth, California Certified Organic Farmers, or Florida Certified Organic Growers and Consumers (now operating as Quality Certification Services). Other certifiers without a regional affiliation, such as the Organic Crop Improvement Association, operated regional or state chapters.

Even though during this time 22 states passed laws governing organics, for the most part there was no commonly agreed upon definition of organic. Individual certifiers developed their own standards and these varied from one certifier to the next. Certifiers had no mechanism to require those marketing organic products to become certified, and lacked any effective legal recourse against those who labeled their products organic without being certified, or even those operations that committed outright fraud. Frequently, certifiers did not recognize the organic certificates issued by other certifiers—a situation that made the formulation of multi-ingredient products problematic, unless a manufacturer insisted that every ingredient supplier was certified by the same certifier as the manufacturer.

Organic consumers, in contrast to today, were less numerous, more knowledgeable and more radical in their support of organic ideals. These early organic consumers were more likely to be directly involved in organics, either through farming or creating value-added products. Early organic consumers looked to certifiers for advocacy on behalf of organics, education about the value of organics, as well as standard-setting and verification systems that preserved organic ideals. During this time, it was the certifier’s seal that served as the guarantee of the organic integrity of products marketed as organic. Savvy organic consumers were skeptical of organic products that were not certified or that were certified by a certifier that they did not recognize.

The Certifier and the Certifier’s Seal: Post-NOP
The Organic Food Production Act and the present National Organic Program regulations governing organic production, processing, and marketing were intended to solve a number of problems that existed in the unregulated organic marketplace, including the potential for organic fraud, the lack of reciprocity among certifiers, and the inability of certifiers to require certification of operations marketing products as organic. A central and intended effect of the regulation was to lower the profile of individual certifiers and state laws governing organics and to make the USDA’s role primary. By requiring each certifier to apply the same standards and to apply no higher standard, to recognize the certifications issued by another USDA accredited certifier without question, and to not allow the certifier’s seal to appear more prominent than the USDA logo on any certified product, the USDA made it clear that consumers were to look to the USDA as the primary guarantor of the organic integrity of products in the U.S.

It is clear that organic products have become increasingly mainstream since the implementation of the NOP final rule, reaching far beyond the traditional organic consumer and the early adopters. What is perhaps less clear is whether or not the USDA seal has gained supremacy over the seals of individual certifiers in creating a preference on the part of consumers choosing between competing organic products and whether or not the selection of a particular certifier confers any marketing advantage for a manufacturer of a certified organic product.

The choice of a certifier has far-reaching consequences for the organic processing operation in terms of cost, the quality of service received, the time required to become certified and the ability of the certifier to help keep the operation out of compliance trouble by communicating clearly and consistently about what the operation can and cannot do. Sacrificing in any of these areas for the perceived or claimed marketing advantage of carrying a particular certifier’s seal can only be justified to the extent that the purported marketing advantage can be realized. Considering the prevalence of the question, there is surprisingly little evidence to which an operation can turn to answer it. What little evidence does exist, however, points to an interesting conclusion that may surprise many.

What the Data Tell Us About Recognition of the Certifier’s Seal
No national survey has yet taken up the question of whether or not the identity of an organic product’s certifier has any role in influencing consumer purchasing decisions. The Hartman Group and the Natural Marketing Institute, two leading marketing research organizations that conduct extensive research on organic consumer knowledge and trends, have specifically researched what factors influence the purchase of organic products but the role that the certifier’s identity plays in selecting between competing products has not been addressed. That may reflect a belief that the answer to that question is a foregone conclusion given the current supremacy of the USDA organic seal. However, the Hartman Group and the Natural Marketing Institute data both provide important, albeit indirect, evidence that bears on the question, and to which we will return to after discussing a recent survey that addressed the question in a slightly more direct fashion.

In May of 2006, Florida Certified Organic Growers and Consumers Inc. (FOG), the parent not-for-profit organization for Quality Certification Services (QCS), a USDA accredited certifier, with grant funding from the Florida Department of Agriculture and Consumer Services (FDACS), designed and conducted a survey of Florida consumers that had the following goals:

• Determining whether the average Florida consumer is aware of the USDA National Organic Program

• Determining whether the average Florida consumer is aware of the existence of independent certifying agents

• Determining whether the average Florida consumer recognizes the individual marks or seals used by certifiers to identify products they certify

Table A. Responses from the 2006 Survey of Florida Consumers Regarding Consumer Recognition of Certifiers’ Seals.

The Florida Organic Consumers Survey was designed to elicit one-word responses to seven questions from a random sample of Florida adults. The study design allowed for 95% confidence that the obtained results would accurately reflect the population’s organic knowledge and attitudes within a +/- 4% margin of error. The survey was intended to be brief and unintimidating for participants. The relevant questions and the survey responses are detailed in Table A.

Results showed 45% of respondents have purchased organic products, 26% knew the USDA accredited independent organizations to certify growers and handlers of organic products, and 42% indicated an accredited certifier’s seal was important purchasing information. However, when asked to name a USDA accredited certifier only 8.8% agreed to try to do so. Most indicated “none” or “I don’t know.” Of those who attempted to name an actual certifier, no one named a USDA accredited certifier.

8.8% of those surveyed offered a name when asked to name a USDA accredited certifier. Of those offering a name, 33.9% named a product brand such as Kraft; 17.9% named a retailer or a retail house brand such as Whole Foods 365 (a Whole Foods organic private label brand) or Greenwise (a Publix organic private label brand); 30.4% named a generic agricultural product name such as milk or tomatoes; 5.4% named the USDA; 7% named a beauty care brand name or nonsense answer, and only 3.6% named a name that might be interpreted as a reference to an actual USDA certifier (e.g. “certified California produce” and “Oregon certifier”). No respondent clearly and unequivocally gave the actual name of a USDA accredited certifier.

A more detailed analysis of the data was conducted with survey respondents who answered “yes” to all three of the first organic related questions; that is, respondents who answered that they did purchase organic products, that they knew that USDA accredited independent certifiers certify organic products, and that looking for the USDA accredited certifier’s seal was important to them in making an organic purchase. Respondents who answered “yes” to all of these questions (11%) were believed to represent a group of more motivated and knowledgeable organic consumers, who were designated “organic aficionados” for purpose of further analysis. Among this group, one would expect greater accuracy in naming a USDA accredited certifier. However, this group was no more likely to name a USDA accredited certifier than respondents who answered “no” to one or more of the qualifying questions. The organic aficionados’ answers to the question, “If you can, please name a USDA accredited certifier whose seal you would look for on organic products,” are summarized below:

• Of the organic aficionados, 77.2% answered “I don’t know,” or “none” when asked to name a USDA accredited certifier.

• Of the organic aficionados, only 22.8% attempted to offer a name of a USDA accredited certifier.

—7.1% named a generic agricultural product

—5.7% gave a product brand name

—4.3% named a retailer or retail house brand

—1.4% named the USDA

—1.4% named a different federal agency, and only

—1.4% offered a name that might be (leniently) considered to refer to an actual USDA accredited certifier (e.g. “certified California produce” and allowing that it might refer to one of two USDA accredited certifying agents—CCOF [California Certified Organic Farmers] or COFA [California Organic Farmers Association]—or might refer only to produce certified as coming from California).

In contrast to the poor name recognition and influence of certifier’s seals as revealed by the Florida study, other studies have revealed that the USDA seal carries a relatively high level of influence on consumer purchasing decisions. Hartman Group research has indicated that less than one-third of organic consumers in various market segments report that they are “much more likely to select products labeled USDA Organic than Organic.”[1] In contrast, however, recent Natural Marketing Institute research reveals that 42% of respondent “organic users” and 18% of the general population report that the presence of the USDA seal influences their purchases “a lot.”[2] The Natural Marketing Institute further reported that the influence of the USDA seal was up 35% as compared to its influence in 2004.

While it would be inappropriate to assume that Florida consumers are representative of all consumers nationwide, the Florida study is to our knowledge the only study that addresses consumer knowledge of the identity of certifiers and their role in organic certification. There is likely to be some minor regional, state or local variation. However, it would be appropriate to assume that consumers have less knowledge of certifiers’ seals than the USDA organic seal, which as reported by The Hartman Group and The Natural Marketing Institute was influential for between 29% and 42% of consumers, with an increase in influence of 35% over two years. The Florida study suggests that certifiers’ seals are much less influential, if at all, with the most generous assessment of the study revealing them as influential in only 3.6% of consumers, and a more strict assessment that would suggest that there is no influence at all.

Given the USDA organic seal’s supremacy and the fact that only 8.8% of Florida consumers would even attempt to name a USDA accredited certifier (with none able to successfully do so), there appears to be no support for the notion that the selection of a particular certifier has any marketing advantage for a national manufacturer or marketer of certified organic products and little reason to consider this a significant factor in choosing a certifier. Clearly, the question could benefit from further research, but any certifier who claims that their seal confers a marketing advantage with retail customers should be asked to produce consumer data to support such a claim.

Should Certifiers Raise Their Profile Among Consumers?
Raising the profile of an individual certifier among consumers, so as to create some “brand” awareness of the certifier among retail consumers, and by extension some marketing benefit to the clients of the certifier, is rife with challenges—and potentially misguided. Given the fact that there are more than 90 USDA accredited certifiers, each certifying products that share retail space, it is unclear how certifiers can cut through the “noise” of the various certifiers’ seals that appear on products, and what the basis of any such attempt might be. After all, under the NOP regulations, no certifier can deny certification for a compliant product merely because it is deemed “low quality,” say made with cheap ingredients or is poorly and unattractively packaged. Accordingly, any attempt by a certifier to claim brand awareness on the basis that they certify only the highest quality products is disingenuous.

It is also unwise for the certifier to entwine its brand too closely with those it certifies for a number of reasons. First, the potential for conflicts of interest is high: The certifier cannot control NOP non-compliance related qualities of the products it certifies, and therefore cannot control the brand. It may put the certifier front and center in controversies that arise from the vagueness of the regulation, which can make the certifier a potential target of consumer groups—the exact groups among which the certifier is ostensibly trying to create brand awareness). These groups have valid concerns about maintaining the integrity of the organic regulations and how they are applied.

Additionally, such co-branding would, by logical extension, require the operation seeking certification for its products to inquire about all of the other products that the certifier certifies to make sure that its own products are not associated with any inferior products. A certified operation might have to monitor the other products the certifier later certifies to make sure that its own co-branding with the certifier is not diluted or devalued. Finally, what form, other than requiring certified operations to carry the certifier’s seal on their label, would the individual certifier’s promotions take? Is the certifier willing and able to spend resources advertising its “family” of products to the retail consumer? Can they do so in any way that is more economical and efficient than the certified operation promoting its own individual brand? After all, those costs of promotion by the certifier will be borne directly by the certified operation in the form of higher fees.

For these reasons, it can be argued that the individual certifier should stay out of the product marketing game. A certified operation should not expect its certifier to be a marketer of its products. The conflicts of interest, the certifier’s inability to control product quality, the lack of experience and the inefficiency of the certifier as marketer are each fatal flaws in any such scheme.

What Processors Seeking Certification Should Focus on When Selecting a Certifier
If there is no marketing advantage to be gained from the selection of a certifier, and if such a notion is rife with conflicts of interest, impracticalities and inefficiencies, what should an operation look for in selecting a certifier? Ultimately, there should be no mystique about the role of the certifier. While the certifier has a unique quasi-regulatory role and is responsible to consumers through the USDA, the certifier is a business-to-business service provider that provides a fungible product—access to the organic marketplace in the form of an organic certificate. It is the manner in which the customer is served where certifiers vary. Accordingly, the certifier should be judged like any business-to-business service provider: on its level of customer service, reliability, experience, and commitment to clear and timely communication. Any brand awareness that a certifier builds will be among its own customers and operations seeking certification services on these platforms.

Ultimately, the certifier should be invisible to the retail customer. Any aspirations to brand-building on the part of the certifier should be focused on by building a name for itself among its certified clients by providing top-notch customer service and doing its job better, more efficiently and more reliably than any other certifier and building consumer awareness of the USDA organic label. When the certifier does what it does best, and leaves the certified operation to do what it does best (creating and marketing high quality organic products), everyone benefits from the best advantage—a stable and long-lasting relationship as partners in NOP compliance, not marketing.

Jonathan Austin is an attorney in private practice, as well as the Managing Director of Florida Certified Organic Growers and Consumers Inc. (FOG), the parent not-for-profit organization that operates the USDA-accredited certification agency Quality Certification Services (QCS.) He also serves on the board of directors of the Accredited Certifiers Association (ACA), a trade association for USDA-accredited organic certification agencies. He can be reached at jonathan@qcsinfo.org.

References
1. Demeritt, Laurie. Consumer awareness and understanding of the USDA organic seal. Organic Processing Magazine. July-September 2006. organicprocessing.com.
2. Natural Marketing Institute. Organic Consumer Trends Report. February 2005. nmisolutions.com/r_organic.html.