National Organic Standards Board

Crops Subcommittee

Petitioned Material Checklist - Soy Wax

January 19, 2016

Summary of Proposed Action:

Soy wax has been petitioned as a synthetic substance for use in organic mushroom production to seal plugs 

and ends of logs inoculated with mushroom spawn. Soy wax is intended to be used for the same purpose as 

microcrystalline cheesewax, which is currently listed at §205.601(o) as a production aid in the production of 

mushrooms grown on logs. 

Soy wax is produced from oil extracted from soybeans. The oil is hydrogenated, making it a solid at room 

temperature. Crystalline cheesewax, which is currently listed for the use, is made from petroleum. Soy wax, 

which is now available from non-GMO, domestically-produced soybeans, was petitioned for use because it 

has fewer environmental and health impacts than products made from petroleum.

Soy wax is considered synthetic because it undergoes a chemical change that does not happen naturally 

when it is hydrogenated. Hydrogenation is the process whereby the poly- and mono-unsaturated oils are 

solidified in order to increase the viscosity. As the petition describes it, this process involves the reaction of 

hydrogen with soybean oil at elevated temperature (140-225o

C) in the presence of a nickel catalyst. 

Therefore, even if soy wax were made from organic soybeans by this process, it would be synthetic.

The Crops Subcommittee supports the addition of soy wax made from non-GMO plant material to the 

National List as an alternative to microcrystalline cheesewax, which is made from petroleum.

Evaluation Criteria (see attached checklist for criteria in each category)

 Criteria Satisfied? 

1. Impact on Humans and Environment ☒ Yes ☐ No ☐ N/A 

2. Essential & Availability Criteria ☒ Yes ☐ No ☐ N/A

3. Compatibility & Consistency ☒ Yes ☐ No ☐ N/A 

Subcommittee Action & Vote: 

Classification Motion: Move to classify soy wax as synthetic. 

Motion by: Francis Thicke 

Seconded by: Colehour Bondera

Yes: 4 No: 0 Absent: 1 Abstain: 0 Recuse: 0 

Listing Motion: Move to list soy wax at §205.601 of the National List (o) - As production aids. Soy wax

(CAS # 8016-70-4) - for use in log grown mushroom production. Must be made from non-GMO 

soybeans. 

Motion by: Francis Thicke 

Seconded by: Colehour Bondera 

Yes: 4 No: 0 Abstain: 0 Absent: 1 Recuse: 0

 

 Proposed Annotation: Must be made from non-GMO soybean oil. 

 Basis for annotation: ☐ To meet criteria above ☒ Other regulatory criteria ☐ Citation 

NOSB APRIL 2016 PROPOSALS & DISCUSSION DOCUMENTS 297/302
Approved by Zea Sonnabend, Subcommittee Chair, to transmit to NOSB January 19, 2016

NOSB Evaluation Criteria for Substances Added To the National List - Crops

Category 1. Adverse impacts on humans or the environment? Soy Wax

Question Yes No N/A Comments/Documentation (TAP; petition; 

regulatory agency; other)

1. Is there a probability of environmental 

contamination during use or misuse? 

[§6518(m)(3)]

X 

2. Is there a probability of environmental 

contamination during, manufacture or 

disposal? [§6518(m)(3)]

X 

3. Are there any adverse impacts on 

biodiversity? (§205.200) X 

Soy wax (hydrogenated soy oil) is 

biodegradable and non-toxic

4. Does the substance contain inerts classified 

by EPA as ‘inerts of toxicological concern’? 

[§6517 (c)(1)(B)(ii)]

X 

5. Is there potential for detrimental chemical 

interaction with other materials used in 

organic farming systems? 

[§6518(m)(1)]

X 

6. Is there a toxic or other adverse action of the 

material or its breakdown products?

[§6518(m)(2)]

X 

Soy wax breaks down into carbon dioxide 

and water.

7. Is there persistence or concentration of the 

material or breakdown products in the 

environment? [§6518(m)(2)]

X 

Soy wax is hydrogenated soybean oil and

non-toxic and biodegradable in soil.

8. Would the use of the substance be harmful 

to human health or the environment? 

[§6517 (c)(1)(A)(i); §6517 (c)(2)(A)(i); 

§6518(m)(4)]

X 

Soy wax for mushroom production is not 

intended to be ingested, but would not be 

harmful it if were.

9. Are there adverse biological and chemical 

interactions in the agro-ecosystem? 

[§6518(m)(5)]

X 

10. Are there detrimental physiological effects 

on soil organisms, crops, or livestock? 

[§6518(m)(5)]

X 

NOSB APRIL 2016 PROPOSALS & DISCUSSION DOCUMENTS 298/302
NOSB Evaluation Criteria for Substances Added To the National List - Crops

Category 2. Is the Substance Essential for Organic Production? Soy Wax

Question Yes No N/A Comments/Documentation (TAP; petition; 

regulatory agency; other)

1. Is the substance agricultural? [§6502(1)]

X

2. Is the substance formulated or 

manufactured by a chemical process? 

[§6502(21)]

X 

Hydrogenation of soybean oil

3. Is the substance formulated or 

manufactured by a process that chemically 

changes a substance extracted from 

naturally occurring plant, animal, or mineral 

sources? 

[§6502(21)]

X 

The chemical change is hydrogenation, which 

alters carbon bonding with hydrogen. 

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

X 

5. Is there a natural source of the substance? 

[§ 205.600(b)(1)] X

6. Is there an organic substitute? 

[§205.600(b)(1)] X

Soy wax could be made with organic soybean 

oil, but would still be considered synthetic.

7. Is there a wholly natural substitute product?

[§6517(c)(1)(A)(ii)] X

8. Are there any alternative substances? 

[§6518(m)(6)] X

Microcrystalline cheesewax, which is 

currently on the National List.

9. Are there other practices that would make 

the substance unnecessary? [§6518(m)(6)] X 

The sealing of log ends and plug holes is 

considered necessary in mushroom 

production.

Category 3. Is the substance compatible with organic production practices? Soy Wax 

Question Yes No N/A Comments/Documentation (TAP; petition; 

regulatory agency; other)

1. Is the substance consistent with organic 

farming and handling? 

[§6517(c)(1)(A)(iii); 6517(c)(2)(A)(ii)]

X 

Soy wax is more consistent and compatible

with organic farming and sustainable 

agriculture than the petroleum-based 

microcrystalline cheesewax currently in use.

2. Is the substance compatible with a system of 

sustainable agriculture? [§6518(m)(7)] X

See #1 above.

3. If used in livestock feed or pet food, is the 

nutritional quality of the food maintained 

with the substance? [§205.600(b)(3)]

X 

4. If used in livestock feed or pet food, is the 

primary use as a preservative? 

[§205.600(b)(4)]

X 

NOSB APRIL 2016 PROPOSALS & DISCUSSION DOCUMENTS 299/302
5. If used in livestock feed or pet food, is the 

primary use to recreate or improve flavors, 

colors, textures, or nutritive value lost in 

processing (except when required by law)? 

[§205.600(b)(4)]

X 

6. Is the substance used in production, and 

does it contain an active synthetic ingredient 

in the following categories:

[§6517(c)(1)(B)(i);

copper and sulfur compounds

X 

toxins derived from bacteria X

pheromones, soaps, horticultural oils, 

fish emulsions, treated seed, vitamins 

and minerals

X 

livestock parasiticides and medicines

X

production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleansers

X 

NOSB APRIL 2016 PROPOSALS & DISCUSSION DOCUMENTS 300/302