Fall 2025 NOSB Meeting
National Organic Standards Board
Fall 2025 NOSB Meeting
Comment by 11:59 pm EDT, Wednesday, October 8, 2025.
The NOSB Fall Meeting 2025 will be held in person in Omaha, Nebraska and virtually from Tuesday, November 4, through Thursday, November 6, 2025. Links to listen in to the virtual comment webinars and the public meeting are posted on this webpage
From the very beginning, with the passage of the Organic Foods Production Act in 1990, “organic” has meant “continuous improvement.” The primary mechanism for continuous improvement in organic production is the high level of public involvement that comes from twice-annual meetings of the stakeholder board.
The second mechanism is the sunset process, which helps move synthetic substances out of organic production as the market invests in growing organic inputs and ingredients. Despite USDA’s efforts to weaken the sunset process, the 5-year cycle of review of every synthetic substance currently used in organic production and processing offers us an opportunity to keep organic strong and strengthen any weaknesses.
For more detailed analysis on all upcoming issues, scroll down to the Table of Contents description and links. For quick copy and paste, use the text below to comment at Regulations.gov. Add a personal message about why this is important to you at the top, if possible
Priority Issues
Beyond Pesticides Priority Issues for the Fall 2025 NOSB will be listed here soon.
For all issues that will be discussed see below.
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Fall 2025 NOSB Meeting
The Fall 2025 NOSB meeting dates have been announced and public comments are due by October 8, 2025, at 11:59 pm EDT. Your comments and participation are critical to the integrity of the organic label.
Where: The meeting will be held virtually. Online meeting access information is available here
When: Tuesday, November 4, Wednesday, November 5, and Thursday, November 6, 2025.
Written comments may be submitted through Regulations.gov until 11:59 pm EDT Wednesday, October 8, 2025. Reservations for oral webinar comments can be made here. Keep in mind they fill up fast. Registration will open in early September when the full agenda and proposals are posted. The online webinar for comments will take place on Tuesday, October 28, and Thursday, October 30.
The proposals of the National Organic Standards Board (NOSB), as a part of its ongoing review of practices and materials, are published for public comment. The public comment period will end on October 8, 2025. On this page, Beyond Pesticides will be providing the public with a listing and analysis of the issues under consideration of the Board on our website pages. You can view USDA's announcement of the NOSB's meeting and proposals here. Please see Beyond Pesticides' analysis below (and more coming soon).
Issues Before the NOSB for Fall 2025
Materials in the list below are either the subject of petitions or the subject of sunset review. Petitioned materials must have evidence summarized in the proposals that they meet the OFPA requirements of essentiality, no adverse effects on humans and the environment, and compatibility with organic practices. Sunset items are already on the National List, and being considered for delisting. They are subject to the same criteria, but are being considered under NOP's new rules.
The NOSB will vote on materials subject to sunset review at the Fall 2025 meeting.
To truly make an impact in the future of organic, Beyond Pesticides encourages you to:
- Become familiar with the issues below;
- See previous comments submitted;
- Submit a public comment by October 8, 2025 11:59 pm EDT (click here for guidelines!) and/or
- Register by October 8, 2025 11:59pm ET, to share oral comments via the online webinars on October 28 and October 30, 2025.
See the Draft Agenda and meeting issues here
See the Full meeting materials and issues here
View issues that were before the Board at the Spring 2025 meeting
Table of Contents/Navigation to Beyond Pesticides' Comments and Summaries
Compliance, Accreditation, and Certification Subcommittee
Policy Development Subcommittee
NOSB Quick Links!
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Compliance Accreditation and Certification Subcommittee
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Risk-Based Certification
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Risk-based oversight as a model for decision-making and compliance prevention strategy is an approach used by certified operations and certifiers in organic certification. As the organic supply chain and businesses engaged in the organic industry get more complex, organic certification is becoming less “one size fits all”. It is becoming more important for organizations to use a risk-based approach in order to optimize their activities (i.e. focus their attention on the areas of highest risk to their organization). Certified operations and certifiers can both apply risk-based oversight to themselves and their activities; or as an evaluation process to determine the risk of another organization they do business with. This could be a certified operation evaluating a supplier or a certifier evaluating one of their certified operations.
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Residue Testing for a Global Supply Chain
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Residue testing is an essential tool for ensuring compliance with organic regulations. Preharvest residue testing can support evaluating an organic producer’s efforts to prevent contamination, provide objective data when prohibited substance use is suspected, and monitor unavoidable residual environmental contamination levels. Postharvest residue testing can support the evaluation of contamination prevention in postharvest handling activities and across supply chains and provide objective data when prohibited substance use or when commingling or substituting conventional products is suspected. Residue testing does not substitute for the certification process and verification of compliance through an organic system plan review and annual inspection. However, it can support this process with objective results related to the presence of prohibited substances or the use of excluded methods. The new Strengthening Organic Enforcement (SOE) rule will make supply chain tracebacks and mass balances mandatory. Complete supply chain tracebacks will require many certifiers to work bidirectionally up and down the supply chain in cooperation with other certifying bodies.
Discussion
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Residue Testing for a Global Supply Chain - Regulation Review
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Residue testing is an essential tool for ensuring compliance with organic regulations. Preharvest residue testing can support evaluating an organic producer’s efforts to prevent contamination, provide objective data when prohibited substance use is suspected, and monitor unavoidable residual environmental contamination levels. Postharvest residue testing can support the evaluation of contamination prevention in postharvest handling activities and across supply chains and provide objective data when prohibited substance use or when commingling or substituting conventional products is suspected. Residue testing does not substitute for the certification process and verification of compliance through an organic system plan review and annual inspection. However, it can support this process with objective results related to the presence of prohibited substances or the use of excluded methods. The new Strengthening Organic Enforcement (SOE) rule will make supply chain tracebacks and mass balances mandatory. Complete supply chain tracebacks will require many certifiers to work bidirectionally up and down the supply chain in cooperation with other certifying bodies.
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Consistency in Organic Seed Use
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Residue testing is an essential tool for ensuring compliance with organic regulations. Preharvest residue testing can support evaluating an organic producer’s efforts to prevent contamination, provide objective data when prohibited substance use is suspected, and monitor unavoidable residual environmental contamination levels. Postharvest residue testing can support the evaluation of contamination prevention in postharvest handling activities and across supply chains and provide objective data when prohibited substance use or when commingling or substituting conventional products is suspected. Residue testing does not substitute for the certification process and verification of compliance through an organic system plan review and annual inspection. However, it can support this process with objective results related to the presence of prohibited substances or the use of excluded methods. The new Strengthening Organic Enforcement (SOE) rule will make supply chain tracebacks and mass balances mandatory. Complete supply chain tracebacks will require many certifiers to work bidirectionally up and down the supply chain in cooperation with other certifying bodies.
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E-Commerce Labeling
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Residue testing is an essential tool for ensuring compliance with organic regulations. Preharvest residue testing can support evaluating an organic producer’s efforts to prevent contamination, provide objective data when prohibited substance use is suspected, and monitor unavoidable residual environmental contamination levels. Postharvest residue testing can support the evaluation of contamination prevention in postharvest handling activities and across supply chains and provide objective data when prohibited substance use or when commingling or substituting conventional products is suspected. Residue testing does not substitute for the certification process and verification of compliance through an organic system plan review and annual inspection. However, it can support this process with objective results related to the presence of prohibited substances or the use of excluded methods. The new Strengthening Organic Enforcement (SOE) rule will make supply chain tracebacks and mass balances mandatory. Complete supply chain tracebacks will require many certifiers to work bidirectionally up and down the supply chain in cooperation with other certifying bodies.
Crops Subcommittee
Proposals
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Pear Ester – petition
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Pear ester is a chemical (Ethyl-2E,4Z-Decadienoate) synthesized to be structurally and
functionally identical to a volatile substance emitted by mature and ripening pears and other fruits. It is attractive to codling moths and is used in various ways to control them. Pear ester is described as a “kairomone,” which is defined as “a chemical that is pertinent to the biology of an organism (organism 1) and that when it contacts an individual of another species (Organism 2) evokes in the receiver a behavioural or physiological response that is adaptively favourable to organism 2 but not to organism 1. Our comments address both pear ester per se and delivery mechanisms. The Crops Subcommittee (CS) states, “Pear ester was previously allowed for use in organic crop production under the synthetic pheromone classification until its correct reclassification as a kairomone.” The petitioner would like pear ester to be added to the National List as a pheromone.
The CS should separate use of pear ester in traps from the use microencapsulated in
sprays. We believe that the use in traps may be consistent with OFPA, but the use in sprays
does not fit into any of the OFPA categories and poses unnecessary risks. We were unable to
untangle results from the two uses with respect to effectiveness of controlling codling moths,
but we encourage the CS to do so.
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Synthetic Compostable Polymers
- Beyond Pesticides' comments
- Submit your own comment here
- Background: On August 30, 2023, the Biodegradable Products Institute (BPI) submitted a petition for rulemaking to the USDA. The petition asks the National Organic Program (NOP) to engage in rulemaking to update the compost regulations in order to create a narrow allowance for certain “compostable” synthetic substances to be included as compost feedstocks without adding these substances to the National List of synthetic substances allowed in organic crop production. The petition proposes allowing substances that meet compostability specifications at ASTM D6400-21, D6868-21, or D8410-21 to be considered allowed “compost feedstocks” in compost used on organic farms. At NOSB’s Spring and Fall 2024 meetings, public commenters expressed strong and varied opinions about the appropriateness of including compostable polymers on the National List and allowing them in compost used on organic farms. For the Spring 2025 meeting, NOSB will be considering a formal proposal that confirms the need for all allowed synthetic compost feedstocks to be added to the National List through a two-third majority vote of the Board, followed by notice and comment rulemaking by USDA. This proposal is designed to convey clarity to the NOP regarding NOSB’s views on how synthetic compost feedstocks should be considered and allowed in compost used in organic crop production.
2027 Sunsets 205.601 and 205.602
- Potassium hypochlorite
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Potassium hypochlorite is a chlorine material listed for pre-harvest use at 7 CFR 205.601(a)(2)(iv) as a synthetic substance for use in organic crop production. It is listed for use in the treatment of irrigation water with the requirement that residual chlorine levels of water in direct contact with crops or water from cleaning irrigation systems applied to soil must not exceed the maximum residual disinfectant limit under the Safe Drinking Water Act. A limited scope technical report (TR) was done in 2024 to provide pertinent information specifically on potassium hypochlorite for the Board’s review of the material. This is because prior to the 2024 TR, potassium hypochlorite was assessed based on information in a 2011 TR on chlorine/bleach materials. That TR only covered specific information on sodium hypochlorite, calcium hypochlorite, and chlorine dioxide.
- Soap based algicide/demossers
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Synthetic soap salts are approved as algicides/demossers and are permitted to control algae and mosses in and around production areas including walkways, greenhouse surfaces, and irrigation systems.
- Ammonium carbonate
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Ammonium carbonate is used in small quantities as an attractant in traps. In some cases, ammonium carbonate is used alone, and in others, as a mixture with yeast to enhance its chemical attraction to insects. It is used for the control of flies that are problematic in fruit and nut production. This material compliments other natural alternatives such as the release of natural predators and parasitoids and manure management.
- Soaps, insecticidal
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Insecticidal soaps are used for control of soft bodied insects and hard bodied insects in the larval stage on organic crops.
- Sucrose octanoate esters
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Sucrose octanoate esters are listed at §205.601(e) in organic crop production as insecticides (including acaricides or mite control) in accordance with approved labeling (2024 TR, lines 32-33). Producers use SOEs to control soft-bodied pest organisms including mites, aphids, and whiteflies (2024 TR, line 56). The EPA has registered SOEs as a biopesticide for foliar spray on greenhouse, nursery, and field crops, and for Sciarid fly control in mushroom-growing media.
- Vitamin D3
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Vitamin D3 (cholecalciferol) is used to fortify food and aids in the growth and maintenance of bones. It is typically found in milk and cereals (2011 TR, lines 45-47). Forms of vitamin D are also found in margarine and infant formula. In this listing, vitamin D3 is used as a synthetic rodenticide in gel and pellet baits. Vitamin D3 kills gophers, mice, rats, and other rodents by causing an excessive, highly elevated level of calcium, which results in hypercalcemia and mineralization of major organs (including kidney failure), leading to death (2011 TR, lines 55-57).
- Aquatic plant extracts
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Plant extracts are composed of chemicals naturally found in aquatic plants (2006 TR, line 19), namely marine plants (also called seaweed). Aquatic plant extracts are used as foliar fertilizers or as soil conditioners. They also are used in combinations as a foliar/soil feed or transplant solution and seed treatment. The material is absorbed into the plant and acts as a growth promoter (2006 TR, lines 63-66). Aquatic plants contain proteins, lipids, sugars, amino acids, nutrients, vitamins, plant hormones, and other biochemicals (2006 TR, lines 26-27). Aquatic plants contain a wide range of naturally occurring plant nutrients and trace minerals essential to plant growth, health, and productivity (2006 TR, lines 41-42). Cytokinins, a class of plant hormones present in aquatic plant extracts, have been reported to have beneficial effects on crops, including increases in number or size of fruits or seed heads, synchronization of flowering within a field, and delayed decay of mature plants (2006 TR, lines 46-48).
- Lignin sulfonate
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Lignin sulfonate acts as a dust suppressant due to its large size and high affinity for binding with polar and nonpolar compounds. Small dust particles of fertilizers adsorb to lignin sulfonate to form a larger, heavier complex which reduces dust (2011 TR, lines 143-145). Products with less dust are easier to handle and are applied more efficiently and accurately. Similarly, lignin sulfonate acts as a chelating agent by binding with smaller, charged micronutrient ions such as boron, manganese, and iron, and are slowly released into the soil in a bioavailable form (2020 TR, lines 146-148). Prior to 2015, lignin sulfonate could be used as a floating agent in postharvest handling for pears. However, it was petitioned for removal at § 205.601(l)(1) in 2014 and voted off the list by the Board in Fall 2015. There were no comments supporting its listing, indicating a lack of essentiality of this synthetic material as a floating agent.
- Fatty alcohols
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Currently, EPA’s registration for this material is limited to use on tobacco. Fatty alcohols (octanol and decanol) are used to chemically remove flower buds and suckers from tobacco plants. Removal of the flower tops and the suckers encourages the growth of larger leaves. The use of fatty alcohols is an alternative to two laborious hand operations in tobacco production (2016 TR, lines 64-66). A course spray of 5% decanol or a combination of decanol and octanol applied before bud formation inhibits the formation of the bud. Fatty alcohol dripping down the stem of the plant inhibits sucker formation (2016 TR, lines 68- 70). Topping and suckering are the most time-consuming tasks associated with growing organic tobacco and may be necessary every week for 10 weeks. It can take one person per acre per day to do the job (2016 TR, lines 498-499). Yields are also increased with the use of this treatment (2016 TR, line 70).
- Sodium silicate
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Sodium silicate, also known as “water glass,” has had a range of uses that include fiber processing, fire prevention, adhesives, egg preservation, and as an anti-corrosion agent (2011 TR, lines 39-44). For organic production, it may be used to modify water density in the water tanks that remove fruit from picking bins at the start of the packing process. This is especially important for pear packing lines since pears are denser than water and will sink to the bottom of the water tank. Adding sodium silicate to the water increases the density of the water, thus causing the pears to float and making them easier to remove from the dump tank and onto the packing line (2011 TR, lines 416-417).
- EPA list 4 - Inerts of minimal concern
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Inert ingredients in pesticide formulations are added to enhance functionality and efficacy. Any of the pesticides approved for organic use may contain inert ingredients. For example, surfactants may improve the solubility and half-life of active pesticide ingredients. As described in Shistar (Shistar, T. “Inert” Ingredients Used in Organic Production. Beyond Pesticides, Washington, D.C., 2017), “The relatively few registered pesticides allowed in organic production contain product formulations with so-called “inert” ingredients that are not disclosed on the product label. The “inerts” make up the powder, liquid, granule, or spreader/sticking agents in pesticide formulations. The “inerts” are typically included in products with natural or synthetic active pesticide ingredients recommended by the National Organic Standards Board (NOSB) and listed by the National Organic Program (NOP) on the National List of Allowed and Prohibited Substances.”
- Paper
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: A paper-based crop production and planting aid is defined at § 205.2 as “a material that is comprised of at least 60% cellulose-based fiber by weight, including, but not limited to, pots, seed tape, and collars that are placed in or on the soil and later incorporated into the soil, excluding biodegradable mulch film. Up to 40% of the ingredients can be nonsynthetic, other permitted synthetic ingredients in § 205.601(j), or synthetic strengthening fibers, adhesives, or resins. Contains no less than 80% biobased content as verified by a qualified third-party assessment (e.g., laboratory test using ASTM D6866 or composition review by qualified personnel).”
- Arsenic
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Arsenic and its compounds, especially arsenic trioxide, are used in the production of pesticide-treated wood products, herbicides, and insecticides. These applications are declining due to the toxicity of arsenic and its compounds. Arsenic is sometimes alloyed with lead to form a harder, more durable metal. Some areas of use include car batteries and bullets. Until recently, arsenic was commonly used in glassmaking. However, due to pressure from the EPA and environmentalists, most glass manufacturers have slowed down or stopped using arsenic.
- Strychnine
- Beyond Pesticides’ comments
- Submit your own comment here
- Background: Strychnine is a toxic alkaloid that is a transparent crystal or white, crystalline powder. It was widely used in poison (toxic) baits to kill rodents and other mammals. Exposure to strychnine can be fatal. It is colorless, odorless and has a bitter taste. Strychnine can be absorbed into the body by inhalation or ingestion. It can also be injected into the body when mixed with a liquid. Strychnine is rapidly metabolized and detoxified by the liver. This substance is also well-absorbed and acts very rapidly, producing muscular hyperactivity, which can quickly lead to respiratory failure and death.
Strychnine has been placed in Toxicity Category I, indicating the greatest degree of acute toxicity with oral and ocular effects; inhalation toxicity is also presumed to be high
Handling Subcommittee
Proposals
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L-Malic Acid Reclassification
- Beyond Pesticides' comments
- Submit your own comment here
- Background: L-malic acid occurs naturally in many fruits and vegetables, including apples and cherries, and can be obtained by enzymatic conversion of fumaric acid and by fermentation of glucose and other carbohydrates. It is not economical to extract L-malic acid from natural foodstuffs such as apple juice. Beyond Pesticides opposes the relisting of L-malic acid. We conclude that there is not sufficient information to support the relisting of L-malic acid on §605(a). Information from the TR challenges the classification of L-malic acid as nonsynthetic and raises issues of compatibility. Ancillary substances have not been identified or assessed. Therefore, L-malic acid should not be relisted.
- Kaolin
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Kaolin is a fine clay, consisting primarily of hydrous aluminum silicate. Because of the
small particle size, it has a high surface-to-volume ratio, making it a highly absorptive material.
Although the technical advisory panel (TAP) review identifies it as an anticaking agent and a
processing aid that is not present in the final product, there is no annotation to limit its use.
Kaolin is also produced in nano-sized particles.1 Kaolin should be annotated to specify allowed
uses and prohibit the use of nano-kaolin.
- Sodium bicarbonate
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Sodium carbonates are used as raising (leavening) agents in food processing. Sodium bicarbonate (baking soda) is a common compound in baking powder; that helps to regulate acidity for things like tomato soup, or in pastes and beverages. It can be used as an anti-caking agent or as a stabilizer helping to maintain the appearance and consistency of foods. Sodium bicarbonate is often used in pancakes, biscuits, muffins, crackers, and in cookies. It often is used in self-rising flour and confections. It may also be used as a neutralizer for use in butter, cream, and ice cream.
- Waxes-nonsynthetic (wood resin)
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: According to the 2014 technical report (TR), wood rosin is used in organic processing and handling primarily as a component of fruit wax, most commonly applied to citrus fruit (2014 TR, line 86). At the most basic level, wood rosin, when formulated as part of a fruit wax, reduces the gas exchange between the surface of the fruit and the atmosphere, which in turn reduces the respiration rate and resulting weight loss. The reduced gas exchange happens in two ways: the wax forms a physical barrier that the gas must permeate, and the coating also fills openings in the fruit peel. Hagenmeier and Baker (1993) found that some factors, such as thickness of coating and the waxiness vs. resinous qualities of the coating, also affect the action of fruit waxes. For example, coating thickness is as important as type of coating for resistance to water vapor. Wood rosin, when formulated with carnauba wax at differing percentages, only offers limited resistance to water vapor unless carnauba wax comprises approximately 90% of the formula (2014 TR, lines 120-128).
- Ammonium bicarbonate
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Ammonium bicarbonate and carbonate are salts composed of ammonium and carbonate ions. Ammonium bicarbonate is the monoammonium salt of carbonic acid with the formula NH4HCO3 and a molecular weight of 79.06 g/mol. Ammonium carbonates are used as leavening agents. Ammonium bicarbonate has critical functionality as a raising (leavening) agent in certain cookies and crackers. Compared to baking soda, it produces more gas, thus not leaving behind a salty or soapy taste in the finished baked goods, as it completely decomposes into
water and gaseous products that evaporate during the baking process. It is used in baking where yeast is not used. Ammonium bicarbonate cannot be used for moist baked goods. It also helps provide certain characteristic textures (such as in crackers), as well as aids in controlling cookie spread.
- Ammonium carbonate
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Ammonium bicarbonate and carbonate are salts composed of ammonium and carbonate ions. Ammonium bicarbonate is the monoammonium salt of carbonic acid with the formula NH4HCO3 and a molecular weight of 79.06 g/mol. Ammonium carbonates are used as leavening agents. Ammonium bicarbonate has critical functionality as a raising (leavening) agent in certain cookies and crackers. Compared to baking soda, it produces more gas, thus not leaving behind a salty or soapy taste in the finished baked goods, as it completely decomposes into
water and gaseous products that evaporate during the baking process. It is used in baking where yeast is not used. Ammonium bicarbonate cannot be used for moist baked goods. It also helps provide certain characteristic textures (such as in crackers), as well as aids in controlling cookie spread.
- Calcium phosphates (monobasic, dibasic and tribasic)
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Calcium phosphates are used as raising (leavening) agents and used as a critical component in baking powder (aluminum free). All three of the calcium phosphates are used as leavening agents: dough conditioner, yeast food, or as an expanding agent. Monobasic and dibasic calcium phosphate are often used for reduced sodium baking. Monobasic is also a buffer, firming agent, sequestering agent, and is popular in pancake mixes. It is the commonly used acid, along with sodium bicarbonate, used to make baking powder. It is also used in baked goods, such as cookies, cakes, and potato chips, and as a firming agent for canned fruits and vegetables. Dibasic is used in enriched flour, noodle products, and in both dry and cooked forms of breakfast cereals. It is often used as a dough conditioner. It also can be used as a thickening agent for various cheese products. Tribasic is an anti-caking agent and buffering agent. It also provides a very critical function as a free flow aid in finely powdered salt used in baking. Additionally, it is used as a food source for yeast in bread making, as an anti-caking agent in dry powders, such as in spices, and as a thickener, stabilizer, and sequestering agent for some dairy products. Calcium is derived from either mined limestone or from oyster shells.
- Low-acyl gellan gum
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Low acyl gellan gum is used in various food formulations, such as aspics; frostings; brownies and bakery fillings; gelatins and puddings; non-standardized jams and jellies; dairy drinks and soy milks; nutritional products; beverages (dairy alternative milks, dairy drinks, fruit drinks, drinking jellies, novelty drinks); beverage mixers; kefir; yogurt, sour cream and cheese where the standards of identity do not preclude its use; yogurt fruit and fruit sauces; marinades; pourable and spoonable dressings; and dairy desserts.
- Ozone
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Ozone is a powerful oxidant with many industrial and consumer applications related to oxidation. The primary use of ozone globally is as a water treatment. In this capacity, ozone oxidizes organic and inorganic compounds, improving water quality when used as a broad-scope disinfectant. In food production, handlers also apply ozone directly to food as an antimicrobial treatment. Consequently, ozone is also a preservative (2024 TR, lines 119-122).
- Sodium hydroxide
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Sodium hydroxide is a highly caustic substance used as a processing aid in cocoa manufacturing, as a caustic bath for pretzels that makes the pretzel surface smooth and helps it to develop brown color during baking, and for removing bitterness from olives. It is also used as an alkali to peel fruits and vegetables, but this use is specifically prohibited in organic foods by the annotation. Sodium hydroxide is used to manufacture soaps, oral care products and detergents, and can be used as an ingredient in food preservatives to prevent the growth of mold and bacteria. Soda ash (NaCO3), magnesium oxide (MgO) or sodium hydroxide can be used in the production of sugar to increase the pH and alkalinity of the sugar cane juice. It is highly soluble in water.
- Carnuba wax
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Carnauba wax is used as a component in fresh fruit coatings, as a candy coating, and as component of an edible coating for nuts. Other uses include a base for chewing gum and in soft drinks. It can also be used as a processing aid, as a releasing agent, and in defoamers. Its Generally Regarded as Safe (GRAS) listing doesn’t provide any limitations on its use as an ingredient in food (2014 TR, lines 65-72).
- Colors
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Colors are added to food products to enhance the attractiveness of the food, to assure uniformity of color, to add back color lost during processing, to intensify existing colors, to protect light-susceptible vitamins, and to preserve flavor (2015 TR, lines 22-24). The natural colors market has grown dramatically since colors were added to the National List (2015 TR, lines 345-348).
- Cornstarch (native)
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Starches are used in many foods as thickeners, formulation aids, to make corn syrup, and as bulking agents and moisture adsorption agents. Cornstarch is made from special strains of corn that are high in amylose and amylopectin (1995 TAP).
- Glycerin
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Glycerin is used in food as a binder, humectant, solvent, and carrier. It is widely used in natural flavors. It is used in alcohol-free applications as an alternative to ethanol (as a carrier or solvent). It is also used in cosmetic and personal care products as an emollient, carrier, lubricant and filler. It has a neutral to sweet taste (2013 TR, lines 24-25).
- Insulin-oligofructose enriched
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Inulin-oligofructose enriched (IOE) is on the National List as a nonorganically produced agricultural product allowed in or on processed products labeled as “organic.” IOE is a non-digestible carbohydrate that is used to increase calcium bioavailability and absorption, as a soluble dietary fiber, as a noncaloric sweetener, and for functional effects on the texture/consistency of food (2015 TR, lines 130-132). It is used in many foods including yogurt, baked goods, candies, jams, baby formulas, and other dairy products.
- Orange Shellac
- Beyond Pesticides’ comments
- Submit your own comments here
- Background: Orange shellac is used to coat fruits and vegetables to reduce water loss and retain firmness. It is an ingredient in lozenges, capsules and tablets, and is a part of confectionary glazes on candy, chocolate and coffee beans. Shellac dye is also used as a food color. It is a natural bio-adhesive polymer that is soluble in alkaline solutions such as ammonia and in solvents such as ethanol. Shellac is water insoluble. There are also numerous non-food uses: on wood, in cosmetics, in clothing, on seeds, and in adhesives, varnish, and polishes.
Livestock Subcommittee
Proposals
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Oxytocin Annotation
- See Beyond Pesticides' comments here
- Submit your own comment here
- Background: Oxytocin should be allowed to sunset. Past comments have shown that the annotation is vague and that it was misused, to help cows let down their milk. Cows can become dependent on it for let-down. There are alternatives. It is a hormone, and even though its use is intended to be limited, this listing allows a use of hormone in organic dairy, which is contrary to consumer expectations.
Discussion
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Chlorine Materials
- See Beyond Pesticides' comments here
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- Background: In September 2024, the National Organic Program received a petition from the Organic Materials Review Institute (OMRI) requesting an amendment to the annotation for Chlorine materials at § 205.603(a)(10) to clarify whether they are allowed for direct treatment of livestock drinking water. The petitioner stated that some entities in the organic industry have established policies that are based on the belief that the National List at § 205.603(a)(10) allows for direct livestock drinking water treatments as long as the final drinking water meets Safe Drinking Water Act (SDWA) standards. Other entities in the industry interpret the § 205.603(a)(10) annotation as one that limits the use of chlorine materials to disinfection of facilities and equipment.
- Integrating Livestock and Agroforestry Crops
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- Background: Pasturing domestic animals in tree crop stands has been practiced for many centuries by cultures around the world. Modern farmers are implementing it as well. It enables fuller utilization of land, and benefits livestock via shelter and forage. Integrating livestock into crop systems is considered a key practice for improving soil health. Tree crops can also benefit from increased nutrients in animal manure and reduction of weedy competition or pests. This discussion document examines food safety aspects of pasturing domestic animals in tree plantings that produce human food crops, and whether National Organic Program regulations might be optimized for them. The Livestock Subcommittee requests feedback from stakeholders on this document.
2027 Sunsets 205.603 &205.604
- Butorphanol
- Beyond Pesticides' comments
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- Background: Butorphanol is used in livestock production as a pre-operative treatment of pain before surgery. Butorphanol belongs to a general class of drugs known as opiate agonists. It is commonly used as an anesthetic used to treat patients prior to surgery. Other related drugs in this class include buprenorphine, fentanyl, merperidine, and morphine. Xylazine, acepromazine, and butorphanol serve similar functions, but each has its own specific advantages that make it the preferred treatment at the time: acepromazine has no analgesic activity, it is only a sedative; xylazine has both analgesic and sedative properties; and butorphanol is a pain killer with no real sedative activity (2002 TAP, page 24). Although there are non-synthetic opiates (refers to a group of drugs used for treating pain), butorphanol is preferred for several reasons: it is associated with fewer adverse effects for the animal and it has less abuse potential in humans, thereby reducing unwanted consequences if the drug is diverted to illicit use (2002 TAP, page 26).
- Flunixin
- Beyond Pesticides' comments
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- Background: Flunixin, in its compounded state called flunixin meglumine, is a potent, non-narcotic, nonsteroidal analgesic agent with anti-inflammatory and antipyretic activity. Flunixin, in its drug form, Banamine®, exists for intravenous or intramuscular use in horses and for intravenous use in beef and non-lactating dairy cattle only to treat inflammation and pyrexia (2007 TAP, pages 1-2.
- Magnesium hydroxide
- Beyond Pesticides' comments
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- Background: Magnesium hydroxide, also referred to as milk of magnesia, is used as an antacid for temporary relief of an upset stomach and as a laxative for short-term relief of constipation. Magnesium hydroxide is used as a flame retardant and smoke depressant for temperatures exceeding 400 degrees Fahrenheit. It is also a general food additive used as a color-retention agent, drying agent, pH control agent, or processing aid.
- Oxytocin
- Beyond Pesticides' comments
- Submit your own comment here
- Background: Oxytocin is a hormone produced primarily in two discrete locations in the brains of all male and female mammals (2005 TR, lines 18-19). In nonorganic production, it can be used regularly to help nonorganic dairy cows relax and “let down their milk” (1995 TAP, page 9). There are some concerns with overuse of oxytocin in nonorganic production systems. In the USDA organic regulations, it is used “in post parturition therapeutic applications,” which is ambiguous.
- Poxolaene
- Beyond Pesticides' comments
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- Background: Poloxalene (chemical formula: C5H10O2) is a copolymer of polyethylene and polypropylene ether glycol that is a non-ionic polyol surface-active agent. Poloxalene is a fast-acting synthetic material approved under the organic regulations only for emergency treatment of bloat in ruminants, such as cattle and sheep. Poloxalene destabilizes foam and allows gas to release from the rumen.
- Formic acid
- Beyond Pesticides' comments
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- Background: Formic acid is a pesticide employed to control Varroa and tracheal mites in honeybee hives. Deployed in the form of a compressed pad inside the hive, the material volatilizes to kill mites throughout the hive including mites attacking broods, and those located externally on and internally in the adult bees.
- Sucrose octanoate esters
- Beyond Pesticides' comments
- Submit your own comment here
- Background: Sucrose octanoate esters are listed at §205.603(b)(10) in organic livestock production as a topical treatment, external parasiticide or local anesthetic as applicable, in accordance with approved labeling (2024 TR, lines 34-35). The product is used in controlling Varroa mites in honeybees.
- EPA List 4 Inerts
- Beyond Pesticides' comments
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- Background: IInert ingredients in pesticide formulations are added to enhance functionality and efficacy. Any of the pesticides approved for organic use may contain inert ingredients. For example, surfactants may improve the solubility and half-life of active pesticide ingredients. As described in Shistar (Shistar, T. “Inert” Ingredients Used in Organic Production, Beyond Pesticides, Washington, D.C., 2017), “The relatively few registered pesticides allowed in organic production are contained in product formulations with so-called “inert” ingredients that are not disclosed on the product label. The “inerts” make up the powder, liquid, granule, or spreader/sticking agents in pesticide formulations. The “inerts” are typically included in products with natural or synthetic active pesticide ingredients recommended by the National Organic Standards Board (NOSB) and listed by the National Organic Program (NOP) on the National List of Allowed and Prohibited Substances.”
- Excipients
- Beyond Pesticides' comments
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- Background: There are more than 8,000 food, drug, and cosmetic excipients available for conventional production; however, excipients currently appear in the USDA National Organic Program (NOP) regulations at §205.603 for use in the manufacture of drugs used to treat organic livestock when the excipient is identified by the FDA as: 1) Generally Recognized As Safe (GRAS); 2) approved by the FDA as a food additive; 3) included in the FDA review and approval of a New Animal Drug Application or New Drug Application; or 4) Approved by APHIS (Animal and Plant Health Inspection Service) for use in veterinary biologics. Additionally, excipients are allowed in “nutritive supplements” listed at §205.603(a)(21).
- Strychnine
- Beyond Pesticides' comments
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- Background: trychnine is a toxic alkaloid that is a transparent crystal or white, crystalline powder. It is colorless, odorless, and has a bitter taste. It was widely used in poison (toxic) baits to kill rodents and other mammals and is a common adulterant of many illicit (street) drugs. Exposure to strychnine can be fatal. Strychnine can be absorbed into the body by inhalation or ingestion. It can also be injected into the body when mixed with a liquid. Strychnine is rapidly metabolized and detoxified by the liver. This substance is also well-absorbed and acts quickly to produce muscular hyperactivity, which can quickly lead to respiratory failure and death.
Materials Subcommittee
- Research Priorities 2025
- Beyond Pesticides' comments
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- Background: The National Organic Standards Board (NOSB) presents an annual list of research priorities for organic food and agriculture, a process originally established by the Board in 2012. The NOSB requests that integrated research be undertaken with consideration of the whole farm system, recognizing the interplay of agroecology, the surrounding environment, and both native and farmed species of plants and animals. As part of this year’s process, the Livestock, Crops, and Handling Subcommittee have made an effort to categorize and differentiate highest priority topics from ongoing topics.
- Induced Mutagenesis
- Beyond Pesticides' comments
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- Background: This discussion applies to both seed-propagated crops and clonally propagated crops such as many fruits and nuts. It uses the term “seeds” throughout for simplicity, which should be read to also include “propagules.” This document distinguishes three aspects of organic seeds:
Breeding of organic seeds/varieties – that is, breeding seeds especially suited for organic
production, ideally under organic conditions.
Propagation of organic seeds – growing seed crops under organic conditions. Currently, organic
seed can be produced starting with either organic or untreated, conventional seed (if organic is
commercially unavailable), which is then grown under organic conditions.
Production using organic seeds – growing crops under organic conditions. Organic seeds are
required unless they are not available for the required traits or quantity, in which case
untreated, conventional seeds can be used.
The scope of this discussion document is limited to seeds as distinguished above. It does not cover the use of induced mutagenesis (IM) in microbe or animal breeding.
Policy Development Subcommittee
- Policy and Procedures Manual Revision
- Beyond Pesticides' comments
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- Background: The Policy and Procedures Manual (PPM) was established to assist the National Organic Standards Board (NOSB) in the implementation of its duties under the Organic Foods Production Act (OFPA), and the USDA Organic Regulations (7 CFR Part 205). It contains operating procedures and policies for the NOSB. During the period since the last revision (April 2024), the Policy Development Subcommittee has discussed changes to address actions the board can take when board members do not participate in meetings and how to ensure the highest level of trust and transparency in our process when evaluating new substances for inclusion on the National List.
- Discussion Document: Sunset review efficiency
- Beyond Pesticides' comments
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- Background: The NOSB dedicates significant time at each Fall meeting to reviewing and voting on substances scheduled for sunset. Numerous National List substances have been reviewed by the NOSB several times and have received unanimous support for relisting. The NOSB has an ongoing obligation to review these materials and determine whether they continue to meet National List criteria, particularly in light of any new information. In recent years, the NOSB’s sunset process has included subcommittee discussions, full Board discussion at the Spring meeting, further subcommittee discussions, and a second full Board discussion and vote at the Fall meeting