National Organic Standards Board

Crops Subcommittee Petitioned Material Discussion Document

Ammonium Citrate and Ammonium Glycinate

August 7, 2018

Summary of Petitions for ammonium citrate and ammonium glycinate: 

Alpha Chelates has petitioned for the inclusion of ammonium citrate and ammonium glycinate on the 

National List at §205.601 (synthetic substances allowed for use in organic crop production). These new 

petitions follow two petitions in 2016 of ammonium citrate and ammonium glycinate during which time 

the NOSB determined in its fall 2016 recommendation1 that alternatives exist, including lignin sulfonate

(synthetic) and nonsynthetic substances. Also on file for these materials are four petition addendums; 

the first addendum was submitted in response to a request for additional information by the Crops 

Subcommittee in 2016; the second addendum was volunteered by the petitioner in 2016; the third 

addendum was volunteered by the petitioner in 2016. An addendum to the new petition was 

submitted in 2018.

Ammonium citrate and ammonium glycinate are used as chelating agents with inorganic metal 

micronutrients copper, iron, manganese, or zinc for high pH soils. Chelated micronutrients (“chelates”) 

are used to supply micronutrients that are not readily available to plants in deficient soils. Ammonium 

citrate and ammonium glycinate are not being petitioned to be applied to crops alone but to serve as 

chelating agents in the formation of chelates. 

During its 2016 review, the Board determined that there was insufficient information in the justification 

statement regarding the necessity of these materials for organic crop production. Chelates occur 

naturally in soils, so chelates, per se, are not incompatible with a system of sustainable agriculture; 

however, overreliance on synthetic materials is not compatible with a system of sustainable agriculture. 

The Subcommittee determined that there were insufficient grounds for adding these substances to the 

National List as there are alternatives available, and it was not clear that the permitted products already 

on the market are inadequate to meet farmers’ needs.

The most recent re-petitions were submitted on the premise that “the technology concerning chelating 

agents and micronutrient chelates has been significantly misunderstood by [the] NOSB”. Additionally,

the new petition refers to the results of a field trial of wheat in high pH soil in Australia in which 

chelated micronutrients led to an increase in yield over unchelated micronutrients. A significant 

component of the original and second petitions is a case for clarifying the terms “chelate” and “chelating 

agent” (or “ligand”) in the regulations and guidance. The petitioner requests that the NOP define which 

bases can be used to neutralize specific acids used to synthesize chelating-agent-salts. Additionally, the 

petitioner asks for “recognition that the species and strength of acid and base are needed for accurate 

and reproducible neutralization; hence the suitability for use of ‘nature identical’ acids and bases”. 

Other clarification and revision appeals are explained in the second petition. 

A Technical Report (TR) was not requested as part of the 2016 review; however, TRs have been solicited

in response to this second application, both to review the petitioned materials and to investigate the 

broader issue of nomenclature and technical errors elaborated by the petitioner. 

1 The 2016 recommendation and all 2016 addendum links are to Ammonium Citrate, though an identical 

recommendation and complementary addendums were submitted for Ammonium Glycinate and can be 

found on the List of Petitioned Substances. 

NOSB Oct 2018 proposals and discussion documents pg. 199 of 204
Questions:

1. Are these materials for which organic farmers have expressed a need? If so, please describe 

how these materials perform a function that the nonsynthetic and/or synthetic chelating agents 

already allowed do not.

2. Please provide evidence of the efficacy of these petitioned chelating agents over currently 

approved chelating agents.

3. Are other changes to the regulations appropriate to clarify which substances are allowed in the 

manufacture of chelated micronutrients? 

Vote in Subcommittee 

Motion to accept the ammonium citrate and ammonium glycinate petitioned material discussion 

document 

Motion by: Emily Oakley 

Seconded by: Dave Mortensen

Yes: 7 No: 0 Abstain: 0 Absent: 1 Recuse: 0

Approved by Steve Ela, Subcommittee Chair to transmit to NOSB, August 7, 2018

NOSB Oct 2018 proposals and discussion documents pg. 200 of 204