Interesting. Thank you for that link, Peter. Also from the http://1.usa.gov/organic-certification website:
"These regulations describe the specific standards required for you TO USE THE WORD “ORGANIC” OR the USDA organic seal" (emphasis added). That is, they assert the authority to require you to follow their regulations even to make the claim that you followed "organic processes" whether or not you choose to use their seal. That wording also requires you to follow their regulations whether or not you meet the exception for certification.
Mike Rossander
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