National Organic Standards Board 

Crops Subcommittee Petitioned Material Proposal 

Paper Based Crop Planting Aids 

July 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 the use of virgin paper. 

Further, the current allowance for paper on the National List 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 use of 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 of this material. 

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 these fibers are 

proposed to be replaced by a natural hemp fiber. The petitioner and public comment 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 salad, 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 paper pots indicated in the petition, there are numerous other paper pot systems, 

both to be used to transplant single plants as well as in chains. 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 20-100%. Synthetic adhesives are currently the only synthetic 

material used in the Ellepots other than the paper itself. 

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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 has viewed 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 Technical Review 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 through Spring 2020 public 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 supplier noted in the petition. Approval of this 

material will 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 higher non-paper, synthetic fiber contents are 

more typically used in the nursery trade where 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 from planting into the pot to planting 

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 additional distinct uses of 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 being used that are later incorporated into 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 period of the crop 

production, and to those aids that would be incorporated 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 have 

developed a listing and annotation that we believe 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” as weed control or as compost 

feed stocks and there are very few differences between the currently allowed paper and the paper as a 

planting aid under review, with the exception of paper pots that have a very high percentage of noncellulose synthetic fibers. Requiring 60% cellulose fiber prevents the planting aids from being 

completely made of biobased, non-degradable plastics and yet allows current products on the market. 

It is hoped that this percentage can increase over time. Requiring 80% biobased content prevents the 

use of planting aids made primarily from petroleum sources and also allows the products currently on 

the market. Again, it is hoped that this percentage can be increased over time and that future Boards 

will be able to modify this annotation to reflect manufacturing technological advances that incorporate 

more natural materials and additional cellulose and biobased content. Small changes have been made 

to the annotation to reflect concerns from stakeholders. There is concern that the annotation 

specifically notes that allowed paper planting aids are not limited to those listed and that the materials 

will be incorporated into the soil (without reference of intent to biodegrade). Finally, as pointed out in 

public comment, the wording that allows the use of newspaper “without colored or glossy inks” was 

intended to prevent use of glossy paper and colored inks and the wording for paper planting aids is 

changed to prevent the use of glossy paper or colored inks. 

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?

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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. In order to be 

explicit, the annotation states that any added nutrients or pesticides must conform to the 

National List or be allowed under OFPA. 

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)]

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 inks or glossy paper would be allowed for paper as a crop planting 

aid, similar to 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)].

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Paper, depending on the percentage of cellulose and type of synthetic fibers/materials used, is 

biodegradable and has no negative effects on human health. The 2019 TR did not find 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 of cellulose and type of synthetic fibers/materials used, is

not harmful to the environment. The 2019 TR did not find any evidence of harmful effects to

environmental health.

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

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 organically allowable pesticides or nutrients 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 and the

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

The annotation of no less than 60% cellulose-based fiber content meets the needs of current

manufacturers with the possibility that hemp or other natural cellulose fibers, capable of

providing the strength needed to meet this annotation, could be used in the future. The 80%

biobased requirement ensures that materials beyond the cellulose base are derived from

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biological sources. Both the 60% cellulosed based fiber content and 80% biobased content 

requirements could be made more stringent by future Boards through an annotation change. As 

the technology of these planting aids advances it’s possible manufacturers will be able to use 

more natural and biobased materials to strengthen the planting aids. Continuing the prohibition 

on glossy paper and colored 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 unless they were on the 

National List for that purpose or otherwise compliant with the OFPA. 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 would like to see 

continued innovation to move to 100% biobased as well as an increase in the natural fiber 

content of these planting aids. Additionally, the Subcommittee wants to make sure that these 

materials are promptly and economically available to growers of all sizes. The Subcommittee 

would like to encourage testing and trials of increased natural and/or biobased contents and 

believe that manufacturers would be less likely to provide small innovations of these new 

products to organic farmers if this testing were required. 

Classification Motion: 

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

Motion by: Steve Ela 

Seconded by: Asa Bradman 

Yes: 7 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 of at least 60% cellulose-based fiber 

by weight, including, but not limited to, pots, seed tape, and collars that are placed in or on the 

soil and later incorporated into the soil. Contains no less than 80% biobased content as verified 

by a qualified third party assessment (e.g. laboratory test using ASTM D6866 or composition 

review by qualified personnel). 

Motion by: Steve Ela 

Seconded by: Jerry D’Amore 

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

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Add to 205.601 (o) Production Aids: 

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

or colored inks. Added pesticides or nutrients must comply with §205.105, 205.203, and 

205.206. 

Motion by: Steve Ela 

Seconded by: Rick Greenwood 

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

Approved by Jesse Buie, Crop Subcommittee Chair, to transmit to NOP July 28, 2020 

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