National Organic Standards Board

Crops Subcommittee Petitioned Material Proposal

Paper based crop planting aids

January 21, 2020

Summary of Petition and Petition Addendum for Paper (Plant Pots and Containers)

The NOSB received a petition in August 2018 for the addition of paper planting pots to the National List: 

§205.601(o) production aids- Plant pot or growing container-hemp or other paper, without glossy or

colored inks.

This material has not been petitioned for inclusion on the National List in the past. However, paper 

chain pots have been historically allowed for the past 12 years by some organic certification agencies, 

under the allowance for “Newspaper or Other Recycled Paper as a mulch or compost feedstock”. 

In February 2018, the NOP notified all certifiers that paper chain pots are not allowed in organic 

systems. However, because some certifiers had previously approved their use, NOP allowed a phase-out 

period until the end of the 2018 crop season. The NOP’s decision on this material was based primarily 

on the presence of an unapproved synthetic adhesive in the product and that the current allowance for 

paper on the National List (i.e., as compost feedstock and mulch) does not extend to the use associated 

with paper pots. At the October 2018 and April 2019 NOSB meetings, there were numerous oral and 

written public comments requesting a longer time period allowing these paper pots while the NOSB 

reviewed the petition. The NOSB also formally requested this extension in November 2018. The NOP 

agreed to allow the use of paper pots in organic agriculture in late Fall 2018, with no time restriction, in 

order to give the NOSB time to go through the review process. 

Paper pots are used by small scale farming operations to efficiently transplant using a non-motorized 

machine transplanting system. More information on this transplanting method can be found on these 

websites: http://paper-pot.com/ and http://www.smallfarmworks.com/. This equipment, along with 

the paper pots, is imported from a manufacturer in Japan. According to the petition, the Nitten paper 

pot chain system uses paper, produced from a non-bleached Kraft pulp, and adhesives. Non-paper 

synthetic fibers have been used in small quantities (15%) in the paper pots, but the manufacturer has 

proposed that these fibers be replaced by a natural hemp fiber. The petitioner and public commenters

at the Spring and Fall 2018 NOSB meetings stated this system is unique and essential for smaller scale 

growers. The only alternative would be the much slower and more costly hand planting of individual 

plants. The system is used for closely spaced crops such as onions, beets, baby greens, etc. The petition 

states that, similar to newspaper, these pots decompose in the soil readily. At the time of this proposal, 

the first trial replacing the synthetic fibers with hemp fibers was not successful, and a second trial was in 

process. 

In addition to the petition, there are numerous other paper pot systems, both to be transplanted as 

single plants and in chains of pots. In addition to paper, these other paper pot systems have various 

percentages of non-paper synthetic fibers, which may or may not be biobased. Paper pots can also 

include other ingredients, such as cow manure, synthetic antimicrobials, fungicides and fertilizers. 

Public comment from another manufacturer based in Denmark, Ellepot, https://www.ellepot.com/, 

provided further information on non-chain paper pots for a variety of uses from fast maturing annuals 

to long term woody perennial crops. The percentage of cellulose based synthetic fibers in their paper 

pots can be 15-100%. Synthetic adhesives are also used in the Ellepots, but currently no other 

synthetics.

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The petition states that, in addition to information on paper, the TR on newspaper addresses the 

presence of adhesives and synthetic fibers in recycled newspaper as well. The three adhesives in the 

Nitten paper chain pots are vinyl-acetate resin (water soluble and stated to be leached from the pots 

before transplanting), ethylene-vinyl-acetate resin, and acrylic acid ester copolymer. 

It should be noted that paper itself is a synthetic fiber due to the manufacturing process. However, for 

the purposes of this discussion, a distinction is made between synthetic paper fibers and synthetic fibers 

that are not strictly paper. These non-paper synthetic fibers can be biobased and made from cellulose 

or they can be non-biobased and made from a number of other materials such as petroleum-based 

plastics. In general, many of the biobased, cellulose derived synthetic fibers used in paper pots are

expected to biodegrade whereas the same might not be true of other petroleum-based fibers. Thus, it is 

important to distinguish not only between synthetic paper fibers and other non-paper synthetic fibers 

but also between whether these non-paper fibers are biodegradable (as referenced to some recognized 

standard) or might persist in the soil.

The Crops Subcommittee views paper pots, used as a crop production aid, as another use of paper 

beyond compost feedstocks and mulch, which are allowed under the NOP regulation. However, in order 

to do due diligence, the Crops Subcommittee requested a Technical Review (TR) to help identify the 

adhesives and synthetic fibers used in paper pots and identify if there are any that would not be present 

in the already-allowed paper used in compost and mulch. Pots, compost, and mulch all degrade into the 

soil, and the Subcommittee believes if the fibers and adhesives are allowed in the other listings for 

paper, then their use in pots should be allowed as well.

The TR clarified that the adhesives and non-paper synthetic fibers found in a variety of paper pots are 

also found in newspaper and recycled paper that are allowed for compost feedstock and mulch. Other 

possible adhesives and synthetic fibers for paper pots that were not mentioned in the petition are 

described in the TR.

Summary of Public Comment

Many users of the paper pot chain system provided written and verbal comment to the NOSB at the Fall 

2018 and Spring 2019 meetings. They spoke in favor of its use due to its efficiency in transplanting at a 

small-scale level. Some certifiers spoke in favor of this material and noted that if the paper was torn off 

the pot before transplanting, it would then be allowed as a mulch or as a compost feedstock under our 

current regulation. Certifiers who had not allowed the use of these paper pots still supported the 

extended allowance for use while the NOSB performed its review. 

There is more than one supplier of paper pots beyond the one noted in the petition. Approval of this 

material will probably open the door for other manufacturers to produce these pots once there is clarity 

on what would be allowed under the organic regulations. Paper pots can be made with all-natural fibers 

or with a mixture of synthetic and natural fibers. The pots with more non-paper synthetic fiber content 

are more typically used in the nursery trade, where the perennial plants may be in the pots for 9-12 

months before transplanting into the field. Natural fiber pots can, at times, be sufficient for use in 

transplanting annual vegetable and flower plants, depending on the time frame between planting into 

the pot and planting out in the field, and if the pots need extra strength for a “chain of pots” planting 

system. All of the paper pots contain some type of synthetic adhesive, but these same adhesives are 

also found on recycled paper, which is already allowed in organic agriculture.

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Numerous commenters mentioned that all uses of paper as a production aid should be included when 

the NOSB does its review for paper pots. Cloches or hot caps, seed tape, and cutworm prevention 

collars are other examples of production aids made from paper and typical paper adhesives. 

There were also a number of comments about whether the listing for paper pots should be expanded to 

include paper as a production aid. Many commenters favored a listing that extended beyond only paper 

pots to include, but not be limited to, items such as seed tape, and other materials with direct soil 

contact. However, commenters also wanted to make sure that there was a differentiation between 

paper materials used with the intent of degrading in the soil versus paper materials that are intended to 

be removed after use. The Crops Subcommittee has narrowed the use from a “production aid” to a 

“planting aid” to limit the use of this paper to that time of the crop production, and to those aids that 

would decompose into the soil.

Specific Uses of the Substance:

These paper pots are either single or in chains to allow for “mechanical” transplanting, either with a 

hand driven machine or with a tractor implement. The paper pots decompose into the soil and lessen 

transplant shock since the roots are not exposed to the air before transplanting like plants being 

removed from plastic pots. The use of paper pots can contribute to less use of plastic in the produce 

industry. Growers can also use soil blocks, which are compressed soil without any container, to grow 

transplants.

Other paper crop production aids include: cloches, a temporary covering used to protect newly 

transplanted plants; seed tape, where individual seed is spaced correctly on a paper tape which lessens 

the need for thinning; and collars to prevent cutworm damage to plants at the soil line. There could be 

other uses of paper currently used as crop production aids, or there may be other uses developed over

time. The composition of the paper allowed in paper pots and other planting aids, as well as the 

adhesives approved, would meet the manufacturer needs of these other paper planting aids.

Approved Legal Uses of the Substance:

Newspaper and recycled paper are allowed under the organic regulations in these two references: 

Reference: 205.601(b) As herbicides, weed barriers, as applicable. (2) Mulches. (i) newspapers or other 

recycled paper, without glossy or colored inks. 

Reference: 205.601(c) - As compost feedstocks - Newspapers or other recycled paper, without glossy or 

colored inks. 

There have been three technical reports (TRs) for Newspaper, in 1995, 2006 and 2017, which can be 

found here: https://www.ams.usda.gov/rules-regulations/organic/national-list/n. 

NOP guidance 5034-1 “Materials for Organic Crop Production” from December 2016 excludes virgin 

paper from the “newspaper or other recycled paper” allowance for mulch or compost feed stocks. The 

guidance states: “Includes newspaper and other recycled paper such as cardboard, without glossy or 

colored inks. Does not include paper that is not recycled (i.e., virgin paper).”

The July 2019 Technical Review of Paper Pots and Containers, detailing the specific possible synthetic 

and natural fibers as well as synthetic adhesives found in paper pots currently commercially available, 

provided more clarity for the NOSB.

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Manufacture:

Paper can be made from various plant sources including wood, trees, straw, hemp, bamboo, reeds, 

kenaf, sisal, jute, sugarcane bagasse, sunflower stalks as well as recycled sources of pulp. Cellulose 

sources are typically mechanically ground, and then chemically “cooked” using an alkali or sulfite 

process. Newspaper and recycled papers can also have a variety of inks, although colored ink and glossy 

paper are not allowed as compost feedstocks or mulch under the organic rule. The paper used as a 

planting aid could include the typical adhesives found in newspaper and recycled paper.

Subcommittee Discussion:

The Crops Subcommittee has reviewed the petition, technical reviews, and public comments and has 

developed a listing and annotation that it believes meets the needs of producers, while addressing 

environmental concerns that might be associated with some types of paper. When discussing the 

possible allowance for paper used as a planting aid, the subcommittee also considered the fact that 

currently there is an allowance for “newspaper or other recycled paper” to biodegrade into soil, and 

there are very few differences between the currently allowed paper and the paper as a planting aid we 

were reviewing, except for the long term use paper pots that have a very high percentage of synthetic 

fibers.

Category 1: Classification 

1. For CROP use: Is the substance _____ Non-synthetic or __x__ Synthetic? 

Is the substance formulated or manufactured by a process that chemically changes a substance 

extracted from naturally occurring plant, animal, or mineral sources? [OFPA §6502(21)] If so, 

describe, using NOP 5033-1 as a guide.

Due to the paper pulping production process, and use of synthetic adhesives, this material is 

considered to be synthetic.

2. For CROPS: Reference to appropriate OFPA category:

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; toxins derived from 

bacteria; pheromones, soaps, horticultural oils, fish emulsions, treated seed, vitamins and 

minerals; livestock parasiticides and medicines and production aids including netting, tree wraps 

and seals, insect traps, sticky barriers, row covers, and equipment cleansers; or (ii) is used in 

production and contains synthetic inert ingredients that are not classified by the Administrator of 

the Environmental Protection Agency as inerts of toxicological concern?

This material is considered a crop planting aid, and is not a pesticide. Although some paper pots 

available on the market might have prohibited pesticides (insecticides, antimicrobials, fungicides 

etc.) embedded in the fiber, these would not be allowed in organic production, and it is not 

necessary to annotate paper to exclude these prohibited materials.

Category 2: Adverse Impacts 

1. What is the potential for the substance to have detrimental chemical interactions with other 

materials used in organic farming systems? [§6518(m)(1)]

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Most of the paper used as a crop planting aid is functionally identical to newspaper and recycled 

paper. The current listing of newspaper and recycled paper has been found to have no 

detrimental interactions with other materials in organic agriculture.

2. What is the toxicity and mode of action of the substance and of its breakdown products or any 

contaminants, and their persistence and areas of concentration in the environment? 

[§6518(m)(2)]

No toxicity or negative mode of action has been found in the breakdown of paper (cellulose) in 

the environment. No colored or glossy inks would be allowed for paper as a crop planting aid, 

to be in alignment with paper as it is currently annotated as a compost feedstock and/or mulch. 

The 2019 TR found many of the adhesives and synthetic fibers biodegraded with no negative 

impacts. There were some that were not as environmentally neutral as others, but all were also 

present in newspaper. The percentage of adhesives in the paper pots is very small. There could 

be an issue with paper used as a planting aid, containing large percentages of synthetic fibers 

that would not biodegrade readily.

3. Describe the probability of environmental contamination during manufacture, use, misuse or 

disposal of such substance? [§6518(m)(3)]

There could be contaminants released into the environment during the manufacture of paper, 

and environmental degradation caused by harvest of cellulose, but no more than newspaper or 

recycled paper, which historically have been approved for use in organic agriculture. A 

difference between this paper and the previously approved newspaper, is that we are not 

restricting it to the use of only recycled paper products. The annotation will allow virgin stocks 

of cellulose to be used in the paper used as a planting aid in organic agriculture. There are 

negative environmental impacts from harvesting trees to make paper such as road building, soil 

erosion degraded water quality and loss of habitat, but there are forestry best management 

practices that can mitigate some of these negative effects. The synthetic fibers that could be 

used in paper are manufactured in a wide range of production systems. These were not 

specifically addressed in the TR. 

4. Discuss the effect of the substance on human health. [§6517 (c)(1)(A)(i); §6517 (c)(2)(A)(i); 

§6518(m)(4)].

Paper, depending on the percentage and type of synthetics, is biodegradable and has no 

negative effects on human health. The 2019 TR did not indicate any evidence of harmful effects 

to human health.

5. Discuss any effects the substance may have on biological and chemical interactions in the 

agroecosystem, including the physiological effects of the substance on soil organisms 

(including the salt index and solubility of the soil), crops and livestock. [§6518(m)(5)] 

Paper, depending on the percentage and type of synthetics, is not harmful to the environment. 

The 2019 TR did not indicate any evidence of harmful effects to environmental health.

6. Are there any adverse impacts on biodiversity? (§205.200) 

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Paper planting aids with high percentages of synthetic fibers that do not biodegrade readily 

could leave residues that would be harmful to terrestrial, avian and aquatic wildlife if consumed. 

Use of synthetic pesticides embedded in the pots could also have adverse impacts on 

biodiversity, but only approved synthetics would be allowed in the paper used as a planting aid.

Category 3: Alternatives/Compatibility 

1. Are there alternatives to using the substance? Evaluate alternative practices as well as nonsynthetic and synthetic available materials. [§6518(m)(6)] 

There are biodegradable pots made from composted cow manure, https://cowpots.com/, but 

these have never been petitioned for use in organic agriculture. We do not know if they could be 

approved or not. The manufacturer states the pots contain post-consumer newsprint and are 

100% biodegradable. In addition, they state they are not approved for Certified Organic 

operations, as of January 2020. It is unclear if there are adhesives or synthetic fibers as well, and 

what they are. 

There are also tools to help growers roll up newspaper into a pot. The paper chain pots offer 

greater efficiency for small scale transplanting, although mechanical or hand transplanting 

operations can be used in both small- and large-scale operations with other types of pots or soil 

blocks.

2. In balancing the responses to the criteria above, is the substance compatible with a 

system of sustainable agriculture? [§6518(m)(7)]

The Crops Subcommittee has developed the definition and annotation described in the motion 

below to both meet the OFPA criteria and to provide a practical and achievable material for 

manufacturers to produce and for organic farmers to use. The material is a planting aid, to limit 

the use of this material to activities around planting of seeds or plants.

The annotation of no less than 85% biobased content meets the needs of current manufacturers, 

with the possibility of hemp or other fibers capable of providing the strength needed to meet this 

annotation. Continuing the prohibition on colored and glossy inks prevents the incorporation 

into organic soil of the worst contaminants. It is understood that there would be a small 

percentage of adhesives and coatings, and the Technical Reviews on paper and paper pots 

described how these are already allowed in paper as mulch or compost feedstocks.

The allowance for virgin paper allows for special papers to be developed that meet the specific 

crop planting needs for a variety of uses, and the amount of paper produced from virgin sources 

for these planting aids would be very small compared to the amount of paper manufactured for 

all uses. Added fungicides, antimicrobials, insecticides or other synthetic items not typically 

found in paper, would not be allowed under the current annotation. Genetically modified 

materials are prohibited under the organic regulation, and would not be allowed as ingredients in

paper-based crop planting aids. With the recommended annotation, paper-based crop planting

aids are compatible with a sustainable system of agriculture.

The Crops Subcommittee did not include a biodegradability standard in this proposal, due to the 

time and cost needed for testing to that standard. The Subcommittee encourages continued 

innovation to move to 100% biobased content as well as to make sure that these materials are 

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promptly and economically available to growers of all sizes. The Subcommittee also encourages 

testing and trials of increased natural and/or biobased synthetic content and believes that 

manufacturers would be less likely to provide products to organic farmers if this testing were 

required.

Classification Motion:

Motion to classify “paper-based crop planting aid” as synthetic. 

Motion by: Harriet Behar

Seconded by: Steve Ela

Yes: 6 No: 0 Abstain: 0 Absent: 1 Recuse: 0 

National List Motion: 

Motion to add to 205.2 Terms Defined: Paper-based crop planting aid. A material that is 

comprised primarily of cellulose-based paper, including pots, seed tape, and collars that are 

placed in or on the soil and are intended to degrade into the soil. Contains no less than 85% 

biobased content with biobased content determined using ASTM D6866 (incorporated by 

reference; see §205.3).

Add to 205.601 (o) Production Aids:

Paper-based crop planting aids as defined in 205.2. Virgin or recycled paper without colored or 

glossy inks. If these paper-based crop planting aids are commercially available with 100% 

biobased fiber content, these must be used.”

Motion by: Harriet Behar

Seconded by: Steve Ela

Yes: 6 No: 0 Abstain: 0 Absent: 1 Recuse: 0

Approved by Jesse Buie, Crop Subcommittee Chair, to transmit to NOP January 21, 2020

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