Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

 

Date: October 28, 2010 

Subject: Tall Oil 

Chair: Daniel G. Giacomini 

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action 

Guidance Statement 

Other Not to list Tall oil (CAS# 8002-26-4) on the National List §205.601.

 

 

Statement of the Recommendation (Including Recount of Vote): 

 

The recommendation is to list Tall Oil (CAS# 8002-26-4) on the National List 205.601 FAILED 

by a vote of 14 no to 0 yes. Tall Oil was classified as synthetic by a vote of 14 yes, and 0 no. 

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

 

 Substance fails criteria categories 1,2, and 3. Even though Tall Oil is being petitioned as an 

inert, it also has insecticidal properties and so fails the environmental impact criteria. There are 

alternatives, therefore it fails the essentiality criteria, and because of its insecticidal properties, 

it fails is not compatible or consistent with organic or sustainable agriculture. Please see the 

Crops Committee recommendation, attached. 

 

NOSB Vote: The motion before the board was to consider Tall oil (CAS# 8002-26-4) 

synthetic. 

Moved: Tina Ellor Second: Jeff Moyer 

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recusal: 0 

NOSB Vote: The motion before the board was to list Tall Oil (CAS# 8002-26-4) on the 

National List §205.601. 

Moved: Tina Ellor Second: Jeff Moyer 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recusal: 0 
Decision Sheets 

December 2006 

NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: October 2010 Substance: Tall Oil CAS# 8002-26-4 

Committee: Crops X Livestock  Handling  Petition is for: Distillated Tall Oil to be included on the National List § 205.601

A. Evaluation Criteria (Applicability noted for each category; Documentation attached) Criteria Satisfied? (see B below) 

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

2. Essential & Availability Criteria Yes  No X N/A 

3. Compatibility & Consistency Yes No X N/A 

4. Commercial Supply is Fragile or Potentially Unavailable as Organic (only for 606) Yes  No  N/A X 

B. Substance Fails Criteria Category: 1, 2, and 3; Comments: Even though Tall Oil is being petitioned as an inert, it also has insecticidal 

properties so the committee felt that it failed the environmental impact category. There are alternatives; therefore the committee does not 

feel it was essential, and the committee determined that it is not compatible or consistent with organic or sustainable agriculture. 

C. Proposed Annotation (if any): _____________________________________________________________________________ 

 Basis for annotation: To meet criteria above: _______ Other regulatory criteria: _______ Citation:______________________ 

D. Recommended Committee Action & Vote, including classification recommendation (State Actual Motion): 

__Tall Oil be classified as synthetic for crop production_______

Classification of the material: Synthetic ____6____ Non- synthetic_____0______ Absent:____1___ Abstain __0__ 

Motion by: Keven Englebert; Seconded: Tina Ellor 

Recommended Committee Action & Vote (State Actual Motion): To add Tall oil to the national list § 205.601 as a synthetic for use in 

crop production. 

Motion by: Kevin Englebert; Seconded: Jeff Moyer Yes: 0; No: 6; Absent: 1; Abstain: 0; 

 

 

1) Substance voted to be added as “allowed” on National List to § 205. with Annotation (if any) ______________________ 

________________________________________________________________________________________________________ 

2) Substance to be added as “prohibited” on National List to § 205. with Annotation (if any) _________________________ 

________________________________________________________________________________________________________ 

Describe why a prohibited substance:__________________________________________________________________________ 

________________________________________________________________________________________________________ 

 

3) Substance was rejected by vote for amending National List to § 205.601_ Describe why material was rejected:__Substance has

insecticidal properties despite being petitioned as an inert. The CC felt that it failed categories 1, 2, and 3: adverse environmental impacts, 

non-essential, and inconsistent with organic and sustainable agriculture. 

4) Substance was recommended to be deferred because ___________________________________________________________ 

If follow-up needed, who will follow up ____________________________________________________________ 

Crops X Agricultural Allowed1

 

Livestock Non-Synthetic Prohibited2 

Handling Synthetic X Rejected3 X 

No restriction Commercially UnAvailable as Organic1

 Deferred4 

E. Approved by Committee Chair to transmit to NOSB: 

Tina Ellor September 9, 2010 

Committee Chair Date
Decision Sheets 

December 2006 

NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Substance – Tall Oil 

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Are there adverse effects on 

environment from manufacture, 

use, or disposal? [§205.600 b.2] 

 X TR lines 194-208—environmental contamination 

associated with the Kraft papermaking process. 

2. Is there environmental 

contamination during 

manufacture, use, misuse, or 

disposal? [§6518 m.3] 

X TR lines 194-208—environmental contamination 

associated with the Kraft papermaking process. 

3. Is the substance harmful to the 

environment and biodiversity? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X X No: TR lines 220-250—low concern for potential risk 

Yes: TR lines 157-167 and 331-341. Tall oil has 

insecticidal properties. 

4. Does the substance contain 

List 1, 2, or 3 inerts? 

[§6517 c (1)(B)(ii); 205.601(m)2] 

X It was (is?) on the EPA List 3 Inert Substances of 

Unknown Toxicity 

5. Is there potential for 

detrimental chemical interaction 

with other materials used? 

[§6518 m.1] 

 X TR lines 256-278 

6. Are there adverse biological 

and chemical interactions in agroecosystem? [§6518 m.5] 

X X No: TR lines 283-341 

Yes: TR lines 157-167 and 331-341. Tall oil has 

insecticidal properties. Insecticidal activity cause 

unintentional adverse biological interactions. 

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5] 

X X No: TR lines 346-412 

Yes: TR lines 157-167 and 331-341. Tall oil has 

insecticidal properties. The insecticidal properties 

may be detrimental to soil organisms, especially 

insects. 

8. Is there a toxic or other 

adverse action of the material or 

its breakdown products? 

[§6518 m.2] 

X TR lines 417-431—Tall oil rosin may cause dermal 

sensitivity 

9. Is there undesirable 

persistence or concentration of 

the material or breakdown 

products in environment?[§6518 

m.2] 

 X TR lines 436-457 

10. Is there any harmful effect on 

human health? [§6517 c (1)(A)(i); 

6517 c(2)(A)i; §6518 m.4] 

 X TR lines 462-481 

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3] 

 X 

12. Is the substance GRAS when 

used according to FDA’s good 

manufacturing practices? 

[§205.600 b.5] 

 X Tall oil is GRAS as an indirect food additive 

(Handbook of Preservatives by Ash and Ash, 

Synapse Information Resources 2004, page 555) 

and http://edocket.access.gpo.gov/ 

cfr_2008/aprqtr/21cfr186.1557.htm 

13. Does the substance contain 

residues of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5] 

 X 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable. 
Decision Sheets 

December 2006 

Category 2. Is the Substance Essential for Organic Production? Substance – Tall Oil 

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Is the substance formulated 

or manufactured by a chemical 

process? [6502 (21)] 

X TR lines 129-146 

2. 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 TR lines 172-181 

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)] 

 X TR lines 186-189. It is an extract of trees, which are 

natural products, but it is not clear whether tall oil 

would exist in nature without the pulping and 

extraction process. 

4. Is there a natural source of 

the substance? [§205.600 b.1] 

 X TR 186-189—Tall oil products are materials 

extracted from wood pulp, especially pine tree 

wood, which is a renewable natural resource. 

During the process of pulping coniferous trees to 

make paper, sodium salts of chemicals (tall oil 

soaps) occurring naturally in the trees are produced 

as a co-product. When acidulated, this soap 

becomes Crude Tall Oil ( US EPA, 2009). 

5. Is there an organic 

substitute? [§205.600 b.1] 

 X Vegetable oil TR line 500. 

6. Is the substance essential for 

handling of organically 

produced agricultural products? 

[§205.600 b.6] 

 X 

7. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)] 

X TR lines 486-491—animal tallow, terpene extracts 

from soft woods 

8. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)] 

 X 

9. Is there any alternative 

substances? [§6518 m.6] 

 X TR lines 496-501, 486-491. Vegetable oils, white 

mineral oils 

10. Is there another practice 

that would make the substance 

unnecessary? [§6518 m.6] 

X TR lines 506-511 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable. 
Decision Sheets 

December 2006 

Category 3. Is the substance compatible with organic production practices? Substance – Tall Oil 

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Is the substance compatible 

with organic handling? 

[§205.600 b.2] 

 X 

2. Is the substance consistent 

with organic farming and 

handling? [§6517 c (1)(A)(iii); 

6517 c (2)(A)(ii)] 

 X TR lines 157-167 and 331-341. Tall oil has 

insecticidal properties although it is being petitioned 

as an inert. Because of it’s unintentional effects on 

non-target insects and therefore biodiversity, the 

CC felt that it is incompatible with organic farming. 

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7] 

 X TR lines 157-167 and 331-341. Tall oil has 

insecticidal properties although it is being petitioned 

as an inert. Because of it’s unintentional effects on 

non-target insects and therefore biodiversity, the 

CC felt that it is incompatible with sustainable 

agriculture. 

4. Is the nutritional quality of the 

food maintained with the 

substance? [§205.600 b.3] 

 X 

5. Is the primary use as a 

preservative? [§205.600 b.4] 

 X 

6. Is the primary use to recreate 

or improve flavors, colors, 

textures, or nutritive values lost 

in processing (except when 

required by law, e.g., vitamin D 

in milk)? [205.600 b.4] 

 X 

7. Is the substance used in 

production, and does it contain 

an active synthetic ingredient in 

the following categories: 

a. copper and sulfur 

compounds; 

 X 

b. toxins derived from bacteria; X 

c. pheromones, soaps, 

horticultural oils, fish emulsions, 

treated seed, vitamins and 

minerals? 

 X 

d. livestock parasiticides and 

medicines? 

 X 

e. production aids including 

netting, tree wraps and seals, 

insect traps, sticky barriers, row 

covers, and equipment 

cleaners? 

 X 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable. 
Decision Sheets 

December 2006 

Category 4. Is the commercial supply of an agricultural substance as organic, fragile or potentially 

unavailable? [§6610, 6518, 6519, 205.2, 205.105 (d), 205.600 (c) 205.2, 205.105 (d), 205.600 (c)] 

Substance – Tall Oil 

Question Yes No N/A Comments on Information Provided 

(sufficient, plausible, reasonable, 

thorough, complete, unknown) 

1. Is the comparative description provided as 

to why the non-organic form of the material 

/substance is necessary for use in organic 

handling? 

 X 

2. Does the current and historical industry 

information, research, or evidence provided 

explain how or why the material /substance 

cannot be obtained organically in the 

appropriate form to fulfill an essential function 

in a system of organic handling? 

 X 

3. Does the current and historical industry 

information, research, or evidence provided 

explain how or why the material /substance 

cannot be obtained organically in the 

appropriate quality to fulfill an essential 

function in a system of organic handling? 

 X 

4. Does the current and historical industry 

information, research, or evidence provided 

explain how or why the material /substance 

cannot be obtained organically in the 

appropriate quantity to fulfill an essential 

function in a system of organic handling? 

 X 

5. Does the industry information provided on 

material / substance non-availability as 

organic, include ( but not limited to) the 

following: 

a. Regions of production (including factors 

such as climate and number of regions); 

 X 

b. Number of suppliers and amount produced; X 

c. Current and historical supplies related to 

weather events such as hurricanes, floods, 

and droughts that may temporarily halt 

production or destroy crops or supplies; 

 X 

d. Trade-related issues such as evidence of 

hoarding, war, trade barriers, or civil unrest 

that may temporarily restrict supplies; or 

 X 

e. Are there other issues which may present a 

challenge to a consistent supply? 

 X