U.S. organic standards are ostensibly 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 United States Department of Agriculture (USDA) oversees the National Organic Program (NOP). 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**.
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 (which the FDA recently reported contains high levels of lead). This substance lightens (or leavens) the dough for organic pancakes, baked goods, and other products.
Non-Organic substances allowed in Food and Products Labeled as “ORGANIC”
§ 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”
The following nonagricultural (Non-organic) substances may be used as ingredients in or on processed products labeled as “organic” or “made with organic (specified ingredients or food group(s))” only in accordance with any restrictions specified in this section.
(a) Nonsynthetics allowed:
Acids (Citric – produced by microbial fermentation of carbohydrate substances; and Lactic).
Animal enzymes – (Rennet – animals derived; Catalase – bovine liver; Animal lipase; Pancreatin; Pepsin; and Trypsin).
Attapulgite – as a processing aid in the handling of plant and animal oils.
Calcium sulfate – mined.
Diatomaceous earth – food filtering aid only.
Enzymes – must be derived from edible, nontoxic plants, nonpathogenic fungi, or nonpathogenic bacteria.
Flavors – nonsynthetic flavors may be used when organic flavors are not commercially available. All flavors must be derived from organic or nonsynthetic sources only and must not be produced using synthetic solvents and carrier systems or any artificial preservative.
Gellan gum (CAS # 71010-52-1) – high-acyl form only.
Glucono delta-lactone – production by the oxidation of D-glucose with bromine water is prohibited.
L-Malic acid (CAS # 97-67-6).
Magnesium sulfate, nonsynthetic sources only.
Microorganisms – any food grade bacteria, fungi, and other microorganism.
Nitrogen – oil-free grades.
Oxygen – oil-free grades.
Perlite – for use only as a filter aid in food processing.
Pullulan – for use only in tablets and capsules for dietary supplements labeled “made with organic (specified ingredients or food group(s)).
Tartaric acid – made from grape wine.
Waxes – nonsynthetic (Wood resin).
Yeast – When used as food or a fermentation agent in products labeled as “organic,” yeast must be organic if its end use is for human consumption; nonorganic yeast may be used when organic yeast is not commercially available. Growth on petrochemical substrate and sulfite waste liquor is prohibited. For smoked yeast, nonsynthetic smoke flavoring process must be documented.
(b) Synthetics allowed:
Acidified sodium chlorite – Secondary direct antimicrobial food treatment and indirect food contact surface sanitizing. Acidified with citric acid only.
Activated charcoal (CAS #s 7440-44-0; 64365-11-3) – only from vegetative sources; for use only as a filtering aid.
Ammonium bicarbonate – for use only as a leavening agent.
Ammonium carbonate – for use only as a leavening agent.
Calcium phosphates (monobasic, dibasic, and tribasic).
Cellulose (CAS #9004-34-6) – for use in regenerative casings, powdered cellulose as an anti-caking agent (non-chlorine bleached) and filtering aid. Microcrystalline cellulose is prohibited.
Chlorine materials – disinfecting and sanitizing food contact surfaces, equipment and facilities may be used up to maximum labeled rates. Chlorine materials in water used in direct crop or food contact are permitted at levels approved by the FDA or EPA for such purpose, provided the use is followed by a rinse with potable water at or below the maximum residual disinfectant limit for the chlorine material under the Safe Drinking Water Act. Chlorine in water used as an ingredient in organic food handling must not exceed the maximum residual disinfectant limit for the chlorine material under the Safe Drinking Water Act.
i. Calcium hypochlorite.
ii. Chlorine dioxide.
iii. Hypochlorous acid – generated from electrolyzed water.
iv. Sodium hypochlorite.
Collagen gel – as casing, may be used only when organic collagen gel is not commercially available.
Ethylene – allowed for postharvest ripening of tropical fruit and degreening of citrus.
Ferrous sulfate – for iron enrichment or fortification of foods when required by regulation or recommended (independent organization).
Glycerides (mono and di) – for use only in drum drying of food.
Magnesium stearate – for use only in agricultural products labeled “made with organic (specified ingredients or food group(s)),” prohibited in agricultural products labeled “organic”.
Nutrient vitamins and minerals, in accordance with 21 CFR 104.20, Nutritional Quality Guidelines For Foods.
Peracetic acid/Peroxyacetic acid (CAS # 79-21-0) – for use in wash and/or rinse water according to FDA limitations. For use as a sanitizer on food contact surfaces.
Phosphoric acid – cleaning of food-contact surfaces and equipment only.
Potassium hydroxide – prohibited for use in lye peeling of fruits and vegetables except when used for peeling peaches.
Potassium lactate – for use as an antimicrobial agent and pH regulator only.
Potassium phosphate – for use only in agricultural products labeled “made with organic (specific ingredients or food group(s)),” prohibited in agricultural products labeled “organic”.
Silicon dioxide – Permitted as a defoamer. Allowed for other uses when organic rice hulls are not commercially available.
Sodium acid pyrophosphate (CAS # 7758-16-9) – for use only as a leavening agent.
Sodium hydroxide – prohibited for use in lye peeling of fruits and vegetables.
Sodium lactate – for use as an antimicrobial agent and pH regulator only.
Sodium phosphates – for use only in dairy foods.
Sulfur dioxide – for use only in wine labeled “made with organic grapes,” Provided, That, total sulfite concentration does not exceed 100 ppm.
Tocopherols – derived from vegetable oil when rosemary extracts are not a suitable alternative.
Source: National List of Allowed and Prohibited Substances
For more information see items from
The National List of Allowed and Prohibited Substances
Table of Contents:
*The NOSB is made up of public volunteers appointed by the Secretary of Agriculture, board members include organic growers, handlers, retailers, environmentalists, scientists, USDA-accredited certifying agents and consumer advocates.
**In theory, 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:
- An individual or organization submits a formal petition to add, remove, or change the listing for a specific substance.
- 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.
- 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.
- 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.
- The NOP reviews the NOSB’s recommendation. The NOP can reject the NOSB’s recommendation to add a substance to the National List, but cannot add a substance that has not been recommended by the NOSB.
- 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 discusses 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.