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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
Jul 28, 2022

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.

NOTE: Reshared from the archives, still true today.

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.

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.

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?

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.

Bryan
Feb 24, 2020

Is Indole-3-butyric acid allowed for organic plants? I can't find that, root, hormone, IBA, or the likes in the "allowed and prohibited substances" lists in the CFR.

Ben Weaver
Mar 02, 2020

@Bryan - thank you for your comment. Thank you for contacting the USDA National Organic Program (NOP) with your question about Indole-3-butyric acid.

If you are a farm or business certified to the USDA organic regulations, your accredited certifier is the best resource for addressing your question. Please reach out to them.

For uncertified farms/businesses

Materials used in organic crop production and processing must comply with the USDA organic regulations.

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 – i.e. synthetic substances that may be used and the nonsynthetic (natural) substances that may not be used in organic crop and livestock production – and how/when each specific substance can be used. 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).

To determine if a specific product is allowed for use in your product, we recommend you contact one of the following:

You may also find the following resources useful regarding material compliance under the USDA organic regulations:

Any individual or organization may submit a petition to add, remove, or amend the listing of a substance on the National List: How to File a Petition.

I hope you find these resources helpful. Please do not hesitate to contact your certifying agent or a consultant if you need additional information.

Ivan
Mar 02, 2020

Hi!
I would like to know if zinc foliar fertilizer is considered organic?
Thank you!

Ben Weaver
Mar 06, 2020

@Ivan - thank you for your comment. If you have a farm or business certified to the USDA organic regulations, your accredited certifier is the best resource for addressing this question. Please reach out to your certifier.

For uncertified farms/businesses

Materials used in organic crop production and processing must comply with the USDA organic regulations.

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 – i.e. synthetic substances that may be used and the nonsynthetic (natural) substances that may not be used in organic crop and livestock production – and how/when each specific substance can be used. 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).

To determine if a specific product is allowed for use in a product, we recommend you contact one of the following:

You may also find the following resources useful regarding material compliance under the USDA organic regulations:

I hope you find these resources helpful. Please do not hesitate to contact a certifying agent or a consultant if you need additional information.

Manoshi T S
Apr 16, 2020

I would like to know if vinegar is allowed as per NOP USDA Regulations?(below 5%)

Samantha P.
May 20, 2020

Hi there! I recently found out I am allergic to Propylene Glycol and Formaldehyde. Does that mean I can buy food products that have the USDA Organic Seal as Propylene Glycol is considered a synthetic solvent but can be used in other ways as well.

Thanks,
Sam

Ramanathan Santhanagopalan
Jun 11, 2020

Dear Madam/Sir, I am looking for NOP list of approved insecticides we can use in bakery to treat flour beetles. Would you please reply?

Robin Rowan
Jul 23, 2020

Why is food grade 35% H2O2 not allowed in minute quantities as input in a preservative knowing it will breakdown into water and oxygen before it reaches the farm

Christine McKenna
Oct 26, 2020

I am trying to ascertain what IS allowed to be used in the production of organic agricultural products. It appeared to me that this link National List of Allowed and Prohibited Substances
in the article above should answer my question. But following the link left me at a dead end. I could see no way to get precisely the information that is seemingly promised by the wording. Please help me. I want to know what pesticide and herbicide residues exist in organic foods. I would also like to know what fertilizers are used. They may be "all natural" but so is hemlock and I am not predisposed to use that!
Thanks

Ben Weaver
Oct 27, 2020

@Christine McKenna - thank you for your comment. The correct link has been updated.

Darran Gould
Nov 23, 2020

Could Propylene Glycol be allowed as an inert ingredient (wetting agent) in a pesticide, as per 205.601(m)? It is on list 4B of the EPA : "Other ingredients for which EPA has sufficient information to reasonably conclude that the current use pattern in pesticide products will not adversely affect the public health or the environment". See NOP Guidance 5008
I know it is not allowed in processed food & for livestock, but it seems it could be allowed as above.
Thanks.

Ben Weaver
Dec 07, 2020

@Darran Gould - thank you for your comment. Certifiers are responsible for making sure USDA-certified organic farms and businesses and their certified organic products comply with the organic regulations. We recommend that you work with an accredited certifier to determine what products can be used in your certified operation.

Materials used in organic production, processing and handling must comply with the USDA organic regulations. In general, synthetic substances are prohibited unless specifically allowed, and non-synthetic (natural) substances are allowed unless specifically prohibited. The National List of Allowed and Prohibited Substances identifies any exceptions – i.e. synthetic substances that may be used and the nonsynthetic (natural) substances that may not be used in organic crop and livestock production – and how/when each specific substance can be used. 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).

Natalie Bramlett
Dec 05, 2020

Is the pesticide chlorpyrifos allowed in organic farming?

Ben Weaver
Dec 07, 2020

@Natalie Bramlett - thank you for your comment. Materials used in organic production, processing and handling must comply with the USDA organic regulations.

In general, synthetic substances are prohibited unless specifically allowed, and non-synthetic (natural) substances are allowed unless specifically prohibited. The National List of Allowed and Prohibited Substances identifies any exceptions – i.e. synthetic substances that may be used and the nonsynthetic (natural) substances that may not be used in organic crop and livestock production – and how/when each specific substance can be used. 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).

To determine if a specific product is allowed for use, we recommend you contact one of the following:

Joe Woloszyn
Feb 23, 2021

Are oxygen scavenger packets composed of activated iron powder and diatomaceous earth acceptable for use with organic products?

Ann
Oct 19, 2021

Is there any organic standard recommended fumigants for organic products ,other than carbon dioxide fumigant. Expecting a quick response from your end. Thanking you .

Irene
Jan 20, 2022

Does the USDA ORGANIC seal mean there is no glyphosate in the product?

I've seen a GLYPHOSATE RESIDUE FREE seal on some products.

I wonder if the USDA ORGANIC seal and the GLYPHOSATE RESIDUE FREE seal are the same as far as prohibiting glyphosate.

Ben Weaver
Jan 25, 2022

@Irene - thank you for your comment. Glyphosate is never allowed for use in organic production. Organic operations must produce and handle organic crops without the use of synthetic substances (with the noted exceptions of synthetic substances allowed for organic crop production on the National List of Allowed and Prohibited Substances), and organic crops must not be produced on land to which prohibited substances have been applied during the three years immediately preceding the harvest of agricultural crops.

For additional information, access the fact sheet on Substances Allowed in Organic Production (PDF, 5 MB).

Jo
Apr 17, 2022

Is ethylene oxide use (it’s often used as a fumigant/pesticide/sterilization) allowed under organic standards for organic certification?

Ben Weaver
Apr 18, 2022

@Jo - thank you for your question about ethylene oxide. The USDA organic regulations specify requirements for handling organic products. The National List of Allowed and Prohibited Substances (National List) identifies nonagricultural and nonorganic agricultural substances (ingredients) that may be used in organic handling. The National List also identifies the synthetic substances allowed in organic farming and the natural substances prohibited in organic farming. Some substances on the National List may only be used in specific situations, e.g. only for certain crops or up to a maximum amount.

Ethylene oxide is allowed for use in organic agriculture, with restrictions. If you are a farm or business certified to the USDA organic regulations, please contact your USDA-accredited certifier or a materials review organization, for specific information on the substances allowed or prohibited in organic handling.