On August 17, 2023, Sarah Reed (CCOF) facilitated a discussion of outstanding questions around new requirements for certification and exemptions from certification. This conversation was rooted in the understanding that the SOE rule has a bias towards certification and that USDA is best able to root out fraud and misconduct when as much of the supply chain as possible is certified. The group discussed the ins and outs of specific exemptions (including the retail exemption); and what certifiers should do after the rule’s effective date if clients are sourcing from uncertified, non-exempt operations.