National Organic Program

1400 Independence Avenue, SW

Room 2642-South, STOP 0268

Washington, DC 20250-0268

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MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD

September 9, 2023 

FROM: Jennifer Tucker, Ph.D. 

 Deputy Administrator 

 National Organic Program (NOP)

SUBJECT: Work Agenda Request: Biodegradable Biobased Mulch Film (BBMF)

The National Organic Program (NOP) requests that the National Organic Standards Board 

(NOSB or Board) continue to work on, and facilitate public discussion about, the topic of 

biodegradable biobased mulch film (BBMF) in organic crop production. 

BBMF is a weed barrier that naturally biodegrades in the soil after use. BBMF is intended to 

reduce labor and the need for non-recyclable plastic mulches that do not biodegrade. Currently, 

the United States Department of Agriculture (USDA) organic regulations (National List) require 

BBMF products to meet specific criteria regarding excluded methods, biobased content, 

compostability, and biodegradability. While technically allowed as a synthetic material in 

organic crop production, no known products meet the requirements of the current regulatory 

listing – making it allowed, but not actually useable. 

The Board’s goal with BBMF has been to reduce plastic waste on organic farms; BBMF was 

originally added to the National List based on a Board recommendation with that intent. The 

Board has discussed the use of BBMF as an alternative to disposable plastic mulch many times, 

with BBMF on their biannual meeting agendas in 2012, 2017, and 2019-2021. Most recently, the 

Board issued a 2021 recommendation proposing to change the biobased content requirement (the 

percent of polymer feedstocks used to make BBMF that must be from renewable sources) in the 

current BBMF listing on the National List from 100% to 80%. Like the existing regulatory 

listing, there are currently no BBMF products that meet the requirements in the Board’s 2021 

recommendation. 

NOP shares the goal of reducing plastic waste as a means of meeting the USDA organic 

requirements for conserving natural resources and environmental stewardship – outlined in 

7 CFR 205.200. The USDA has programs and research focusing on the development and 

expansion of markets for biobased products, including the National Institute of Food and 

Agriculture (NIFA) Bioproduct Pilot Program, USDA BioPreferred Program, and several

Agricultural Research Service (ARS) projects. Because rulemaking requires intensive USDA 

staff time and effort as well as broad stakeholder support, the NOP prefers to only conduct 

rulemaking if it supports the organic community in a practical way. Because there are no 

commercially available BBMF products that could meet the current recommendation, NOP has 

determined that it will not implement the 2021 recommendation as is. Instead, the NOP asks the 
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Board to continue work on the topic of BBMF and submit a revised recommendation that 

addresses the questions outlined below. 

Background 

BBMF products are used in agriculture as physical weed barriers. They are laid as a thin layer on 

top of the soil to suppress weeds while also controlling soil moisture, temperature, and crop 

pests. BBMF products can be used in a wide range of crops including berries, brassicas, melons, 

onions, squash, and tomatoes. In general, biodegradable mulch films are made from biobased or 

fossil-fuel-derived (e.g., petroleum) polymer feedstocks combined with other pigments and 

processing aids. The most common biobased feedstocks are thermoplastic starches (TSP) 

extracted from natural materials like high-amylose starch, polylactic acid (PLA) produced by 

chemical synthesis from cornstarch, and polyhydroxyalkanoates (PHA) produced by 

microorganisms.

1

BBMF products are intended to be left in the field after use, where they naturally biodegrade in 

the soil. BBMF is an alternative to traditional plastic mulch (sheets of plastic used as weed 

barriers) made from fossil-fuels (e.g., polyethylene (PE) plastic mulch). The USDA organic 

regulations require the removal of plastic mulch from the field at the end of the growing or 

harvest season, resulting in waste build-up in landfills, as the plastic is typically non-recyclable. 

The recommendation to allow organic farmers to use BBMF products as an alternative to plastic 

barriers was intended to save labor and reduce plastic waste.

The current USDA organic regulations allow BBMF products that meet specifications for

excluded methods, compostability, biodegradability, and biobased content (§§ 205.601(b)(2)(iii)

and 205.2). These regulations reference a variety of third-party testing standards from ASTM 

International, European Committee for Standardization (EN), and the International Organization 

for Standardization (ISO). The USDA organic regulations state that BBMF products: 

1) Must not be produced using excluded methods.

2

2) Must be compostable: 

a) ASTM D6400: Standard Specification for Labeling of Plastics Designed to be 

Aerobically Composted in Municipal or Industrial Facilities. 

b) ASTM D6868: Standard Specification for Labeling of End Items that Incorporate Plastics

and Polymers as Coatings or Additives with Paper and Other Substrates Designed to be

Aerobically Composted in Municipal or Industrial Facilities. 

c) EN 13432: Requirements for packaging recoverable through composting and 

biodegradation—Test scheme and evaluation criteria for the final acceptance of 

packaging. 

d) EN 14995: Plastics—Evaluation of compostability—Test scheme and specifications. 

e) ISO 17088: Specifications for compostable plastics. 

3) Must biodegrade by at least 90% in less than two years: 

a) ISO 17556: Plastics—Determination of the ultimate aerobic biodegradability of plastic

materials in soil by measuring the oxygen demand in a respirometer or the amount of

carbon dioxide evolved. 
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b) ASTM D5988: Standard Test Method for Determining Aerobic Biodegradation of Plastic 

Materials in Soil. 

4) Must be biobased: 

a) ASTM D6866: Standard Test Methods for Determining the Biobased Content of Solid, 

Liquid, and Gaseous Samples Using Radiocarbon Analysis. 

BBMF was added to the USDA organic regulations in 2014 in response to a petition and NOSB 

recommendation. When BBMF was added, NOP explained in the preamble to the final rule that 

100% of feedstocks used to make BBMF products must be derived from renewable materials 

(biobased), not fossil-fuels. Because no products actually aligned with the rule listing, in 2019, 

the NOP asked the Board to work further on this topic and develop a recommendation for next 

steps. Public comments submitted to the Board reported that 20-50% was a more feasible 

biobased content percentage for BBMF.

3

After reviewing public comments and deliberating at their meeting, the NOSB issued a 2021 

recommendation to reduce the required minimum biobased content to from 100% to 80%. At the 

time, the Board acknowledged that 80% was not currently available, calling the percentage 

“aspirational.” In the 2021 recommendation, the Board also recommended requiring organic 

farmers to switch to BBMF products with higher biobased content whenever they become 

commercially available. Other historical NOSB and NOP work on BBMF is included in 

Appendix A. 

When the NOP receives recommendations from the Board, subject matter experts vet the 

proposal and conduct further research, which may include discussions with other federal 

agencies. Occasionally, new research or information becomes available between the time the 

Board has submitted the recommendation and the time NOP staff begin their vetting process. 

NOP also balances NOSB recommendations against other high-priority rules, staff capacity, 

impact to industry, and stakeholder support. 

After speaking with industry and subject matter experts, NOP determined that the organic 

industry would be unable to meet the Board’s 80% biobased requirement recommendation for 

BBMF in the near future. Based on our analysis, the NOP has identified the following 

challenges:

1) Eighty percent biobased BBMF products are not available. Only <50% biobased BBMF 

products are commercially available in the United States.

4, 5

2) Biobased content has no impact on biodegradability.6, 7 Some biobased components only 

biodegrade under high temperatures.

8, 9

 These high temperatures may be produced in a 

composting environment but not naturally in the field. It is our understanding that a 

hypothetical 80-100% biobased mulch film must use components that make it unable to meet 

the biodegradable requirements. For these reasons, researchers stated that developing 80% or 

higher biobased content mulch film products for commercial use that are functional and 

biodegradable is not currently possible.6

3) The USDA organic regulations require BBMF products to meet 90% biodegradation within 

two years. Researchers have indicated that this requirement does not account for differences 

between in-field and laboratory conditions. Products that meet the current biodegradation 
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requirements may be too fragile and become brittle and fragmented before the end of the 

growing season. A BBMF product that lasts all growing season may take longer than two 

years to biodegrade, depending on the agricultural location and climate.

6, 9

4) Currently, the USDA organic regulations require BBMF products to be compostable and 

biodegradable. Biodegradation is a process that happens naturally in the field over time, 

while composting is an actively managed process that involves human labor. The NOP 

believes these two requirements may be in conflict with each other for several reasons. The 

NOP questions whether requiring both compostability and biodegradability is necessary. 

a) Requiring compostability may result in products that, while strong and last all season, do 

not biodegrade in the field. As BBMF products are designed to be left in the field to 

biodegrade, requiring compostability may be unnecessary. Requiring BBMF products to 

be sent to composting facilities after use is contrary to the intent of saving labor. In 

addition, not all regions may have access to commercial compost facilities.

b) There appears to be conflicting data on the differences between “compostability” and 

“biodegradability.” One source indicates that compostable products are biodegradable, 

but not all biodegradable products are compostable.10 Another source appears to 

contradict this by indicating that compostability does not equal in-field biodegradation.

11

5) The current annotation for BBMF on the National List requires that it be produced without 

organisms or feedstock derived from excluded methods. However, most of the biobased 

components of commercially available BBMF products may be produced using excluded 

methods.9

The National Organic Program’s Request to the National Organic Standards Board

Given the challenges identified above, the NOP requests that the NOSB continue work on this 

topic. The Board’s consideration is the logical next step in this process and will help us find the 

best path forward through engagement with stakeholders, discussion in subcommittees, 

solicitation of comments, and discussion at public meetings. This recommendation should 

identify ways to overcome the challenges we have identified, reflect BBMF products or other 

alternatives that could be commercially available now or in the near future, meet the goal of 

reducing plastic waste, and be consistent with the Organic Foods Production Act (OFPA). 

As the Board deliberates this issue, please reference past NOSB work (Appendix A) and the 

challenges identified in this memorandum. We also look forward to responses to the following 

questions: 

1) As biobased content does not impact biodegradability, is it necessary to require biobased 

content? If so, why? 

2) If the Board determines that biobased content requirements are necessary, how should the 

biobased content be revised, given that current commercially available products are less than 

50% biobased? 

3) If biodegrading to 90% within two-years is unrealistic, what is a realistic requirement? Are 

the third-party testing standards currently in the USDA organic regulations appropriate? If 

not, what other testing standards could be used? 
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4) Given the conflicts between compostability and biodegradability, are both needed? If so, 

why? If only one is needed, which one is necessary and why? 

5) What is the need for BBMF as an alternative to plastic mulch outside of reducing plastic 

waste? What types of organic operations are expected to use BBMF if compliant products 

were available now? Please be as specific as possible (number of operations, crop types, 

production systems, size/scale, geographic regions, etc.). 

6) What specific uses of plastic mulch can be replaced by BBMF? How much plastic mulch 

would organic farmers no longer use if BBMF products were available? How many organic 

farms would switch from plastic mulch to BBMF? Would the use of plastic mulch be 

eliminated on these farms?

7) Are there other materials that could meet the functional goals of BMMF, but without the 

continued use of plastic-like materials?

The Board must review all substances on the National List of Allowed and Prohibited Substances

portion of the USDA organic regulations every five years for renewal or removal (called a 

“sunset review”). The next sunset date for BBMF is October 30, 2029, and the NOSB is 

scheduled to conduct their next sunset review in 2027. We ask the Board to provide a revised 

recommendation before the next sunset review, at or before the Spring 2025 meeting. 

We acknowledge and appreciate the Board’s previous work on this complex topic. The NOP 

thanks the NOSB in advance for continuing your work, and we look forward to your discussion 

and guidance. 

References

1 Ghimire, S., and C. Miles. 2020. "Soil-Biodegradable Mulches: Course Lecture." Soil-biodegradable Mulches in 

Agriculture. Washington State University Extension. September. 

https://s3.wp.wsu.edu/uploads/sites/2181/2021/11/2.-long-lecture_presenter-notes.pdf. 

2 Excluded methods is defined at 7 CFR 205.2 and refers to a variety of methods used to genetically modify 

organisms or influence their growth and development in ways that are not possible under natural conditions.

3 DeVetter, L., B. Madrid, C. Miles, M. Flury, D. Griffin-LaHue, J. DeBruyn, S. Schaeffer, D. Hayes, and S. 

Ghimire. 2021. "Public Submissions to the NOSB." Washington State University; University of TennesseeKnoxville; University of Connecticut. September 28. https://www.regulations.gov/comment/AMS-NOP-21-0038-

0239.

4 DeVetter, L., S. Shrestha, and D. Hayes. 2021. "What is a Soil-Biodegradable Plastic mulch Composted Of?" 

Washington State University Extension. July. Accessed July 13, 2023. 

https://s3.wp.wsu.edu/uploads/sites/2181/2021/07/What-is-in-a-BDM.pdf. 

5 Miles, C., S. Shrestha, and S. Ghimire. 2021. "Soil-Biodegradable Mulch for Organic Production." Washington 

State University Extension. May. Accessed July 13, 2023. https://s3.wp.wsu.edu/uploads/sites/2181/2021/06/4.-

BDM-organic_presenter-notes.pdf. 

6 Miles, C. 2023. "Reducing Plastics Along the Entire Organic Supply Chain." The Organic Center Confluences 

Organic Week 2023. Washington, DC: https://www.organic-center.org/organic-confluences-during-organic-weekwashington-dc. 

7 Michigan State University. 2019. "Biodegradable Biobased Mulch Films in Organic Crop Production." National 

Organic Program. September. Accessed July 13, 2023. 

https://www.ams.usda.gov/sites/default/files/media/2019MemoBiobasedMulchReport.pdf. 
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8 Miles, C., B. Madrid, L. DeVetter, and B. Weiss. 2023. "Soil-Biodegradable Plastic Mulch for Organic Production 

Systems." Washington State University Extension. March. Accessed July 13, 2023. 

https://smallfruits.wsu.edu/documents/2023/05/soil-biodegradable-plastic-mulch-for-organic-productionsystems.pdf/.

9 Ghimire, S., D. Hayes, J. Cowan, D. Inglis, L. DeVetter, and C. Miles. 2018. "Biodegradable Plastic Mulch and 

Suitability for Sustainable and Organic Agriculture." Washington State University Extension. Accessed July 13, 

2023. https://pubs.extension.wsu.edu/using-biodegradable-plastics-as-agricultural-mulches. 

10 Royer, S., F. Greco, M. Kogler, and D. Deheyn. 2023. "Not so biodegradable: Polylactic acid and cellulose/plastic 

blend textiles lack fast biodegradation in marine waters." PLOS ONE. https://doi.org/10.1371/journal.pone.0284681. 

11 United States Environmental Protection Agency (EPA). 2022. Frequently Asked Questions about Plastic 

Recycling and Composting. August 30. Accessed July 13, 2023. https://www.epa.gov/trash-free-waters/frequentlyasked-questions-about-plastic-recycling-and-composting#dif.
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APPENDIX A – History of NOSB Review & NOP Rulemaking Activity for BBMF

Website: NOP Petitioned Substances Index entry for Biodegradable Biobased Mulch Films (BBMF)

Timeline:

• 2012 Petition requesting addition of BBMF to the National List.

• 2012 Technical Report. 

• 2012 Fall NOSB recommendation to add BBMF to the National List.

• 2014 NOP final rule adding BBMF to the National List (79 FR 58655). The preamble explains that all 

BBMF feedstocks must be derived from renewable materials (biobased), not fossil-fuels.

• 2015 NOP Policy Memorandum 15-1 clarified that all feedstocks must be biobased, and non-biobased 

feedstock such as petrochemical resins are prohibited. The 2019 NOP Memorandum (see below) rescinded 

this memorandum as it did not present new information or impose additional requirements compared to the 

2014 NOP final rule.

• 2015 Report on Biodegradable Biobased Mulch Films. 

• 2016 Limited Scope Technical Report. 

• 2017 Fall NOSB recommendation to renew BBMF (2019 Sunset).

• 2019 Spring NOSB meeting: Expert panel on BBMF. 

• 2019 NOP Memorandum to NOSB to rescind Policy Memorandum 15-1, transmit a BBMF study from 

Michigan State University, and request the Board’s review and recommendation for next steps.

• 2019 NOP notice renewing BBMF until 2024 (84 FR 53577).

• 2020 Spring NOSB discussion document. 

• 2020 Fall NOSB discussion document.

• 2021 Fall NOSB recommendation to amend BBMF.

• 2022 Fall NOSB recommendation to renew BBMF (2024 Sunset).

• 2023 NOP notice renewing BBMF until October 30, 2029 (88 FR 22893).