National Organic Standards Board

Crops Subcommittee Petitioned Material Discussion Document

Paper (Plant Pots and Other Crop Production Aids)

August 15, 2019

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) As 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 fact that paper (a synthetic substance) is not included on the National List for uses other than as 

mulch and as compost feedstock. The paper chain pots also contain other synthetic substances, such as 

adhesives. At the October 2018 and April 2019 NOSB meetings, there were numerous oral and written 

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

reviewed the petition. The NOSB also formally requested this extension of the NOP 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 review this material. 

Paper pots are used by small and mid-scale farming operations to efficiently transplant vegetable 

seedlings. More information on this transplanting method can be found on these websites: 

http://paper-pot.com/ and http://www.smallfarmworks.com/. The transplanting equipment and paper 

pot chains are imported from a manufacturer in Japan. According to the petition, the Nitten paper chain 

pot system uses paper produced from a non-bleached Kraft pulp, and adhesives. There have been 

synthetic polymers (also called “synthetic fibers” in this document) in small quantities in the paper pots, 

but experiments are taking place to determine if these can 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 growers. The alternative would be the much slower and more costly method of hand 

planting individual seedlings. 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 readily in the soil. 

In addition to the Nitten petitioner, there are numerous other paper pot systems, both to be 

transplanted as single plants and in chains of pots. These other paper pot systems have various 

proportions of synthetic polymer fibers as well as other ingredients, such as cow manure. The 

subcommittee seeks to address all these products in our recommendation. 

The petition states that in addition to information on paper, the 2017 Technical Report (TR) on 

newspaper and other recycled paper addresses the presence of adhesives in recycled paper 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. 

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The crops subcommittee has seen 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 conduct this review, the crops subcommittee requested a July 2019 Technical Report on Paper Pots 

and Containers to determine the extent of synthetic adhesives, synthetic polymer fibers, and other 

additives in paper pots and to determine whether or not they are substantively different than those 

found in paper already allowed as mulch and compost feedstocks (§§ 205.601(b) and 205.601(c)). Pots, 

compost, and mulch all degrade into the soil, and the crops subcommittee believes if the fibers and 

additives are allowed in the other listings for paper, then their use in pots should be allowed as well.

However, since the subcommittee is proposing allowing the use of virgin paper, the subcommittee 

wants to make sure that the annotation does not allow for that virgin paper to include any amount or 

type of synthetic polymer and that those synthetic polymers used in the virgin paper are biobased and 

biodegrade in the soil.

The Technical Review clarified that the additives and synthetic fibers found in a variety of paper pots are 

also found in newspaper and other recycled paper currently allowed for compost feedstock and mulch. 

Other possible additives 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 chain pot 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, 

particularly in smaller scale production systems. 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 the current regulation. Certifiers who had not previously 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 Nitten supplier noted in the petition.

Approval of this material will likely lead to other manufacturers competing for their share of this market. 

Synthetic paper pots can be made from natural fiber feedstock or from a mixture of natural fiber

feedstock and synthetic polymers. The pots with synthetic polymers 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 are, at times, used in transplanting annual vegetable and floriculture seedlings, 

depending on the time frame between planting into the pot and planting out in the field and whether

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 in the recycled paper already 

allowed in organic agriculture.

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 that would 

decompose in the soil.

Specific Uses of the Substance:

Paper-chain pots are either single or in chains to allow for “mechanical” transplanting. The paper pots 

decompose in the soil and lessen transplant shock since the seedling root system is less disturbed, and 

the paper pots are part of a greenhouse-to-field growing system that requires considerably less labor 

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than hand transplanting. Use of paper pots may significantly reduce reliance on plastics. 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 on which 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. 

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 two technical reports (TRs) on Newspaper and Other Recycled Paper in 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 Report of Paper Pots and Containers, which detailed the specific possible 

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

available, provided more clarity about manufacture and use of paper pots for the NOSB.

Manufacture:

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

kenaf, sisal, jute, sugarcane bagasse, sunflower stalks, and 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. Paper used as a production 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 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 production aid, the subcommittee also considered the fact that 

we currently have an allowance for paper used in organic production. It is the subcommittee’s view that 

there are few differences between the current paper allowance and the use of paper for plant pots and 

containers. 

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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.

The paper pulp production process and the adhesives used in maintaining structural integrity of 

the paper pots currently rely on synthetically manufactured ingredients. 

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 a crop production aid, not a pesticide.

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)]

Paper for plant pots/containers (as a crop production aid) is functionally identical to newspaper 

and recycled paper. This current listing of newspaper and recycled paper has been found to 

have no detrimental interactions with other materials in organic agriculture. Since virgin paper, 

with potentially different synthetic polymer makeup than recycled paper, would be allowed 

under this listing, a biodegradability standard in the annotation ensures that these paper 

products would not persist in the environment.

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 production 

aid, which would be aligned with the current annotation for paper as a compost feedstock 

and/or mulch. The 2019 TR found many of the adhesives and synthetic fibers biodegrade with 

no negative impacts. There were some that were not as environmentally neutral as others, but 

all are also present in paper under the current allowance. The subcommittee wants to ensure 

that the fibers used in paper products described by this petition will similarly biodegrade in the 

soil, especially given that virgin paper, with potentially different quantities of synthetic polymers 

than recycled paper, would be allowed. 

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

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

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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. A difference between this paper and the previously approved newspaper and 

other recycled paper 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 production 

aid in organic agriculture. There are negative environmental impacts from harvesting trees to 

make paper such as deforestation, road building, soil erosion, and degraded water quality, but 

there are forestry best management practices that can help mitigate some these negative 

effects.

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

§6518(m)(4)].

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, as a material, 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) 

No.

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, but these have never been 

petitioned for use in organic agriculture. We do not know if they could be approved or not. 

These pots contain 10% newspaper. There are also tools to help growers roll up newspaper into 

a pot. The paper chain pots offer greater efficiency for transplanting, although mechanical or 

hand transplanting operations can be used in both small- and large-scale operations with other 

types of containers. The future use of hemp fibers may also offer an alternative to synthetic 

polymers. 

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 annotation “Virgin or recycled paper, without 

colored or glossy inks; any synthetic fibers included must not exceed 15% of the paper and must 

be 100% biobased with content determined using ASTM D6866 (incorporated by reference; see 

205.3), and demonstrates at least 90% biodegradation absolute or relative to microcrystalline 

cellulose in less than two years, in soil, according to one of the following test methods: ISO 17556 

or ASTM D5988 (both incorporated by reference; see § 205.3)”. Continuing the prohibition on 

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colored and glossy inks prevents the incorporation into organic soil of the worst contaminants. 

Allowing the adhesives typically used in paper, makes this crop production aid equivalent to 

newspaper and recycled paper that is currently allowed. The allowance for virgin paper allows 

for special papers to be developed that meet the specific crop production needs for a variety of 

uses, and the amount of paper produced from virgin sources for these production aids would be 

very small compared to the amount of paper manufactured for all uses. Added fungicides, 

insecticides, or other synthetic materials not typically found in paper, would not be allowed 

under the current annotation. An unanswered question is whether it is practical and achievable 

to allow only natural fibers, using hemp or other fibers, to provide the strength needed in paper 

crop production aids. With the recommended annotation, paper as a crop production aid is 

compatible with a sustainable system of agriculture.

Discussion Questions:

1. Please comment on the following options under consideration by the subcommittee for listing at 

§ 205.601(o) as production aids: 

a. “Virgin or recycled paper, without colored or glossy inks,” or 

b. “Virgin or recycled paper, without colored or glossy inks; any synthetic polymer fibers

included must not exceed 15% of the paper and must be 100% biobased with content 

determined using ASTM D6866 (incorporated by reference; see 205.3), and demonstrates 

at least 90% biodegradation absolute or relative to microcrystalline cellulose in less than 

two years, in soil, according to one of the following test methods: ISO 17556 or ASTM 

D5988 (both incorporated by reference; see § 205.3)”

2. Synthetic polymer content— 

a. Should a maximum synthetic polymer content be stated explicitly? If so, what is the 

appropriate level? 

b. What is the amount (or range) of synthetic polymer content in products currently 

available? 

c. How would synthetic content be measured? How would a certifier or Material Review 

Organization verify content? For example, if a product included recycled paper as an 

ingredient, how would the synthetic polymer content be determined?

d. Is it possible to manufacture paper production aids that use only natural fiber sources and 

that meet the product specifications for their intended use?

3. Biodegradability— 

a. Should a biodegradability standard be included for these products? If so, is this the 

appropriate biodegradability standard?

b. Does maximum synthetic polymer content need to be stated if there is a biodegradability 

requirement? 

c. As the products biodegrade, what is the impact on the soil? Also, can fragments be 

consumed by wildlife or livestock before it is completely degraded?

4. Biobased content— 

a. Should a minimum biobased content standard be included for these products?

b. Is 100% biobased content achievable for these products? If not, what should be the 

minimum biobased content requirement? 

5. Is genetic engineering involved in the production of these products? 

6. Does the annotation need to specify that added fungicides, insecticides, or other synthetic 

materials not typically found in paper would not be allowed, or is that already understood?

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Subcommittee Vote:

 

Motion to accept the petitioned material discussion document on Paper (Plant Pots and Other Crop 

Production Aids)

Motion by: Harriet Behar

Seconded by: Steve Ela

Yes: 8 No: 0 Abstain: 0 Absent: 0 Recuse: 0 

Approved by Steve Ela, Crop Subcommittee Chair, to transmit to NOP August 14, 2019

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