Environmental certification programs have emerged and matured in many resource industries. Program autonomy is a central strategic problem in assessing program effectiveness and legitimacy. The article treats the problem of autonomy by drawing on Teubner's heuristic, strategic reconceptualization of Luhmann's conception of autopoiesis. Emergent autonomy can be inferred in different ways at different stages of program development. It is concretely expressed both in a distinct circularity in internal referral, deferral, and appeals procedures, and in institutional capacities to develop such procedures. Procedural circularity is often taken as evidence of program failure, but it may instead be an indicator of early strength. Periods of acute crisis are privileged circumstances for observing such capacities.