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Organic 101: Allowed and Prohibited Substances

Posted by Miles McEvoy, National Organic Program Director in Food and Nutrition Research and Science
Aug 16, 2018

The basic rule for organic agriculture is to allow natural substances and prohibit synthetic. For livestock like these healthy cows, however, vaccines play an important part in animal health—especially since antibiotic therapy is prohibited.
The basic rule for organic agriculture is to allow natural substances and prohibit synthetic. For livestock like these healthy cows, however, vaccines play an important part in animal health—especially since antibiotic therapy is prohibited. (Photo courtesy Pleasantview Farm, an Ohio certified organic dairy farm)

This is the second  installment of the Organic 101 series that explores different aspects of the USDA organic regulations.

Organic standards are designed to allow natural substances in organic farming while prohibiting synthetic substances. The National List of Allowed and Prohibited Substances—a component of the organic standards—lists the exceptions to this basic rule.

The National Organic Standards Board (NOSB) is designed by law to advise the National Organic Program (NOP) on which substances should be allowed or prohibited.  Made up of dedicated public volunteers appointed by the Secretary of Agriculture, board members include organic growers, handlers, retailers, environmentalists, scientists, USDA-accredited certifying agents and consumer advocates.

NOSB members must use specific criteria when voting, including the need for the substance and its impacts on human health and the environment.  In specific cases, the NOSB also votes to allow non-organic versions of a substance if it isn’t available in organic form on a scale large enough to support organic agriculture.

Some synthetic substances are listed as exceptions to the basic rule and are allowed for use in organic agriculture.  For instance, pheromones have long been used as an effective, non-toxic way to “confuse” insects that may otherwise infest organic crops, especially fruit. Likewise, vaccines for animals are important disease prevention tools against many infectious diseases, especially since antibiotic therapy is prohibited in organic livestock.

The National List also allows certain processing aids, such as baking soda. This substance lightens (or leavens) the dough for organic pancakes, baked goods, and other products.

Conversely, some substances like strychnine and arsenic are examples of natural toxic substances that are prohibited in organic production.

The process for adding or removing allowed substances is an open process, allowing for direct input from the organic community.  The process typically follows these steps:

  1. An individual or organization submits a formal petition to add, remove, or change the listing for a specific substance.
  2. NOSB sub-committee reviews the petition. A third-party technical report is often used to gather scientific information about the substance and to identify any negative impacts to human health or the environment.
  3. The NOSB sub-committee publishes a proposed recommendation for the substance with request for public comments before a public meeting, typically held twice per year.
  4. During the meeting, the NOSB discusses the public comments related to the petition and then votes in a public forum. All NOSB meetings are free and open to the public.
  5. The NOP reviews the NOSB’s recommendation. The NOP can reject the NOSB’s recommendation to add a substance to the National List, but can’t add a substance that hasn’t been recommended by the NOSB.
  6. If the NOP agrees with the NOSB’s recommendation, it initiates rulemaking to amend the National List for that substance.

Through this process the NOSB devotes countless hours to discussing the range of perspectives on each substance under their review. The public comment process plays an important role in ensuring that all perspectives are considered thoroughly.

Since this citizen advisory board represents all key sectors of the organic community, the NOSB’s recommendations provides the NOP with invaluable insight into which substances should be allowed or prohibited in organic agriculture. The NOP invites the public to participate in this process as we shape the future of organic agriculture.

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Comments

K.sahithi
May 08, 2018

Where can I see regulations for gums and polysaccharide s

Ivà
Jun 26, 2018

Is Purified Protein of Pea allowed as a fining agent for certified "made with organic grapes" wines? Many thanks.
Many wine products suppliers say yes, but some certifying agents say no.

Jay Dralle
Jul 20, 2018

I'm looking much more for the USDA Organic seal. I'm assuming that glyphosate (Monsanto or other companies) is not allowed in the food production in order to receive the USDA seal?

Ben Weaver
Jul 27, 2018

@Ivà - The Organic Wine: Oversight, Labeling and Trade fact sheet and the Labeling Organic Wine guide provide assistance in interpreting the USDA regulations for wine being labeled and marketed as ‘organic.’ In addition, the USDA organic regulations describe composition requirements for organic products, including wine.

To get additional information on specific products, we encourage you to contact a USDA-accredited certifying agent.

Certifying agents are responsible for evaluating whether the products produced and handled by a certified operation comply with the USDA organic regulations. As such, they are best positioned to answer questions like these. You can work with any accredited certifier you would like based on your needs - If you are not currently working with a certifier, you can find one at: organic.ams.usda.gov/Integrity/Certifiers/CertifiersLocationsSearchPage.aspx.

Piller Gregerson
Aug 16, 2018

The Organics 101 link, the very first link in this, is a 404. Please fix this. I came looking for information and found that instead.

Jo NELSON
Sep 02, 2018

Carrageenan, and any ingredient that states some kind of gum in gluten free products ARE TOXIC. I just had celiac.
I starting drinking protein drinks and gluten free foods. I became so sick, weak,
IBS. Stomach pains. All ingredients in
Boost, Ensure, Protein powders, foods
Has Carrageenan. Now I have autoimmune
Disease. Stomach inflamed, joints inflamed. As soon as I stopped eating or drinking any product that had Carrageenan in it. My stomach lining is starting to heal. Now today I see that
Ensure Max drink just came into the stores for old people to drink that has Carrageenan with caffeine. The government is miss guiding - and the companies putting this ingredient into our food and drinks are tricking. Old people to kill us with tumors and gallbladder, cancer.
What you do to trick people will come back your way. I bet your not drinking theses
Products. Get rid of red seaweed, any product that has the last ingredient that has gum in it and Carrageenan.

beth malik
Sep 20, 2018

I am making a product and want it to be organically certified. This product has a percentage of dried wild porcini mushrooms. They are not organically certified, but do they need to be in order to have the product certified organic if all other ingredients are organically certified?

J. Haymon
Jan 14, 2019

For a meal to be label as "organic" can it contain non organic spices/seasonings like salt, pepper, parsley, etc?

Cynthia Doisy
Jan 21, 2019

I would like to know how you qualify organic agriculture on a piece of property that may have been farmed commercially, i.e. w/ pesticides, previous to the establishment of the NOSB.

Lane Partin
Mar 14, 2019

We need to educate people about GMO's. I'm tired of seeing people buy a corn product just because it has "Non GMO" on the package. All corn has been genetically modified throughout the years of humanity. These advertisements are just simply not true.

Subra
Mar 25, 2019

Is palm leaf plates accepted under fda

Sanaullah
May 06, 2019

potassium extracted from crop, could be considered as organic potash?

Dipankar Verma
May 07, 2019

In organic moringa powder, the followings herbicides came up in lab results:

Shall FDA & USDA are ok with the below:

Metribuzine - 0.044ppm
Monochrotophos -0.212 ppm
Quinalphos - 0.048 ppm

Client in USA has concern about it. Any help shall be beneficial for the moringa community. Thanks.

rohit vohra
May 30, 2019

potassium sorbate . can we use it in organic fruit and vegetable juices as preservative

Shwetha K.R
Jun 25, 2019

I would like to know is Dalda is allowed to use in organic processing??
Thank you

Ben Weaver
Jun 26, 2019

@Shwetha K.R - thank you for your comment. Hydrogenated oils are manufactured by chemically changing an oil using methods that are not permitted by the organic regulations. Some nonorganic ingredients are allowed in organic products (at maximum levels). Organic regulations do not currently include any exceptions for hydrogenated oils.

In general, synthetic substances are prohibited unless specifically allowed and non-synthetic substances are allowed unless specifically prohibited. For more information on exemptions, please see the National List of Approved and Prohibited Substances.

Bill
Jun 27, 2019

I need to know what anticorrosion steam line treatment chemicals are the best option for use in organic food production where the steam comes in direct contact with the product.

Darrell S
Jul 10, 2019

Can the water source from an underground well to grow organics supply one organic greenhouse also source water to other non-organic greenhouses?

Ben Weaver
Jul 11, 2019

@Darrell S - thank you for your comment. Every farm is different. USDA accredited certifiers are trained to help organic farmers ensure their organic system plans comply with the organic standards.

Aaron
Nov 26, 2019

Please stop using citric acid in product as a preservative immediately. I avoid them all and I pretty sure I am not alone.
Thanks for stopping
Please let me know when you do so I can start buying your products again.
Aaron avid organic fan except when I see unneeded and unnatural products added. You guys are not looking to good on this one.

sam byrd
Dec 06, 2019

Are there any synthetic nitrogen sources that are GRAS?

Rodrigo Sanchez
Dec 10, 2019

We are a company and we are interested in participating in the National Organic Program.
For 1 of our products: it is an ingredient for final products such as fungicides and organic insecticides,
We are a Colombian company concerned with the environment.
We would like to know if there is any kind of special standard for a product (ingredient / raw material) is Mixture of methylated oil palm
I appreciate all the information you can give me about it.

Greetings from Colombia
Cordially

Ben Weaver
Dec 11, 2019

@Rodrigo Sanchez - thank you for your comment. Imported organic products must be certified to one of the following standards to be sold in the United States:

  1. The USDA organic regulations: USDA authorizes organizations around the world to certify farms and businesses to the USDA organic regulations. Learn about the certification process and view a list of accredited certifiers at: www.ams.usda.gov/services/organic-certification/becoming-certified.
  2. An authorized international standard: The U.S. has established organic trade arrangements with Canada, the European Union, Japan, Republic of Korea and Switzerland. These arrangements help food producers located in the U.S. import organic ingredients that are not produced within the U.S. View details: www.ams.usda.gov/services/organic-certification/international-trade.

To export organic product from Columbia, you will need to become a certified operation. There are five basic steps to organic certification:

  1. The farm or business adopts organic practices, USDA-accredited certifying agent, and submits an application and fees to the certifying agent.
  2. The certifying agent reviews the application to verify that practices comply with USDA organic regulations.
  3. An inspector conducts an on-site inspection of the applicant’s operation.
  4. The certifying agent reviews the application and the inspector’s report to determine if the applicant complies with the USDA organic regulations.
  5. The certifying agent issues organic certificate.

In addition to organic requirements, traded agricultural products must meet all general or commodity-specific import requirements. U.S. importers and customs services can provide detailed guidance on:

  • Labeling. Organic products sold in the U.S. must meet all Federal labeling requirements (general and organic).
  • Import Codes. For certain organic products, traders must use harmonized tariff schedule codes for tracking purposes: bit.ly/organic-codes2
  • Grading. Imported agricultural commodities must often meet product size, grade, quality, and maturity requirements: www.ams.usda.gov
  • Health Inspection. Shipments must include permits, sanitary certificates (animal products), and phytosanitary certificates (plant products) to ensure the product is healthy and free from pests requiring quarantine: www.aphis.usda.gov/aphis/ourfocus/importexport
  • Meat, Poultry, and Processed Egg Products. The USDA only allows imported meat, poultry, and processed egg products from countries with inspection standards equivalent to U.S. standards: bit.ly/imports-fsis
Mary Ann Klugh
Dec 14, 2019

Is pesticide licensing required for organic producers?

Ben Weaver
Dec 18, 2019

@Mary Ann Klugh - thank you for your comment. In general, synthetic substances are prohibited for organic crop and livestock production unless specifically allowed. Non-synthetic (natural) substances are allowed for organic crop and livestock production unless specifically prohibited. The National List of Allowed and Prohibited Substances identifies these exceptions. Exemptions are rare and there must be reasonable evidence and justification that the substance will still allow the organic product to conform to the organic principles in the Organic Food Production Act (OFPA).

Exemptions on the National List – including any allowed pesticides – are evaluated for their environmental and human health impacts and its necessity to be eligible for use in organic production. Based on criteria in OFPA, the NOSB makes a recommendation to the USDA on whether a pesticide should be allowed in organic production. The USDA may accept or reject the recommendation. If the USDA agrees with NOSB’s recommendation to add a synthetic substance to the National List, USDA will go through the public rulemaking process including providing an opportunity for public comment.

T P L Raj
Jan 25, 2020

I need to know the Limit of Quantification for testing of Diuron in Cinnamon Powder and other spices

Babu Sebastian
Feb 08, 2020

I would like to know whether ethanol (non-organic certified - but of natural origin)- can be used as an extraction solvent of organic spices? Basically as processing aids under 95% organic ingredient. The remaining residue of alcohol will be less than 0.1% in a B2B product.