Requirements also include no medications for the pullets when they hatch and no beak trimming (so no buying started pullets from a hatchery). No antibiotics -- though if a hen gets sick or injured and requires antibiotics for proper treatment you are expected to provide them, but take the hen out of the organic egg production pen. After the necessary withdrawal period from the med, she would have to relegated to a non-organic flock.
Then, if you're looking to get certified, you have a lot of paperwork to complete, a lot of fees to pay, and a lot of hoops to jump through. All of which will be ongoing. On the other hand, you can tell people that you provide the hens with certified organic layer feed, that their environment is free from chemicals, and explain why you don't want to carry the brand name of Certified Organic because of all the bureaucratic nonsense that doesn't make the eggs any better and because part of "the good life" for hens includes eating table scraps that might not qualify. Most consumers who are searching for a better product will probably understand that.