Do You Want Organic Food to Be Held to the Highest Standards?

This precedes the upcoming public comment webinar on October 17 and 19 and the deliberative hearing October 24-26—concerning how organic food is produced. Sign up to speak at the webinar by September 29. Written comments must be submitted through Regulations.gov. by 11:59 pm EDT, September 28. Links to the virtual comment webinars and the public meeting will be posted on this webpage in early October. 

The NOSB is responsible for guiding the U.S. Department of Agriculture (USDA) in its administration of the Organic Foods Production Act (OFPA), including the materials (substances) allowed to be used in organic production and handling. The role of the NOSB is especially important as we depend on organic production to protect our ecosystem, mitigate climate change, and enhance our health. 

The NOSB plays an important role in bringing the views of organic producers and consumers to bear on USDA, which is not always in sync with organic principles. There are many important issues on the NOSB agenda this Fall. We encourage you to use the Beyond Pesticides organic webpage and comment on as many issues as you can. For a complete discussion, see Keeping Organic Strong and the Fall 2023 issues page.

Some important issues that need your comments:
  1. “Inert” ingredients used in organic agriculture must be evaluated individually. “Inert” ingredients are not necessarily biologically or chemically inert—in almost every category of harm, there are more harmful “inerts” than active substances used in organic production. OFPA allows the use of a synthetic substance in organic production only if it is listed on the National List “by specific use or application” based on a recommendation by the NOSB, following procedures in OFPA. The NOSB has repeatedly passed recommendations telling NOP to evaluate individual “inerts.”

  2. Plastic mulch is under consideration this year as a part of its five-year review cycle. This is part of the larger issue relating to the use of plastic in organic production and handling. Awareness is growing about the impacts of plastic—and the microplastic particles resulting from its use—on human health and the environment. Plastics manufacture requires transportation of hazardous chemicals, such as those involved in the recent derailment in East Palestine, Ohio. Organic should lead the way. Plastic mulch should not be relisted as allowable in organic production. Moreover, the NOSB should initiate action to eliminate all uses of plastic in organic processing and packaging.

  3. Nonorganic ingredients should be eliminated from processed foods under the NOSB review (or sunset) process. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” The materials on §205.606 up for sunset review this year are made from agricultural products that can be supplied organically and thus should be taken off the National List of allowed materials

Submit Comments Now. 

Need help in submitting comments? Regulations.gov requires more than a single click, but it is not difficult. Please feel free to cut-and-paste language from the comments above into Regulations.gov and add or adjust the text to personalize it. See this instructional video. (Regulations.gov has changed its look since this video was made.) 

Thank you for keeping organic strong!