Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

Date: May 25, 2012

Subject: Petition to add curry leaves to § 205.606 of the National List.

Chair: Barry Flamm

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action ___x_____

Guidance Statement __________

Other __________

Statement of the Recommendation (Including Recount of Vote):

Classification Motion: Move that curry leaves are agricultural.

Vote: 15 yes, 0 no

Listing Motion: 1. Move to add curry leaves to the National List 205.606.

 Vote: 12 yes 2 no 1 abstain

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

Since curry leaves are an important ingredient in numerous Indian recipes, and it 

is reported that no common ingredient substitution exists, this agricultural item 

appears to meet the requirements defined for “commercially available” in §205.2 in 

the NOP regulation (appropriate form, quality, quantity). As a result, curry leaves 

are a candidate for listing on §205.606

Committee Vote-Classsification:

Moved: John Foster Second: Tracy Favre

Yes: 15 No: 0 Abstain: 0 Absent: 0 Recusal: 0

Committee Vote-Listing:

Moved: John Foster Second: Harold Austin

Yes: 12 No: 2 Abstain: 1 Absent: 0 Recusal: 0
National Organic Standards Board

Handling Committee

Petitioned Material Proposal

Murraya koenigii (curry leaves)

March 31, 2012

Summary of Proposed Action:

A petition has been received to add Murraya koenigii (curry leaves) to be added to §205.606-

Nonorganically produced agricultural products allowed as ingredients in or on processed products 

labeled as “organic.” Murraya koenigii (more commonly known as curry leaves or sweet neem leaves) 

is an extremely fragrant leaf commonly used for Indian cuisine. 

Discussion

Since curry leaves are natural, not reported to be toxic or dangerous and are in fact a common 

condiment or ingredient in human diets, the Handling Committee chose not to request a TR. 

Searches of the NOP database and two major organic certifiers’ online databases (QAI) and 

directories (CCOF) have yielded only three suppliers of organic curry leaves. The NOP’s database 

lists two distinct suppliers of curry leaves, both located in Sri Lanka while the CCOF directory lists one 

domestic source. QAI’s product listing database did not return any results. Since curry leaves are 

an important ingredient in numerous Indian recipes, and it is reported that no common ingredient 

substitution exists, this agricultural item appears to meet the requirements defined for “commercially 

available” in §205.2 in the NOP regulation (appropriate form, quality, quantity). As a result, curry 

leaves are a candidate for listing on §205.606. 

The petitioner indicated that a pest species quarantined in the United States, the Asian citrus 

psyllid, is commonly found on curry leaves in common countries of origin; as a result, imported 

organic curry leaves are not reliably available. A simple internet search for the pest yields numerous 

reliable stories on the quarantines in place. Additionally, the single domestic supplier has limited 

quantities available, well under the quantity claimed to be needed by the petitioner.

Evaluation Criteria 

(Applicability noted for each category; Documentation attached) Criteria Satisfied? (see 

“B” below)

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

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

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

4. Commercial Supply is Fragile or Potentially Unavailable x Yes ☐ No ☐ N/A 

as Organic (only for § 205.606)

Substance Fails Criteria Category: [ ] Comments: 

Proposed Annotation (if any): 

Basis for annotation: ☐ To meet criteria above ☐ Other regulatory criteria ☐ Citation 

Notes: 

Recommended Committee Action & Vote, including classification recommendation (state actual 

motion):

Classification Motion: Motion to determine substance as non-synthetic.

Motion by: John Foster Seconded by: Harold Austin

Yes: 5 No: 0 Absent: 1 Abstain: 0 Recuse: 0
Revised March 2012

Listing Motion: Motion to add Murraya koenigii (curry leaves) to §205.606- Nonorganically 

produced agricultural products allowed as ingredients in or on processed products labeled as 

“organic.”

Motion by: John Foster Seconded by: Joe Dickson

Yes: 5 No: 0 Absent: 1 Abstain: 0 Recuse: 0

Crops ☐ Agricultural ☐ Allowed1 x

Livestock ☐ Non-synthetic x Prohibited2 ☐

Handling x Synthetic ☐ Rejected3 ☐

No restriction ☐ Commercial unavailable as 

organic

x Deferred4 ☐

1

Substance voted to be added as “allowed” on National List to § 205. with Annotation (if any): 

2

Substance to be added as “prohibited” on National List to § 205. with Annotation (if any): 

Describe why a prohibited substance: 

3

Substance was rejected by vote for amending National List to § 205. . Describe why material 

was rejected: 

4

Substance was recommended to be deferred because 

If follow-up needed, who will follow up: 

Approved by Committee Chair to Transmit to NOSB

John Foster, Committee Chair 3/31/12

NOSB Evaluation Criteria for Substances Added To the National List

Category 1. Adverse impacts on humans or the environment? 

Substance: Murraya koenigii (Curry Leaves)

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Are there adverse effects on 

environment from manufacture, use, 

or disposal?

[§205.600 b.2]

x

2. Is there environmental contamination 

during manufacture, use, misuse, or 

disposal? [§6518 m.3]

x

3. Is the substance harmful to the 

environment and biodiversity?

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

x

4. Does the substance contain List 1, 2 x
Revised March 2012

or 3 inerts? [§6517 c (1)(B)(ii); 

205.601(m)2]

5. Is there potential for detrimental 

chemical interaction with other 

materials used?

[§6518 m.1]

x

6. Are there adverse biological and 

chemical interactions in agroecosystem? [§6518 m.5]

x

7. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518 m.5]

x

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products?

[§6518 m.2]

x

9. Is there undesirable persistence or 

concentration of the material or 

breakdown products in environment? 

[§6518 m.2]

x

10.Is there any harmful effect on human 

health? [§6517 c (1)(A)(i); 6517 

c(2)(A)i; §6518 m.4]

x

11.Is there an adverse effect on human 

health as defined by applicable 

Federal regulations? [205.600 b.3]

x

12.Is the substance GRAS when used 

according to FDA’s good 

manufacturing practices? [§205.600 

b.5]

x

13.Does the substance contain residues 

of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5]

x

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 

(b) are N/A—not applicable.
Revised March 2012

NOSB Evaluation Criteria for Substances Added To the National List

Category 2. Substance Essential for Organic Production? 

Substance: Murraya koenigii (Curry Leaves)

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Is the substance formulated or 

manufactured by a chemical 

process? [6502 (21)]

x

2. 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

3. Is the substance created by naturally 

occurring biological processes? 

[6502 (21)]

x

4. Is there a natural source of the 

substance? [§205.600 b.1]

x

5. Is there an organic substitute? 

[§205.600 b.1]

x But limited and uncertain supply

6. Is the substance essential for 

handling of organically produced 

agricultural products? [§205.600 b.6]

x For those foods needing the profile 

the ingredient imparts

7. Is there a wholly natural substitute 

product?

[§6517 c (1)(A)(ii)]

x

8. Is the substance used in handling, not 

synthetic, but not organically 

produced?

[§6517 c (1)(B)(iii)]

x

9. Is there any alternative substances? 

[§6518 m.6]

x

10.Is there another practice that would 

make the substance unnecessary? 

[§6518 m.6]

x

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 

(b) are N/A—not applicable.
Revised March 2012

NOSB Evaluation Criteria for Substances Added To the National List

Category 3. Substance compatible with organic production practices? 

Substance: Murraya koenigii (Curry Leaves)

Question

Y

e

s

No N/A

1 Documentation (TAP; petition; 

regulatory agency; other)

1. Is the substance compatible with 

organic handling? [§205.600 b.2]

x Petition

2. Is the substance consistent with 

organic farming and handling? [§6517 

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

x

3. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518 m.7]

x

4. Is the nutritional quality of the food 

maintained with the substance? 

[§205.600 b.3]

x

5. Is the primary use as a preservative? 

[§205.600 b.4]

x

6. Is the primary use to recreate or 

improve flavors, colors, textures, or 

nutritive values lost in processing 

(except when required by law, e.g., 

vitamin D in milk)? [205.600 b.4]

x

7. Is the substance used in production, 

and does it contain an active synthetic 

ingredient in the following categories:

a. copper and sulfur compounds;

x

b. toxins derived from bacteria; x

c. pheromones, soaps, horticultural 

oils, fish emulsions, treated seed, 

vitamins and minerals?

x

d. livestock parasiticides and 

medicines?

x

e. production aids including netting, 

tree wraps and seals, insect traps, 

sticky barriers, row covers, and 

equipment cleaners?

x

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 

(b) are N/A—not applicable.
Revised March 2012

NOSB Evaluation Criteria for Substances Added To the National List

Category 4. Is the commercial supply of an agricultural substance as organic, fragile or 

potentially unavailable? [§6610, 6518, 6519, 205.2, 205.105 (d), 205.600 (c) 205.2, 205.105 (d), 

205.600 (c)] Substance: Murraya koenigii (Curry Leaves)

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Is the comparative description provided

as to why the non-organic form of the 

material /substance is necessary for use 

in organic handling? 

x Petition

2. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the 

material /substance cannot be obtained 

organically in the appropriate form to 

fulfill an essential function in a system of 

organic handling? 

x

3. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the 

material /substance cannot be obtained 

organically in the appropriate quality to 

fulfill an essential function in a system of 

organic handling? 

x

4. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the 

material /substance cannot be obtained 

organically in the appropriate quantity

to fulfill an essential function in a system 

of organic handling?

x

5. Does the industry information provided 

on material / substance non-availability 

as organic, include ( but not limited to) 

the following:

a. Regions of production (including 

factors such as climate and number 

of regions);

x

b. Number of suppliers and amount 

produced;

x

c. Current and historical supplies 

related to weather events such as 

hurricanes, floods, and droughts that 

may temporarily halt production or 

destroy crops or supplies; 

x

d. Trade-related issues such as 

evidence of hoarding, war, trade 

barriers, or civil unrest that may 

x
Revised March 2012

temporarily restrict supplies; or

e. Are there other issues which may 

present a challenge to a consistent 

supply?

x

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 

(b) are N/A—not applicable.
National Organic Standards Board

Handling Committee

Petition Proposal 

Murraya koenigii (Curry Leaves)

March 31, 2012

Introduction

A petition has been received to add Murraya koenigii (curry leaves) to be added to §205.606-

Nonorganically produced agricultural products allowed as ingredients in or on processed 

products labeled as “organic.”

Background

Murraya koenigii (more commonly known as curry leaves or sweet neem leaves) is an 

extremely fragrant leaf commonly used for Indian cuisine. 

Relevant areas in the Rule

§ 205.606 Nonorganically produced agricultural products allowed as ingredients in or on 

processed products labeled as “organic.”

Discussion

Since curry leaves are natural, not reported to be toxic or dangerous and are in fact a common 

condiment or ingredient in human diets, the Handling Committee chose not to request a TR. 

Searches of the NOP database and two major organic certifiers’ online databases (QAI) and 

directories (CCOF) have yielded only three suppliers of organic curry leaves. The NOP’s 

database lists two distinct suppliers of curry leaves, both located in Sri Lanka while the CCOF 

directory lists one domestic source. QAI’s product listing database did not return any results. 

Since curry leaves are an important ingredient in numerous Indian recipes, and it is reported 

that no common ingredient substitution exists, this agricultural item appears to meet the 

requirements defined for “commercially available” in §205.2 in the NOP regulation (appropriate 

form, quality, quantity). As a result, curry leaves are a candidate for listing on §205.606. 

The petitioner indicated that a pest species quarantined in the United States, the Asian citrus 

psyllid, is commonly found on curry leaves in common countries of origin; as a result, imported 

organic curry leaves are not reliably available. A simple internet search for the pest yields 

numerous reliable stories on the quarantines in place. Additionally, the single domestic 

supplier has limited quantities available, well under the quantity claimed to be needed by the 

petitioner. 

Proposal

The Handling Committee recommends the addition of the following substances in this use 

category as published in the final rule:

Murraya koenigii (curry leaves)

Committee Vote
March 31, 2012

Page 2 of 2

Motion to add Murraya koenigii (curry leaves) to §205.606- Nonorganically produced 

agricultural products allowed as ingredients in or on processed products labeled as “organic.”

Motion by: John Foster Second: Joe Dickson

Yes: 5 No: 0 Absent: 1 Abstain: 0 Recuse: 0