Formal Recommendation 

From: National Organic Standards Board (NOSB) 

To: the National Organic Program (NOP)

Date: 

Subject: 

Chair: 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: 

Guidance Statement: 

Other: 

Statement of Recommendation:;DŽƚŝŽŶηϭͿ

 

Rationale Supporting Recommendation (including consistency with OFPA and NOP):

 

Committee Vote:

 

Moved: 

SecondĞĚ: 

Yes:EŽ͗ďƐƚĂŝŶ͗ďƐĞŶƚ͗ZĞĐƵƐĞ͗

 

 

 3DJHUHYLVHGPD

October 18, 2012

Petition to list Biodegradable biobased mulch films on §205.601(b)(2)

Barry Flamm

Petition Passed

Motion to classify Biodegradable biobased mulch film as synthetic.

 

 

✔

Passed

While the building blocks of the polymers that make the mulch films are often starches and other 

non-synthetic components, there are some synthetic additives to help the films hold together and 

add pigment. 

Carmela Beck

Jay Feldman

15 0 0 0 0
Rationale Supporting Recommendation (including consistency with OFPA and NOP):

Statement of Recommendation:;DŽƚŝŽŶηϮͿ

Committee Vote:

 

Moved: 

SecondĞĚ: 

Yes:EŽ͗ďƐƚĂŝŶ͗ďƐĞŶƚ͗ZĞĐƵƐĞ͗

 

 

 

 

3DJHUHYLVHGPD

Passed

Petition to list Biodegradable biobased mulch films on §205.601(b)(2) Mulches:

See attached Statement of Recommendation (Motion # 2) for further detail

 

The NOSB sees the approval of these materials as an opportunity to reduce pollution substantially 

without sacrificing organic farming principles. The first several criteria apply to those certifiers and 

Material Review Organizations (MROs) that will determine allowed products. The last clause is the 

only one that refers to a grower's responsibility and correspondingly what the certifier must 

evaluate. The annotation has been crafted to be as specific as possible to ensure that only acceptable 

products are reviewed and allowed for organic farming. 

Rationale behind the annotation and some accompanying issues are attached.

Zea Sonnabend

Harold Austin

12 3 0 0 0
Statement of Recommendation (Motion #2) 

Petition to list Biodegradable biobased mulch films on §205.601(b)(2) Mulches: 

(iii) Biodegradable biobased mulch films to be reviewed meet the following criteria: 

(A) Completely biodegradable as shown by: 

1) meeting the requirements of ASTM Standard D6400 or D6868 specifications, or of other 

international standard specifications with essentially identical criteria, i.e. EN 13432, EN 14995, 

ISO 17088; and 

2) Showing at least 90% biodegradation in soil absolute or relative to microcrystalline cellulose 

in less than two years, in soil, tested according to ISO 17556 or ASTM 5988; 

(B) Must be biobased with content determined using the ASTM D6866 method; 

(C) Must be produced without organisms or feedstock derived from excluded methods; and 

(D) Grower must take appropriate actions to ensure complete degradation. 

In addition, add the following definition to 205.2 

Biobased: organic material in which carbon is derived from a renewable resource via biological 

processes. Biobased materials include all plant and animal mass derived from carbon dioxide 

recently fixed via photosynthesis, per definition of a renewable resource (ASTM). 

Rationale Supporting Recommendation (including consistency with OFPA and NOP) 

The NOSB sees the approval of these materials as an opportunity to reduce pollution substantially 

without sacrificing organic farming principles. The first several criteria apply to those certifiers and 

Material Review Organizations (MROs) that will determine allowed products. The last clause is the 

only one that refers to a grower’s responsibility and correspondingly what the certifier must 

evaluate. The annotation has been crafted to be as specific as possible to ensure that only 

acceptable products are reviewed and allowed for organic farming. 

Rationale behind the annotation and some accompanying issues: 

Introductory Text 

The term “Biodegradable biobased mulch film” reflects the Board’s intention to define bio-based so 

that this category would not allow products, for example those made from aliphatic aromatic 

copolymers (AACs), which come from petroleum. The definition of biobased is provided in addition 

to the annotation to make this as clear as possible. 

The Board chose to not use the word “bioplastic” because OFPA and the NOP rule encourage 

biodegradable mulches and have clauses that prohibit plastic that is not removed at the end of the 

season. The NOSB adopts the interpretation that these mulches biodegrade and the process of 

biodegradation is equivalent to removal of the substance at the end of the growing season. 
“(A) Completely biodegradable as shown by..... “ 

The standards referred to here will cover the range of products in a range of temperatures and 

environments. The Board understands that the ASTM 6400 will involve testing for any residues and 

ecotoxic effects. 

“(B) Must be biobased with content.....“ 

The Board has also provided a good definition of ‘biobased material’ to ensure that this testing 

protocol is meaningful. 

“(C) Must be produced without organisms or feedstock derived from excluded methods.” 

While the NOSB has some concerns about consistency between this and excluded methods in other 

soil inputs, since this will be a brand new category of materials to the Board intends to shut the 

door to GMOs at the outset. The annotation regarding GMO feedstock is not to be construed as 

carrying over to other soil applied materials. 

“(D) Grower must take appropriate actions to ensure complete degradation.” 

It is expected that NOP, in conjunction with the NOSB, will develop guidance that explains proper 

practices for utilizing the biodegradable mulch film. In addition, it is expected that the inspection 

process and certification review will determine that biodegradation of the mulch film is occurring so 

that it does not accumulate in the fields where it is used. 

It is the Board’s belief, in submitting this recommendation, that biodegradable mulch film made 

with nanomaterials is prohibited under the listing on the National List. While the NOSB established 

a working definition of nanomaterials in 2010, the clause in the Crops Subcommittee proposal 

prohibiting nanomaterials was removed due to the current lack of an officially-recognized definition 

of nanomaterials. 

The Board continues to support the prohibition of nanomaterials as defined in 2010: 

Engineered nanomaterials: substances deliberately designed, engineered and produced by 

human activity to be in the nanoscale range (approx. 1-300 nm) because of very specific 

properties or compositions (e.g., shape, surface properties, or chemistry) that result only in that 

nanoscale. Incidental particles in the nanoscale range created during traditional food processing 

such as homogenization, milling, churning, and freezing, and naturally occurring particles in the 

nanoscale range are not intended to be included in this definition. All nanomaterials (without 

exception) containing capping reagents or other synthetic components are intended to be 

included in this definition. 

In a December 17, 2010 Memorandum to the NOSB, the NOP responded as follows: 

The NOP understands that the NOSB considers nanomaterials to be synthetic and prohibited 

under the National Organic Program..... The NOP accepts the NOSB recommendation and 

intends to gather additional information about how nanomaterials are regulated and used in 

agricultural production and handling. 
The Board would like the proposed guidance regarding appropriate grower actions to be added to 

the Crops Subcommittee workplan. Additionally, the Board would like unanswered questions, 

especially those concerning possible long-term impacts of biodegradable mulch film on soil 

health, to be added to the Materials Subcommittee research priorities for the coming year as a high 

priority topic, in order to provide more complete data for the sunset decision. 

Some members of the Board who did not support the final annotation noted a concern that 

explicit language requiring removal (or in this case complete degradation) of plastic or synthetic 

mulch at the end of each harvest or growing season was removed from the Crops 

Subcommittee proposal. Additionally, some Board members felt that the Board should retain 

the listing as originally petitioned, “Biodegradable Mulch Film Made from Bioplastics”, due to 

the nature of the material under review and the testimony of the petitioner and others on the 

definition of plastic (albeit biodegradable). 

Committee Vote: 

Moved: Zea Sonnabend 

Seconded: Harold Austin 

Yes: 12 No: 3 Abstain: 0 Absent: 0 Recuse: 0 
National Organic Standards Board

Crops Subcommittee

Petitioned Material Proposal

Biodegradable Mulch Film Made from Bioplastics

August 15, 2012

Introduction

A petition was submitted requesting the addition of biodegradable biobased bioplastic 

mulch to section 205.601(h) of the National List. This petition involves definitions of new 

substances, which the subcommittee recommends be incorporated into the listing. The 

subcommittee explicitly seeks public comment on the definitions and possible 

restrictions on use.

Background

Biodegradable mulch film made from bioplastics is petitioned to section 205.601 of the 

National List for use in organic crop production. This is an alternative to petroleumbased plastic mulches that do not completely biodegrade. Over the past 50 years much

research and development has gone into developing biodegradable mulches which are 

the subject of this petition. As product development has been underway, removal and 

disposal of polyethylene plastic mulches has become increasingly difficult because its 

removal is time-consuming, delays cover cropping and must largely be sent to landfills. 

The OFPA requires the removal of plastic mulches at the end of the growing or harvest 

season (7 U.S.C. 6508).

The petitioner argues that OFPA’s mention of plastic was not intended to refer to 

biodegradable mulch film. Biodegradable mulch is intended to biodegrade by the end of 

the season or prior to the beginning of the following season. This distinction leads us to 

question whether the approval of the petition would require a rule change to allow the 

mulch to biodegrade in the field or whether the two substances should be treated as 

separate and distinct. However, bioplastics are defined in terms of “plastics,” according 

to the petitioner, “Biodegradable Plastic Mulch is defined as plastic mulching material 

that meets both of the following requirements.” Furthermore, bioplastics fit the definition 

of plastic, “Any of various organic compounds produced by polymerization, capable of 

being molded, extruded, cast into various shapes and films, or drawn into filaments 

used as textile fibers.” (American Heritage Dictionary) The petition defines 

biodegradable mulch film as mulching materials that:

1) meet the requirements of ASTM International (formerly American Society for 

Texting and Materials) Standard D6400 or D6868 specifications, or of other 

international standard specifications with essentially identical criteria, i.e. EN 

13432, EN 14995, ISO 17088; and

2) show at least 90% biodegradation absolute or relative to microcrystalline 

cellulose2 in less than two years, in soil, tested according to ISO 17556 or 

ASTM 5988.
Additionally, the petitioner suggests that the reference to “fully biodegradable” in section 

205.206(c)(1) be defined when referencing bioplastic degradation in soil. Full 

biodegradation is covered under several standards which discuss the compostability of 

the petitioned product. These include, American Society for Testing and Materials 

(ASTM) Standard D5988 (biodegradability of bioplastic in soil), ASTM Standard D6400 

(biodegradability of bioplastic in compost), and ASTM Standard D6868 (biodegradability 

of bioplastic specifications). The ASTM definition of “biodegradable plastic” is, “a 

degradable plastic in which the degradation results from the action of naturally occurring 

microorganisms such as bacteria, fungi, and algae.”

The petition further clarifies, that according to the European Bioplastics’ definition, 

bioplastics are biobased, biodegradable, or both. The ASTM definition of “biobased 

material” is “organic material in which carbon is derived from a renewable resource via 

biological processes. Biobased materials include all plant and animal mass derived from 

carbon dioxide recently fixed via photosynthesis, per definition of a renewable 

resource.” Biobased materials are certified using the ASTM D6866 method, which 

certifies the biologically derived content of bioplastics. 

The petition provides the following description: biodegradable films are produced from 

bioplastics that meet standards for aerobic biodegradation in soil. These bioplastics are 

comprised of structural units which may be easily broken down into carbon substrates 

by soil microorganisms. Under aerobic conditions, these microorganisms are able to 

utilize the carbon substrates as a food source. This metabolism of the carbon substrates 

ultimately results in two simple compounds – carbon dioxide and water.

Relevant areas in the Rule

OFPA §6508 (c) says

For a farm to be certified under this chapter, producers on such farm shall not - 

...(2) use plastic mulches, unless such mulches are removed at the end of each growing 

or harvest season; 

The regulations provide at §205.206(c) that 

Weed problems may be controlled through: 

... (6) Plastic or other synthetic mulches: Provided, That, they are removed from the field 

at the end of the growing or harvest season. 

And the National List includes at §205.601(b)(2) 

Mulches. 

...(ii) Plastic mulch and covers (petroleum-based other than polyvinyl chloride (PVC)). 

Discussion 

Neither conventional plastic mulch nor biodegradable bioplastic mulch can perform all of 

the functions—particularly, feeding the soil—that organic mulches perform. However, 

there are times—such as when cold soil is a problem—when the qualities of plastic or 

bioplastic have been viewed as necessary. As always, it is our understanding that the 
use of synthetic mulch products will be limited to those circumstances when natural 

organic mulches are inappropriate or impossible to use. When this is the case, it makes 

sense to use a material that degrades in place rather than one that is removed and 

taken to a landfill. On the other hand, the subcommittee believes that it may be difficult 

to separate claims from truth concerning biodegradability and the source of the material. 

In addition, the subcommittee would like to make a robust recommendation that 

correctly describes biodegradable biobased bioplastic mulches that meet the three 

criteria above. According to the European Bioplastics definition, bioplastics are 

biobased, biodegradable, or both. The committee intends this recommendation to cover 

those bioplastics that are both biobased and biodegradable.

The subcommittee understands the importance of a definition, which it is proposing, and 

is particularly interested in public comment on the biobased classification and the ASTM 

standard. Meeting this standard, however, does not automatically ensure that the mulch 

will be “removed from the field at the end of each growing or harvest season.” This 

removal may require steps like tilling the film into the ground. The subcommittee 

therefore proposes the annotation that growers take appropriate actions to guarantee

that the mulch decomposes within the appropriate time frame.

Evaluation Criteria 

(Applicability noted for each category; Documentation attached) Criteria Satisfied? 

(see “B” below)

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 

4. Commercial Supply is Fragile or Potentially Unavailable ܆ Yes ܆ No 

܈ N/A 

as Organic (only for § 205.606)

Substance Fails Criteria Category: [ ] Comments:

Proposed Annotation:

List on §205.601(b)(2) Mulches: (iii) Biodegradable biobased bioplastic mulch meeting 

the following criteria: (A) Completely biodegradable as shown by: 1) meeting the 

requirements of ASTM Standard D6400 or D6868 specifications, or of other 

international standard specifications with essentially identical criteria, i.e. EN 13432, EN 

14995, ISO 17088; and 2) showing at least 90% biodegradation absolute or relative to 

microcrystalline cellulose in less than two years, in soil, tested according to ISO 17556 

or ASTM 5988; (B) Biobased certified using the ASTM D6866 method; (C) Must be 

produced without excluded methods; (D) Must be produced without engineered 

nanomaterials; and (E) Grower must take appropriate actions to ensure complete 

degradation at the end of each growing or harvest season.
Basis for annotation: ܈ To meet criteria above ܈ Other regulatory criteria ܆

Citation 

Notes: Annotation is necessary to meet the requirements of OFPA §6508(c).

Recommended Subcommittee Action & Vote, including classification 

recommendation (state actual motion):

Classification Motion:

Biodegradable Mulch Film Made from Bioplastics is synthetic.

Motion by: Colehour Bondera Seconded by: Jay Feldman

Yes__8___ No__0__ Abstain__0__ Recuse__0__ Absent__0__ 

Listing Motion: 

To list on §205.601(b)(2) Mulches: (iii) Biodegradable biobased bioplastic mulch 

meeting the following criteria: (A) Completely biodegradable as shown by: 1) 

meeting the requirements of ASTM Standard D6400 or D6868 specifications, or of 

other international standard specifications with essentially identical criteria, i.e. EN 

13432, EN 14995, ISO 17088; and 2) showing at least 90% biodegradation absolute 

or relative to microcrystalline cellulose in less than two years, in soil, tested 

according to ISO 17556 or ASTM 5988; (B) Biobased certified using the ASTM 

D6866 method; (C) Must be produced without excluded methods; (D) Must be 

produced without engineered nanomaterials; and (E) Grower must take appropriate 

actions to ensure complete degradation at the end of each growing or harvest 

season.

Motion by: Colehour Bondera Seconded by: Barry Flamm

Yes__7___ No__0__ Abstain__1__ Recuse__0__ Absent__0__

܆ 1Allowed ܆ Agricultural ܈ Crops

Livestock ܆ Non-synthetic ܆ Prohibited2 ܆

܆ 3Rejected ܈ Synthetic ܆ Handling

No restriction ܆ Commercial unavailable as 

organic

܆ 4Deferred ܆

1

Substance voted to be added as “allowed” on National List to § 20 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. Describe why 

material was rejected: 

4

Substance was recommended to be deferred because 

If follow-up needed, who will follow up: 

Approved by Subcommittee Chair to Transmit to NOSB

Jay Feldman, Subcommittee Chair August 15, 2012

NOSB Evaluation Criteria for Substances Added To the National List

Category 1. Adverse impacts on humans or the environment? Substance: Biodegradable

 Mulch Film Made from Bioplastics 

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 TER 525-531: The production of PLA & 

PHA involves fermentation processes & 

feedstocks derived from natural sources 

(with the exception of geneticallymodified organisms). The potential for 

environmental contamination from these 

products is limited, with the exception of 

the metal salt catalysts used to 

polymerize PLA (Bastioli, 2005). No 

reports of tin contamination from 

production of bioplastics were found.

2. Is there environmental contamination 

during manufacture, use, misuse, or 

disposal? [§6518 m.3]

x TER 533-537: Many of the feedstocks 

used in the production of AAC could be 

hazardous if they were spilled or 

discharged into the environment during 

manufacture & processing. No specific 

reports of environmental contamination 

from these compounds as a result of 

manufacturing bioplastics were found. 

Systematic reviews of the environmental 

impact from manufacturing of bioplastics 

were not found. TER 547-550:

Erucamide, glycerol, and stearic acid 

amide could be released to the 

environment through multiple 

manufacturing processes, including 

bioplastics production. No research 

reports were found that described 

environmental releases of these 
chemicals from bioplastics 

manufacturing.

3. Is the substance harmful to the 

environment and biodiversity?

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

x TER 614-621: The researchers 

concluded that using PE mulch may have 

a harmful effect on the environment due 

to increased runoff & is less sustainable 

than vegetative mulch (Rice et al., 2001). 

Based on their similarities in construction 

& intended use, bioplastic mulches would 

likely have similar environmental impacts 

to PE mulch, though their greater 

tendency to degrade sooner than PE 

mulch may decrease some of the 

adverse environmental impacts. TER 

623-627: Anaerobic degradation of 

bioplastics may produce methane 

(greenhouse gas). Research was not 

found that quantified methane emissions 

from bioplastic mulch use. Degradation of 

bioplastic mulches must take place in an 

aerobic environment in the soil to prevent 

methane emissions. TER 629-630:

Adverse environmental impacts from the 

use of bioplastic mulches are only likely 

to occur if the material does not 

completely biodegrade in soil. TER 652-

657: Some reports have shown that 

bioplastics containing terephthalic acid at 

concentrations over 50% do not 

completely biodegrade in soil (Bastioli, 

2005). 

4. Does the substance contain List 1, 2 or 3 

inerts? [§6517 c (1)(B)(ii); 205.601(m)2]

x

5. Is there potential for detrimental chemical 

interaction with other materials used?

[§6518 m.1]

x TER 566-567: The plastics are inert in 

the soil when they are intact, and are 

biodegraded by soil microorganisms.

6. Are there adverse biological and 

chemical interactions in agro-ecosystem? 

[§6518 m.5]

x TER 582-587: Given the complete 

aerobic biodegradation of bioplastic 

mulches, the by-products are carbon 

dioxide, water, & soil biomass. Soil 

biomass refers to the total amount of 

microorganisms in the soil, excluding 

plant roots & macrofauna (NRCS, 2012). 

The increase in biomass may cause a 

concomitant increase in the populations 

of microorganisms that degrade the 

mulches on a local basis. This could lead 

to changes in the population dynamics of 

microorganisms in the soil. TER 593-595:

Complete degradation of the bioplastics 
depends on blending the polymers to 

maximize degradability & depends on the 

composition of soil microorganisms. 

7. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518 m.5]

x TER 352-354 ASTM standard D5988 is 

designed to be applicable to bioplastic 

materials that are “not inhibitory to the 

bacteria & fungi present in the soil”...it 

could be assumed that the bioplastic 

does not inhibit soil bacteria or fungi by 

its breakdown processes. TER 357-358:

Many bacteria & fungi in the soil can use 

bioplastics derived from starch as a 

carbon source (Shah et al., 2008). TER 

409-410: Biochar, a method of generating 

carbon black for soil amendment, may 

help promote nutrient use efficiency in 

treated soils (Chan, 2008; Hunt, 2010).

8. Is there a toxic or other adverse action of 

the material or its breakdown products?

[§6518 m.2]

x TER 446-447: Studies were not found 

that specifically assessed the ecotoxicity 

of bioplastics following degradation in the 

soil, & a better understanding of 

bioplastic degradation & soil 

environmental effects is needed. TER 

462-466: It seems unlikely that the 

source material (the bioplastic film) would 

interact with other organisms & cause

toxicity. The material is manufactured to 

remain intact & inert during its intended 

use, then (ideally) break down at the end 

of the season.

9. Is there undesirable persistence or 

concentration of the material or 

breakdown products in environment? 

[§6518 m.2]

x x TER 330-333: The petitioner states that 

biodegradable mulch film is defined in 

two ways...Second, by “show[ing] at least 

90% biodegradation absolute or relative 

to microcrystalline cellulose in less than 

two years, in soil, tested according to ISO 

17556 or ASTM 5988.” TER 347-350:

ISO 17556 & ASTM 5988 are equivalent 

standards. They “describe the standard 

test method for determining aerobic 

biodegradation of plastic materials in 

soil.” This standard is most applicable to 

the proposed use of the bioplastic mulch 

because the mulches will be left in the 

field at the end of the season to 

biodegrade according to their petitioned 

use. TER 356-357: Biodegradability is 

quantified by measuring the amount of 

carbon dioxide released from the soil 

over time. TER 362-370: degradation 

occurs quicker when chiseled or tilled into 
the soil during times of warm 

temperatures & moisture in soils with 

high organic matter. TER 374-375:

Hydrolysis breaks PLA into lactic acid & 

water-soluble compounds. Once this 

breakdown occurs, PLA is completely 

mineralized to CO2, water, & biomass. 

TER 384-386: Degradation of PHA 

occurs by enzymatic hydrolysis at the 

surface of the film, which is carried out by 

soil microbial populations. Hydrolysis 

breaks the PHA polymers into oligomers 

& monomers which are subsequently 

consumed & assimilated by microbes in 

the soil as nutrients. TER 395-399: All of 

the commercially available AAC polymer 

materials contain terephthalic acid, which 

is most responsible for determining the 

degradation rates in AAC plastics. As the 

fraction of terephthalic acid increases, the 

degradation rate decreases. No 

significant biological degradation was 

found when the molar fraction of AAC 

was increased to more than 60%, which 

is thought to be due to the relatively low 

melting point of terephthalic acid (Bastioli, 

2005). TER 405-410: Carbon black is 

elemental carbon in the form of a 

particulate that is manufactured from 

burning or partial combustion of 

hydrocarbons (NLM, 2011)...it is resistant

to breakdown in the soil environment. 

TER 412-419: Titanium dioxide is found 

as the minerals rutile, octahedrite, 

brookite, ilmenite, & perovskite. Titanium 

dioxide may persist in soil as the byproduct of titanium tetrachloride 

hydrolysis (ATSDR, 1997), so it may 

persist from use in bioplastic mulch as 

well. Titanium dioxide may settle out into 

sediments & persist for long periods of 

time (ATSDR, 1997). The compound is 

characterized by ATSDR as “ a very inert 

compound” (ATSDR, 1997). TER 421-

425: Erucamide (plasticizer) binds 

strongly to soil & sediments in water & is 

likely to bioconcentrate in aquatic 

organisms, meaning it will occur at higher 

levels up the food chain (NLM, 2011). 

The physical properties of erucamide 

suggest that the material will persist in 
the environment, and would be found in 

the water, soil & air if released (NLM, 

2011). TER 427-431: Glycerol 

(plasticizer) released to the environment 

will be present as both a vapor & a 

particle in the atmosphere, but will be 

degraded within hours (NLM, 2011). The 

potential for bioconcentration in aquatic 

organisms is low for glycerol in aquatic 

environments (NLM, 2011).

10. Is there any harmful effect on human 

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

§6518 m.4]

x TER 663-673: Pesticide runoff may be 

increased if plastic mulches are used in 

agricultural production due to the creation 

of impervious surfaces (Rice et al., 2001). 

The increase in pesticide loads may lead 

to an overall increase in the pesticide 

load in waterways which could potentially

impact human health by causing 

increases in pesticide loads in 

downstream drinking water sources. No 

other reports of impacts on human health 

from the use of bioplastic mulches were 

found in the published literature.

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

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.
NOSB Evaluation Criteria for Substances Added To the National List

Category 2. Is the Substance Essential for Organic Production? Substance: 

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 TER 294-296: Bioplastic mulches are 

manufactured with the addition of 

synthetic plasticizers and colorants which 

are added using a synthetic process. 

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 TER 301-302: To develop PLA the lactic 

acid monomers must be polymerized. 

This is accomplished through the use of a 

chemical catalyst. TER 302-305:

Fermentation is a naturally occurring 

process, but under laboratory conditions, 

the feedstocks and environmental 

conditions are manipulated in order to 

provide an environment that is most 

conducive to production of PLA, a 

process which would be unlikely to occur 

in nature. TER 309-310: Researchers 

have developed genetically-engineered 

bacterial strains that produce PHA more 

efficiently & in differing polymer amounts. 

TER 313-315: PHA production by 

fermentation is a natural process, but the 

conditions used in laboratories to 

maximize yields and polymer amounts 

are not naturally occurring. TER 317-319:

Some feedstocks used to produce AAC 

are naturally occurring, but the chemical 

processes used to refine them for use do 

not occur in nature, nor do the synthetic 

processes that are used to create the 

ester linkages.

3. Is the substance created by naturally 

occurring biological processes? [6502 

(21)]

x x

4. Is there a natural source of the 

substance? [§205.600 b.1]

x

5. Is there an organic substitute? [§205.600 

b.1]

x

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 TER 679-682: The petitioned substance 

would be an alternative to synthetic, nondegradable substance, polyethylene 

plastic mulch. Bioplastic mulch is 
produced through synthetic processes as 

previously described, but is created to be 

biodegradable, a reason for its petitioned 

use in organic agriculture. TER 684-690:

Mulches made from biomass include 

bark, cocoa-bean hulls, corncobs, grass 

clippings, leaves, pine needles, sawdust, 

straw, & wood chips. Biomass mulch 

availability may depend on what types of 

plants or crops are available in the area & 

the type of crop they are used in.

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 TER 717-721: Living mulch involves 

planting a low-growing cover crop that is 

effective at competing with weed species. 

The drawback is that living mulches 

compete for nutrients & water & reduce 

yields. Reports discuss the need to strike 

a balance between environmental impact, 

cost, ease of use, & crop yields to 

determine which alternative is most 

beneficial for individual farms & crops.

10. Is there another practice that would make 

the substance unnecessary? [§6518 m.6]

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.
NOSB Evaluation Criteria for Substances Added To the National List

Category 3. Is the substance compatible with organic production practices? Substance: 

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 x The substance is of synthetic origin but 

appears to completely biodegrade in a 

two-year timeframe. This serves as an 

alternative to the current practice of using 

synthetic, non-degradable, polyethylene 

plastic mulch.

3. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518 m.7]

x

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 TER 218- 221: Bioplastic mulch is used 

as a production aid, but is not technically 

considered a row cover because they 

increase soil temperature, reduce weed 

pressure, maintain soil moisture levels, 

and may help extend the growing season.

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.
NOSB Evaluation Criteria for Substances Added To the National List

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: Name

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

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 

x
barriers, or civil unrest that may 

temporarily restrict supplies; or

e. Are there other issues which may 

present a challenge to a consistent 

supply?

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.