USDA Cotton Classing and Standards

Every bale of U.S. cotton can be submitted to a USDA classing office for official grading — a measurement of fiber length, color, leaf content, and other quality factors against physical reference standards. This classification system, governed by 7 CFR Part 28, is the common language of the entire U.S. cotton market: buyers, sellers, textile mills, and futures traders all price and contract cotton using USDA class data. The free classification service for producers — which delivers electronic quality data for every submitted bale — is one of the lesser-known ways USDA supports farm income directly.

Current Rule (2026)

What This Rule Does

Every bale of cotton produced in the United States can be submitted to a USDA classing office for official classification — a measurement of fiber length, color, leaf, and other quality factors against physical standard samples maintained by the USDA. This classification, governed by 7 CFR Part 28, is the universal language of the U.S. cotton market: buyers, sellers, textile mills, and futures traders all reference USDA class data when pricing and contracting cotton.

The U.S. Cotton Standards Act of 1923 created the official standards framework. AMS maintains the physical standard sets — sealed containers holding actual cotton samples that represent each official grade — and licenses the classing offices and gin/warehouse sampling operations that feed the system. Cotton prices on the Intercontinental Exchange (ICE) futures contracts are denominated in terms of USDA grades, and cash contract discounts and premiums are calculated based on departures from the "contract grade" (which has historically been Middling, 1-3/32 inch staple).

The classification data AMS generates serves two markets simultaneously. Commercial classification (Subpart A) is a paid service for merchants, merchants' agents, and exporters who need certified classification for trading purposes. Classification for Producers (Subpart D) is a free government service — the USDA classes producers' bales submitted through licensed gins and warehouses and delivers classification data electronically at no charge, giving farmers an independent assessment of their cotton's quality before they sell.

AMS also classifies foreign-grown cotton (Subpart B) when imported into the United States and performs high-volume instrument (HVI) fiber and processing tests (Subpart E) that measure micronaire (fiber fineness and maturity), fiber strength, uniformity, and elongation — properties critical to modern textile mill processes.

Key Provisions

• § 28.105 — Physical standard sets: sealed, signed, certified cotton samples representing each official grade are available for purchase; they are the reference against which all classification comparisons are made
• § 28.106 — Universal standards: foreign cotton associations and exchanges that adopt the U.S. standards as their own may display the association's name on the outside of the standards container — making U.S. grades the de facto international benchmark
• § 28.107 — The original standard sets and reserve sets are kept by USDA; the Director may authorize them to be moved for Universal Cotton Standards Conferences
• § 28.116 — Commercial classification fees: set annually by AMS based on hourly cost (pay + benefits + operating overhead); overtime at 1.5×, holidays at 2×; fee is assessed when the request is filed
• § 28.118 — No fee for corrections: clerical errors, form replacements, and administrative changes do not trigger a new classification fee
• § 28.301–28.307 — Staple length standards: measured at 65% relative humidity and 70°F with the Suter-Webb Duplex Cotton Fiber Sorter; official lengths run from "Below 13/16 inch" through steps of 1/32 inch up to "1 3/4 inch and longer"; when different parts of a bale measure different lengths, the bale gets the shorter length
• §§ 28.401–28.406 — Color grade hierarchy for American Upland cotton: Good Middling → Strict Middling → Middling → Strict Low Middling → Low Middling → Strict Good Ordinary; each grade is defined by reference to the physical standard samples USDA maintains
• § 28.901 — Definitions for the Classification for Producers program: "Act" includes both the Cotton Standards Act and the Cotton Statistics and Estimates Act
• § 28.903 — Free classification: when a producer sends a properly sampled bale, the Director must provide classification results to the producer or the producer's designated agent
• § 28.904 — Market news service: AMS distributes current price information for different cotton qualities to producers and anyone who requests it
• § 28.906–28.908 — Sampling: cotton must be sampled by a licensed gin or warehouse; samples are approximately 6 oz per bale (at least 3 oz from each side); one sample per bale for classification, with an optional second sample for review
• § 28.910 — Classification results delivered electronically at no charge; extra copies or alternative delivery methods carry a fee
• § 28.917 — AMS may suspend services for producers who fail to comply with the regulations or fail to pay commercial classification fees

How It Affects You

If you grow cotton: Classification for Producers is a free federal service. Once your gin or warehouse submits the samples, AMS classes your bales and delivers the results electronically. The class data — grade, staple length, micronaire, strength, uniformity — tells you where your cotton lands on the quality spectrum before you negotiate a price. Cotton buyers in the merchant and manufacturing sector make offers based on USDA class data; having the official number removes information asymmetry from the negotiation. Class data is also used by crop insurance adjusters to calculate quality-adjusted loss payments.

If you buy, sell, or trade cotton: USDA class certificates are the standard documentation for cotton sales contracts. Most domestic and export contracts specify delivery at or near a contract grade, with discounts and premiums for departures. ICE futures settlement uses USDA class data. When you take delivery of a futures contract, you receive bales with USDA class certificates documenting their quality. The classification system provides a trusted third-party quality description that makes it possible to trade cotton as a commodity rather than requiring inspection of every individual lot.

If you operate a textile mill: HVI fiber tests under Subpart E give you micronaire, fiber strength, length uniformity, and elongation data — the properties that drive spinning efficiency and yarn quality. AMS test data allows mill buyers to specify exactly the fiber profile they need for their yarn systems. Mills typically specify minimum HVI parameters in their purchase contracts; USDA data is the standard verification mechanism.

If you are a cotton gin or warehouse: To participate in the Classification for Producers program, your operation must be licensed to sample cotton under §§ 28.20–28.22. Licensed gins and warehouses are "primarily responsible" for collecting, labeling, handling, and shipping samples. You bear the costs of sample preparation and delivery to the shipping point; AMS covers postage and carrier shipping after that. Licensing can be suspended for non-compliance.

Statutory Authority

This rule implements:

• 7 U.S.C. §§ 51–65 (U.S. Cotton Standards Act of 1923) — Authorizes USDA to establish and maintain official cotton standards for the United States, operate classing offices, license samplers, and provide classification services
• 7 U.S.C. §§ 471–476 (Cotton Statistics and Estimates Act of 1927) — Authorizes USDA to collect and disseminate cotton production and market data, including the Classification for Producers program market news service

Recent Rulemakings

• 81 FR 7030 and 81 FR 7031 (February 2016) — Dual rulemaking that updated the classification program; affected 10 sections each; part of a modernization of the fee structure and HVI testing protocols
• 65 FR 36601 (2000) — Earlier update affecting 10 sections; updated fee calculation methodology
• 52 FR 30881 and 52 FR 30882 (1987) — Major earlier amendment package establishing the current fee structure framework

The official grade standards themselves — particularly the color grade hierarchy and staple length categories — have been highly stable. The physical standards are replaced or refreshed when the reference cotton deteriorates, but the grade designations (Good Middling through Strict Good Ordinary for color; 13/16 inch through 1 3/4+ for staple) have not changed in decades.

Cotton Futures Classification (7 CFR Part 27)

A parallel USDA classification program — 7 CFR Part 27 — covers cotton submitted for classification specifically in connection with cotton futures trading on commodity exchanges. While Part 28 serves the general commercial and producer markets, Part 27's classification is designed to produce the official quality certificates that underpin futures contract delivery. The statutory authority is 7 U.S.C. §§ 15b (Commodity Exchange Act futures provisions governing cotton).

Key distinctions from the Part 28 general program:

• Supervisory structure: USDA's Cotton Division directly supervises inspection, weighing, and sampling for futures classification (§ 27.10); the Area Director oversees Marketing Services Offices performing the work
• Request timing: classification requests must be filed within 10 days of sampling (§ 27.14); this tighter window reflects the time-sensitive nature of futures delivery logistics
• Micronaire: fiber fineness and maturity (micronaire) may be determined as incidental to futures classification when requested (§ 27.13) — providing the same HVI-type data available under Part 28's Subpart E
• Conflict of interest: persons disapproved by the Area Director may not perform inspection or sampling under Part 27 (§ 27.18); the program's integrity depends on classification independence from the futures market participants whose contracts turn on the results
• All provisions in Subpart A (64 sections): unlike Part 28's multi-subpart structure covering commercial, foreign, and producer classification, Part 27 concentrates its entire regulatory scheme in a single subpart

The practical significance: ICE cotton futures contracts settle based on USDA grade certificates. A trader taking physical delivery under a futures contract receives bales with USDA Part 27 classification certificates. The Part 27 program ensures that certificates used in exchange-regulated settlement are produced under the tightest quality controls — separate from the general commercial classification system and subject to the oversight structure of the Commodity Exchange Act.

Recent Developments

• HVI technology evolution: High Volume Instrument (HVI) testing — which measures multiple fiber properties simultaneously — has become the industry standard since the 1990s. USDA's marketing services offices maintain calibration standards through official reference cottons (ORC) that serve as the physical basis for all HVI measurements. As HVI technology continues to improve measurement precision, USDA periodically updates measurement protocols and reference cotton refresh schedules.
• Advanced fiber information systems (AFIS): Beyond traditional HVI measurements, some research and premium market applications use Advanced Fiber Information System (AFIS) measurements for finer characterization of nep content, short fiber content, and maturity. USDA's cotton classing regulations focus on the HVI properties used for commercial trading; AFIS results are supplementary and not part of the official USDA classification certificate.
• U.S. cotton exports and certification: The United States is a major cotton exporter, with approximately 70–80% of annual production exported. USDA classification certificates issued under Part 28 are recognized in international cotton trading under the American Cotton Shippers Association (ACSA) contract rules and in Liverpool Rules contracts. The international credibility of USDA's classification program supports premium pricing for U.S. Upland and Pima cotton in global markets.
• Farm Bill and cotton program interaction: Cotton's unique position in federal agricultural policy — it is an eligible commodity for Agricultural Risk Coverage (ARC) and Price Loss Coverage (PLC) programs, and also has a separate lint content-based marketing loan under STAX — means that USDA's classification data directly affects subsidy payment calculations. Accurate fiber quality data has financial implications beyond trading: it determines marketing loan rates for individual bales.

Pending Action

No major rulemaking of 7 CFR Part 28 is currently pending. USDA's AMS Cotton and Tobacco Program updates classification fee schedules annually (published in the Federal Register) and updates HVI measurement protocols on a technical basis without formal rulemaking. Farm Bill 2025 reauthorization affects the cotton marketing loan and ARC/PLC programs that interact with USDA classification data, but the classification standards themselves are administratively stable. Cotton producers and merchants should monitor AMS's annual fee schedule updates and check the AMS Cotton and Tobacco Program website for any updates to classing office procedures or HVI calibration reference cotton refresh schedules that affect the classification data they rely on for commercial transactions.