Formal Recommendation 

From: National Organic Standards Board (NOSB)

To: the National Organic Program (NOP)

Date: April 27, 2016

Subject: Addition of squid byproducts at 205.601(j)(7)

NOSB Chair: Tracy Favre

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: X

Guidance Statement:

Other:

Statement of the Recommendation: 

Shoreside Organics, LLC submitted a petition in April 2015 to add “squid and squid byproducts” to the 

National List of Allowed and Prohibited Substances at section 205.601(j)(7) for use as a fertilizer. The 

petitioner wanted acid-adjusted squid products to be categorized as fish products for use in organic 

production. Squid byproducts make up 52% of the total body weight and include the squid ink, pen, skin, 

milt, liver and viscera and are typically discarded as waste. In general, squid byproducts are chopped, 

heated, digested with natural enzymes and stabilized with an acid such as phosphoric, sulfuric or citric 

acid to prevent microbial growth. 

Squid are commercially harvested primarily for calamari. Fishermen target spawning squid because they 

die shortly after reproduction. There are several squid fisheries throughout the world. There are two 

main squid fisheries in the US including along the Atlantic coast for long-finned squid and along the 

Pacific coast for market squid. The US Pacific squid fishery is managed by the California Department of 

Fish and Game, the National Oceanographic and Atmospheric Administration (NOAA) Fisheries, and the 

Pacific Fishery Management Council. Atlantic squid are managed in federal waters by NOAA Fisheries in 

conjunction with the Mid-Atlantic Fishery Management Council. Management includes seasonal catch 

limits, timed fishery closures, administration of permit issuance and limitations on using lights to attract 

squid to ensure uninterrupted spawning. Sustainable harvesting practices should be monitored in order 

to prevent ocean degradation and overharvesting.

The reason the squid byproducts need to be added to the National List is that they are stabilized with 

acid to lower the pH. The Subcommittee proposal listing motion only intended to allow squid from the

processing waste stream; the proposal was not intended to allow the use of whole squid in the 

manufacture of fertilizers.

Rationale Supporting Recommendation: 

The addition of squid byproducts is consistent with the National List listing for liquid fish products that 

are pH adjusted with synthetic sulfuric, citric or phosphoric acid (7 CFR 205.601(j)(7)). Only squid 
byproducts originating from the food processing waste stream are acceptable for use in organic 

agriculture. Whole squid caught for fertilizer purposes would not be included in this listing.

NOSB Vote: 

Classification Motion: Move to classify squid and squid byproducts (pH adjusted with synthetic 

acids) as synthetic.

Motion by: Carmela Beck 

Seconded by: Zea Sonnabend

Yes: 15 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Listing Motion: Motion to amend the listing motion to strike the words “squid and”.

Motion by: Carmela Beck 

Seconded by: Zea Sonnabend

Yes: 15 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Listing Motion: Move to list squid byproducts at § 205.601(j) with the annotation – can be pH 

adjusted with sulfuric, citric or phosphoric acid. The amount of acid used shall not exceed the 

minimum needed to lower the pH to 3.5.

Motion by: Carmela Beck 

Seconded by: Zea Sonnabend

Yes: 11 No: 4 Abstain: 0 Absent: 0 Recuse: 0

Motion Passed
National Organic Standards Board

Crops Subcommittee

Petitioned Material Proposal - Squid & Squid Byproducts

March 1, 2016

Introduction

Shoreside Organics, LLC submitted a petition in April, 2015 to add “Squid and Squid Byproducts” to the 

National List of Allowed and Prohibited Substances section 205.601(j)(7) for use as a fertilizer.

205.601 Synthetic substances allowed for use in organic crop production. ...the following synthetic 

substances may be used in organic crop production: Provided, that, use of such substances do not 

contribute to contamination of crops, soil or water... (j) As plant or soil amendments. (7) Liquid fish 

products – can be pH adjusted with sulfuric, citric or phosphoric acid. The amount of acid used shall 

not exceed the minimum needed to lower the pH to 3.5.

The petitioner would like acid-adjusted squid products to be categorized as fish products for use in organic 

production. 

Background 

The use of squid and squid byproducts for use in agriculture date back to the 1800’s when much of the 

product was shipped from CA market squid fisheries to Asian countries for consumption and fertilizer 

applications. Squid byproducts make up 52% of the total body weight and include the squid ink, pen, skin, 

milt, liver and viscera and are typically discarded as waste. There are several uses for these byproducts 

including food, medicinal and soil amendment uses. Squid and squid byproducts are the starting ingredients 

in the production of enzymatically produced hydrolysates with N-P-K values ranging from 2-2-2 to 3.3-7.3-2 

or more. Seafood derived hydrolysates, including squid and squid byproducts, have been used both as foliar 

sprays and soil amendments for propagating cranberries, cherries and apples. In general, squid byproducts 

are chopped, heated, digested with natural enzymes and stabilized with an acid such as phosphoric, sulfuric 

or citric acid to prevent microbial growth.

Squid are commercially harvested using nets directly above spawning grounds during mating season 

primarily for calamari. Fisherman target spawning squid because they die shortly after reproduction. There 

are several squid fisheries throughout the world. There are two main squid fisheries in the US including 

along the Atlantic coast for long finned squid and along the Pacific coast for market squid. The US Pacific 

squid fishery is managed by the CA Department of Fish and Game, the National Oceanographic and 

Atmospheric Administration (NOAA) Fisheries, and the Pacific Fishery Management Council. Atlantic squid 

are managed in federal waters by NOAA Fisheries in conjunction with the Mid-Atlantic Fishery Management 

Council. Management includes seasonal catch limits, timed fishery closures, administration of permit 

issuance and limitations on using lights to attract squid to ensure uninterrupted spawning. 

Discussion

Squid are littoral invertebrates classified into the phylum Mollusca, class Cephalopoda and order Loligo 

(later renamed Doryteuthis). There are an estimated 300 squid species known throughout the world. 

Common to the northeastern Atlantic coast is the longfin squid, species Doryteuthis (Loligo) pealli. Common 

to the US west coast is the market squid, species Doryteuthis (Loligo) opalescens. 

Per the TR, squid differ anatomically and phylogenetically from fish. The US Food and Drug Administration 

(FDA) defines “fish” to mean fresh or saltwater finfish, crustaceans, other forms of aquatic animal life 

(including, but not limited to, alligator, frog, aquatic turtle, jellyfish, sea cucumber, and sea urchin and the 
roe of such animals) other than birds or mammals, and all mollusks, where such animal life is intended for 

human consumption. The term “fishery products” means any human food product in which fish is a 

characterizing ingredient. Molluscan shellfish means any edible species of fresh or frozen oysters, clams, 

mussels, or scallops, or edible portions of such species, except when the product consists entirely of the 

shucked adductor muscle. This definition is not inclusive of squid, despite its classification as a mollusk. 

Scientifically, squids are cephalopod mollusks; however, for legal purposes and because they are part of a 

defined fishery, squid can be included “as other forms of aquatic life” per the FDA fish definition. Squid and 

squid byproduct hydrolysate have potential uses as food products.

The Canadian Organic Standard allows for the use of fish products; in Canadian fisheries, the definition of 

fish includes marine invertebrates such as squid. The EU Organic Standard allows the use of molluscan 

(squid) products from sustainable fisheries and may be used in organic production of feeds for nonherbivores; squid products are not explicitly authorized for use in organic production. The Japanese Organic 

Standard permits the use of food industry byproducts of fish origin if they are derived from natural sources; 

mollusks (squid) are included in Japanese fisheries. IFOAM permits the use of fish and shell products and 

food processing of animal origin. 

The Subcommittee recommends amending the current listing to read: Liquid fish and squid products – can 

be pH adjusted with sulfuric, citric or phosphoric acid. The amount of acid used shall not exceed the 

minimum needed to lower the pH to 3.5.

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

 Criteria Satisfied? 

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

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

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

Subcommittee Action & Vote 

Classification Motion: Move to classify Squid & Squid Byproducts as synthetic. 

Motion by: Carmela Beck 

Seconded by: Zea Sonnabend

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

Listing Motion: Move to list Squid & Squid Byproducts at §205.601(j) of the National List – with the 

annotation – can be pH adjusted with sulfuric, citric or phosphoric acid. The amount of acid used shall 

not exceed the minimum needed to lower the pH to 3.5. 

Motion by: Carmela Beck 

Seconded by: Zea Sonnabend

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

 

Approved by Zea Sonnabend, Subcommittee Chair, to transmit to NOSB March 1, 2016
NOSB Evaluation Criteria for Substances Added To the National List - Crops

Category 1. Adverse impacts on humans or the environment? Squid & Squid Byproducts

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

regulatory agency; other)

1. Is there a probability of environmental 

contamination during use or misuse? 

[§6518(m)(3)]

X TR (219-220; 562-563): If squid or squid 

byproduct fertilizers are over applied they 

can leach nitrogen and phosphate into the 

soil. Discharges of dead squid & wastewater 

boost ammonia concentrations & reduce 

oxygen content in the water posing a threat 

to marine life.

2. Is there a probability of environmental 

contamination during, manufacture or 

disposal? [§6518(m)(3)]

X TR (191-192): Disposal is regulated as a solid 

waste by the US EPA. 

3. Are there any adverse impacts on 

biodiversity? (§205.200)

X TR (78-81): Even without fishing, the entire 

population replaces itself annually. The stock 

is entirely dependent on successful spawning 

from each generation coupled with good 

survival of recruits to adulthood.

4. Does the substance contain inerts classified 

by EPA as ‘inerts of toxicological concern’? 

[§6517 (c)(1)(B)(ii)]

X

5. Is there potential for detrimental chemical 

interaction with other materials used in 

organic farming systems?

[§6518(m)(1)]

X

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

material or its breakdown products?

[§6518(m)(2)]

X

7. Is there persistence or concentration of the 

material or breakdown products in the 

environment? [§6518(m)(2)]

X TR (489-490; 524-525): Squid & squid 

byproduct hydrolysate is used as fertilizer in 

crop production providing organic matter. At 

high levels of application there is greater 

potential for leaching of nitrogen and 

phosphorus.

8. Would the use of the substance be harmful 

to human health or the environment? 

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

§6518(m)(4)]

X TR (674-676; 718; 727-733) Manufacture 

waste of fats and oils must be properly 

treated or can lead to pollution. International 

squid fishing remains a concern of human 

rights advocacy particularly in SE Asia & NZ 

where debt bondage and captive 

enslavement are practiced. Illegal, 

unreported & unregulated fishing is a 

significant problem affecting the marine 

ecosystem (examples cited China, Chile, 

Thailand, and India).
9. Are there adverse biological and chemical 

interactions in the agro-ecosystem? 

[§6518(m)(5)]

X TR (614-615; 622-623): Decomposition of 

squid & squid byproducts provide starting 

ingredients for humus formation which 

comprises much of the organic matter in soil. 

Microbial activity is higher in soils fertilized 

with squid & squid byproducts hydrolysate 

than comparable soils fertilized with other 

organic fertilizers or synthetic mineral 

products.

10. Are there detrimental physiological effects 

on soil organisms, crops, or livestock? 

[§6518(m)(5)]

X

Category 2. Is the Substance Essential for Organic Production? Squid & Squid Byproducts

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

regulatory agency; other)

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

2. Is the substance formulated or 

manufactured by a chemical process? 

[§6502(21)]

X TR (464; 479-482): Squid and squid 

byproduct hydrolysates are similar in 

composition to fish emulsions. The addition 

of sulfuric and phosphoric acid are 

considered synthetic.

3. Is the substance formulated or 

manufactured by a process that chemically 

changes a substance extracted from 

naturally occurring plant, animal, or mineral 

sources? 

[§6502(21)]

X

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

X

5. Is there a natural source of the substance? 

[§ 205.600(b)(1)]

X

6. Is there an organic substitute? 

[§205.600(b)(1)]

X

7. Is there a wholly natural substitute product?

[§6517(c)(1)(A)(ii)]

X TR (738-739): Raw animal manure, 

composted plant and animal materials & 

uncomposted plant and animal materials.

8. Are there any alternative substances? 

[§6518(m)(6)] 

X TR (742-746): Aquatic plant extracts, 

elemental sulfur, humic acids, lignin 

sulfonate, micronutrients, & liquid fish 

products.

9. Are there other practices that would make 

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

X TR (775-781): Use of cover crops, crop 

rotations, no-till and the application of plant 

and animal materials.
NOSB Evaluation Criteria for Substances Added To the National List - Crops 

Category 3. Is the substance compatible with organic production practices? Squid & Squid Byproducts

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

regulatory agency; other)

1. Is the substance consistent with organic 

farming and handling? 

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

X

2. Is the substance compatible with a system of 

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

X

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

nutritional quality of the food maintained 

with the substance? [§205.600(b)(3)]

X

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

primary use as a preservative? 

[§205.600(b)(4)]

X

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

primary use to recreate or improve flavors, 

colors, textures, or nutritive value lost in 

processing (except when required by law)? 

[§205.600(b)(4)]

X

6. Is the substance used in production, and 

does it contain an active synthetic ingredient 

in the following categories:

[§6517(c)(1)(B)(i);

copper and sulfur compounds

toxins derived from bacteria

pheromones, soaps, horticultural oils, 

fish emulsions, treated seed, vitamins 

and minerals

X (TR 298-304): OFPA does not specifically list 

squid or squid byproducts, however, it does 

list fish emulsion. In US law, the term “fish” is 

often taken to mean finfish, mollusks, 

crustaceans, and all other marine animal and 

plant life with the exclusion of marine 

mammals and birds. Squid are considered 

mollusks.

livestock parasiticides and medicines

production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleansers