Sunset 2017 

NOSB Final Review

Handling Substances §205.605(a)

October 2015

As part of the National List Sunset Review process, the NOSB has evaluated the need for the continued 

allowance for or prohibition of the following substances for use in organic handling.

Reference: 7 CFR 205.605 Nonagricultural (Nonorganic) substances allowed as ingredients in or on 

processed products labeled as ‘‘organic’’ or ‘‘made with organic (specified ingredients or food 

group(s)).’’

§205.605(a) Nonsynthetics allowed:

Acid, Alginic

Acid, Citric

Acid, Lactic

Attapulgite

Bentonite

Calcium carbonate

Calcium chloride

Dairy cultures

Diatomaceous earth

Enzymes

Flavors

Kaolin

Magnesium sulfate

Nitrogen

Oxygen

Perlite

Potassium chloride

Potassium iodide

Sodium bicarbonate

Sodium carbonate

Waxes (Carnauba)

Waxes (Wood rosin)

Yeast

Links to additional references and supporting materials for each substance can be found on the NOP 

website: http://www.ams.usda.gov/rules-regulations/organic/national-list/petitioned
Acid, Alginic

Reference: 205.605(a) Acids (Alginic; Citric – produced by microbial fermentation of carbohydrate 

substances; and Lactic).

Technical Report: 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 10/2010 sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove alginic acid from 205.605(a) 

Motion by: Tracy Favre

Seconded by: Zea Sonnabend 

Yes: 2 No: 11 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Acids – Citric, Lactic

Reference: 205.605(a) Acids (Alginic; Citric – produced by microbial fermentation of carbohydrate 

substances; and Lactic).

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 
Vote

Motion to remove Acids – citric and lactic from 205.605(a)

Motion by: Ashley Swaffar

Seconded by: Tracy Favre

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Attapulgite

Reference: 205.605(a) – as a processing aid in the handling of plant and animal oils.

Technical Report: 2010 TR 

Petition(s): 2009 Attapulgite

Past NOSB Actions: 04/2011 NOSB recommendation

Recent Regulatory Background: Added to National List effective 08/03/2012 [77 FR 45903]

Sunset Date: 08/03/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove attapulgite from 205.605(a)

Motion by: Jean Richardson

Seconded by: Tom Chapman

Yes: 3 No: 11 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Bentonite

Reference: 205.605(a)

Technical Report: 1995 Kaolin Clay and Bentonite

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290), 

Sunset Date: 06/27/17
Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove bentonite from 205.605(a)

Motion by: Jean Richardson

Seconded by: Lisa de Lima

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Calcium carbonate

Reference: 205.605(a)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove calcium carbonate from 205.605(a)

Motion by: Jean Richardson

Seconded by: Tom Chapman

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
Calcium chloride

Reference: 205.605(a)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote 

Motion to remove calcium chloride from 205.605(a)

Motion by: Tracy Favre

Seconded by: Ashley Swaffar 

Yes: 0 No: 12 Abstain: 2 Absent: 0 Recuse: 0

 Outcome: Motion failed. NOSB completed its sunset review.

Dairy cultures

Reference: 205.605(a)

Technical Report: 1995 TAP; 2014 TR for Ancillary Substances

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove Dairy Cultures from 205.605(a)
Motion by: Tom Chapman

Seconded by: Ashley Swaffar

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Diatomaceous earth

Reference: 205.605(a) - food filtering aid only 

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove diatomaceous earth from 205.605(a)

Motion by: Jean Richardson

Seconded by: Tracy Favre

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Enzymes

Reference: 205.605(a) - must be derived from edible, nontoxic plants, nonpathogenic fungi, or 

nonpathogenic bacteria.

Technical Report: 1995 TAP; 1996 TAP; 2011 TR; 2014 TR for Ancillary Substances

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 04/2011 sunset

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17
Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. Ancillary substances were 

not considered within this proposal. 

Vote

Motion to remove enzymes from 205.605(a)

Motion by: Lisa de Lima

Seconded by: Jean Richardson

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Flavors

Reference: 205.605(a), nonsynthetic sources only and must not be produced using synthetic solvents 

and carrier systems or any artificial preservative.

Technical Report: 2005 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 04/2006 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove flavors from 205.605(a)

Motion by: Tom Chapman

Seconded by: Jean Richardson 

Yes: 1 No: 12 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
Kaolin

Reference: 205.605(a)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove kaolin from 205.605(a)

Motion by: Jean Richardson

Seconded by: Ashley Swaffar

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Magnesium sulfate

Reference: 205.605(a) - nonsynthetic sources only.

Technical Report:1995 TAP (Processing); 2011 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 04/2011 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 
Vote

Motion to remove magnesium sulfate from 205.605(a)

Motion by: Jean Richardson

Seconded by: Harold Austin

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Nitrogen

Reference: 205.605(a) - oil-free grades.

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove nitrogen from 205.605(a)

Motion by: Lisa de Lima

Seconded by: Jean Richardson

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Oxygen

Reference: 205.605(a) - oil-free grades.

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)
Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove oxygen from 205.605(a)

Motion by: Lisa de Lima

Seconded by: Ashley Swaffar

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Perlite

Reference: 205.605(a) - for use only as a filter aid in food processing.

Technical Report: 1996 TAP

Petition(s): N/A

Past NOSB Actions: NOSB minutes and vote 09/1996; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove perlite from 205.605(a)

Motion by: Jean Richardson

Seconded by: Ashley Swaffar

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.
Potassium chloride

Reference: (a) Nonsynthetics allowed: 

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote 

Motion to remove potassium chloride from 205.605(a)

Motion by: Tracy Favre

Seconded by: Harold Austin 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Potassium iodide

Reference: 205.605(a)

Technical Report: 1995 TAP; 2011 TR; 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove potassium iodide from 205.605(a)
Motion by: Tracy Favre

Seconded by: Ashley Swaffar 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Sodium bicarbonate

Reference: 205.605(a) 

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove sodium bicarbonate from 205.605(a)

Motion by: Harold Austin

Seconded by: Tracy Favre 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Sodium carbonate

Reference: 205.605(a) 

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17
Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove sodium carbonate from 205.605(a)

Motion by: Harold Austin

Seconded by: Ashley Swaffar 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Waxes (Carnauba)

Reference: 205.605(a) Waxes – nonsynthetic (Carnauba wax; and Wood resin).

Technical Report: 1996 TAP; 2014 TR - Carnauba Wax

Petition(s): N/A

Past NOSB Actions: NOSB minutes and vote 09/1996; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove carnauba wax from 205.605(a)

Motion by: Zea Sonnabend

Seconded by: Harold Austin

Yes: 0 No: 13 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
Waxes (Wood rosin) (sic. resin)

Reference: (a) Nonsynthetics allowed: Waxes—nonsynthetic (Carnauba wax; and Wood resin).

Technical Report: 1996 TAP; 2014 TR - Wood Rosin

Petition(s): N/A

Past NOSB Actions: NOSB minutes and vote 09/1996; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove wood rosin (sic. resin) from 205.605(a)

Motion by: Zea Sonnabend

Seconded by: Harold Austin

Yes: 0 No: 13 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Yeast

Listing: 205.605(a) - When used as food or a fermentation agent, yeast must be organic if its end use is 

for human consumption; nonorganic yeast may be used when equivalent organic yeast is not 

commercially available. Growth on petrochemical substrate and sulfite waste liquor is prohibited. For 

smoked yeast, nonsynthetic smoke flavoring process must be documented.

Technical Report: 1995 TAP (Smoked Yeast); 1995 TAP (Baker’s Yeast); 2014 TR

Petition(s): 2006 Petition; 2010 Petition Supplement; 2010 Petition memo

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290) 

Sunset Date: 10/21/17

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 
Vote

Motion to remove yeast from 205.605(a)

Motion by: Zea Sonnabend

Seconded by: Harold Austin

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.
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Sunset 2017 

NOSB Final Review

Handling Substances §205.605(b)

October 2015

As part of the National List Sunset Review process, the NOSB has evaluated the need for the continued 

allowance for or prohibition of the following substances for use in organic handling.

Reference: 7 CFR 205.605 Nonagricultural (Nonorganic) substances allowed as ingredients in or on 

processed products labeled as ‘‘organic’’ or ‘‘made with organic (specified ingredients or food 

group(s)).’’

§205.605(b) Synthetics allowed:

Acidified sodium chlorite

Alginates

Ammonium bicarbonate

Ammonium carbonate

Ascorbic acid

Calcium citrate

Calcium hydroxide

Calcium phosphates: monobasic, dibasic, 

tribasic

Carbon dioxide

Chlorine Materials: calcium hypochlorite, 

chlorine dioxide, sodium hypochlorite

Ethylene

Ferrous sulfate

Glycerides: mono and di

Glycerin

Hydrogen peroxide

Magnesium carbonate

Magnesium chloride

Magnesium stearate

Nutrient vitamins and minerals

Ozone

Phosphoric acid

Potassium acid tartrate

Potassium carbonate

Potassium citrate

Potassium phosphate

Sodium citrate

Sodium hydroxide

Sodium phosphates

Sulfur dioxide

Tocopherols

Xanthan gum

Links to additional references and supporting materials for each substance can be found on the NOP 

website: http://www.ams.usda.gov/rules-regulations/organic/national-list/petitioned
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Acidified sodium chlorite

Reference: 205.605(b) - Secondary direct antimicrobial food treatment and indirect food contact surface 

sanitizing. Acidified with citric acid only. 

Technical Report: 2008 TAP 

Petition(s): 2006 Sodium Chlorite, Acidified

Past NOSB Actions: 2009 NOSB recommendation 

Recent Regulatory Background: Added to NL effective 03/15/2012 (77 FR 8089)

Sunset Date: 03/15/17

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove acidified sodium chlorite from 205.605(b)

Motion by: Ashley Swaffar

Seconded by: Tom Chapman

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Alginates

Reference: 205.605(b) Synthetics allowed

Technical Report: 1995 TAP

Petition(s): 1995 Alginates

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

from the National List. 

Vote

Motion to remove alginates from 205.605(b)

Motion by: Tracy Favre

Seconded by: Ashley Swaffar 

Yes: 2 No: 11 Abstain: 0 Absent: 1 Recuse: 0

 Outcome: Motion failed. NOSB completed its sunset review.

Ammonium bicarbonate

Reference: 205.605(b) - for use only as a leavening agent

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of Ammonium bicarbonate. This material 

still continues to satisfy all OFPA criteria, and public comment confirmed its current use and need. All 

comments, oral and written supported the re-listing of this material. There were none opposed.

Vote

Motion to remove ammonium bicarbonate from 205.605(b)

Motion by: Harold Austin

Seconded by: Ashley Swaffar 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Ammonium carbonate

Reference: 205.605(b) –for use only as a leavening agent

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of Ammonium carbonate. This material still 

continues to satisfy all OFPA criteria, and public comment confirmed its current use and need. During 

the 1st public comment period there were no comments either in support or against re-listing this 

material. One comment during the 2nd public comment period raised concerns about this lack of 

comment, but there were other comments submitted in support of this material continuing to remain 

on the National List, which helped to alleviate those previous concerns.

Vote

Motion to remove ammonium carbonate from 205.605(b)

Motion by: Harold Austin

Seconded by: Ashley Swaffar 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Ascorbic acid

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Vote

Motion to remove ascorbic acid from 205.605(b)

Motion by: Tracy Favre

Seconded by: Ashley Swaffar 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Calcium citrate

Reference: 205.605(b)

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove calcium citrate from 205.605(b)

Motion by: Ashley Swaffar

Seconded by: Tracy Favre 

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Calcium hydroxide

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove calcium hydroxide from 205.605(b)

Motion by: Jean Richardson

Seconded by: Tracy Favre

Yes: 0 No: 13 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Calcium phosphates (monobasic, dibasic, and tribasic) 

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

Public comment from organic handling stakeholders provided both in written comments and by oral 

testimony showed a strong continued support for re-listing, as well as an overall continued need. 

However, there were also several comments that raised a concern regarding the cumulative effect on 

human health associated with the use of inorganic forms of phosphates as a whole, caused by an overall 

increase in usage. Other comments argued against the validity of those claims.

The NOSB supported (in a split vote) the continued listing of these materials, while discussing the need 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

for the Handling subcommittee to continue to look into the concerns raised and comeback to the full 

NOSB with any further additional information that they could provide on this matter, after conducting 

further research looking into the concerns raised. 

Vote

Motion to remove Calcium Phosphates (monobasic, dibasic, and tribasic) from 205.605(b)

Motion by: Harold Austin

Seconded by: Jean Richardson

Yes: 2 No: 10 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Carbon dioxide

Reference: 205.605(b)

Technical Report: 1995 TAP; 2006 TAP

Petition(s): 2007 Carbon Dioxide

Past NOSB Actions: 10/1995 NOSB minutes and vote; 2007 NOSB Committee recommendation;

11/2005 sunset recommendation; 10/2010 sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove carbon dioxide from 205.605(b)

Motion by: Lisa de Lima

Seconded by: Ashley Swaffar

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Chlorine materials

Reference: 205.605(b) Chlorine materials - disinfecting and sanitizing food contact surfaces, Except,

That, residual chlorine levels in the water shall not exceed the maximum residual disinfectant limit 

under the Safe Drinking Water Act (Calcium hypochlorite; Chlorine dioxide; and Sodium hypochlorite).

Technical Report: 2006 TR - Handling

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 04/2006 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

While there are some concerns about the relisting of this material from NGO’s, chlorine has been used 

for many years as a sanitizer and is necessary in the organic industry for proper sanitation. The majority 

of the NOSB supported the continued listing of Chlorine Materials. The NOSB finds this material 

compliant with OFPA criteria, and does not recommend removal from the National List. 

Vote

Motion to remove chlorine materials from 205.605(b)

Motion by: Ashley Swaffar

Seconded by: Jean Richardson

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Ethylene

Reference: 205.605(b) allowed for postharvest ripening of tropical fruit and degreening of citrus.

Technical Report: 1995 TAP; 1999 TAP - Processing

Petition(s): 1995 N/A, 2008 Ethylene (for use with pears)

Past NOSB Actions: 10/1995 NOSB minutes and vote; 10/1999 NOSB minutes and vote (add tropical 

fruit and citrus); 11/2005 sunset recommendation; 11/2008 recommendation for pears; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove ethylene from 205.605(b)

Motion by: Lisa de Lima

Seconded by: Jean Richardson

Yes: 3 No: 11 Abstain: 0 Absent: 1 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Ferrous sulfate

Reference: 205.605(b) - for iron enrichment or fortification of foods when required by regulation or 

recommended (independent organization).

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove ferrous sulfate from 205.605(b)

Motion by: Tracy Favre

Seconded by: Ashley Swaffar 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Glycerides (mono and di)

Reference: 205.605(b) for use only in drum drying of food. 

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that the substance itself is necessary for dried 

potato and other vegetable and fruit products. Those in favor of removal raised human health concerns. 

The majority of the NOSB concluded that it meets the criteria in OFPA, is not available in an organic 

form and should be renewed.

Vote

Motion to remove glycerides (mono and di) from 205.605(b)

Motion by: Jean Richardson

Seconded by: Harold Austin

Yes: 6 No: 8 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Glycerin

Reference: 205.605(b) - produced by hydrolysis of fats and oils. 

Technical Report: 1995 TAP; 2013 TR

Petition(s): 1995 N/A, Glycerin (2012 Petition to remove)

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. The NOSB notes it recommended in the April 2015 to remove Glycerin from 

205.605(b) and add to 205.606. The NOSB continues to support its April 2015 recommendation but is 

conduction the sunset review to ensure continuity during rulemaking. 

Vote

Motion to remove glycerin from 205.605(b) based its unanimous vote in April 2015 to reclassify Glycerin 

as agricultural and List it at 205.606.

Motion by: Jean Richardson

Seconded by: Harold Austin 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Hydrogen peroxide

Reference: 205.605(b)

Technical Report: N/A for handling use

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove hydrogen peroxide from 205.605(b)

Motion by: Ashley Swaffar

Seconded by: Tracy Favre 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Magnesium Carbonate

Reference: 205.605(b) - for use only in agricultural products labeled “made with organic (specified 

ingredients or food group(s)),” prohibited in agricultural products labeled “organic”.

Technical Report: 1996 TAP

Petition(s): Magnesium Carbonate (2005)

Past NOSB Actions: 09/1996 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material is no longer necessary for organic production and therefore no 

long meets OFPA criteria. The NOSB recommends removal from the National List. 

Vote

Motion to remove magnesium carbonate from 205.605(b)

Motion by: Jean Richardson

Seconded by: Harold Austin

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion passed. NOSB completed its sunset review and recommended removal of Magnesium 

Carbonate.

Magnesium chloride

Reference: 205.605(b) – derived from sea water.

Technical Report: 1995 TAP

Petition(s):N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 10/1999 NOSB minutes and vote; 11/2005 

sunset recommendation; 10/2010 sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

NOSB Review:

The NOSB completed the sunset review for this material. Some commenters noted this items should be 

reclassified as non-agricultural and usage be restricted to usage only as a coagulant in production of 

tofu. Based on the Subcommittee review and public comment, the NOSB finds this material compliant 

with OFPA criteria, and does not recommend removal from the National List. 

Vote

Motion to remove magnesium chloride from 205.605(b)

Motion by: Jean Richardson

Seconded by: Harold Austin

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Magnesium stearate

Reference: 205.605(b) - for use only in agricultural products labeled “made with organic (specified 

ingredients or food group(s)),” prohibited in agricultural products labeled “organic”.

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove magnesium stearate from 205.605(b)

Motion by: Jean Richardson

Seconded by: Tracy Favre

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Nutrient vitamins and minerals

Reference: 205.605(b) Nutrient vitamins and minerals, in accordance with 21 CFR 104.20, Nutritional 

Quality Guidelines For Foods. 

Technical Report: 1995 TAP - Minerals; 1995 TAP - Vitamins; 2015 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 03/2011 

Handling Subcommittee Proposal; 04/2011 sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 10/21/2017

Subcommittee Review

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that these substances are widely used, critical and 

in some cases required by other regulations in organic processed products. Those in favor of removal 

noted previous NOSB recommendations recommending changes in the annotation that have not yet 

completed rulemaking. The NOSB has requested to add nutrient vitamins and minerals to its work 

agenda for 2016. The majority of the NOSB concluded that it meets the criteria in OFPA, is not available 

in an organic form and should be renewed.

Vote

Motion to remove nutrient vitamins and minerals from 205.605(b)

Motion by: Zea Sonnabend

Seconded by: Harold Austin

Yes: 6 No: 8 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Ozone

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove ozone from 205.605(b)

Motion by: Ashley Swaffar

Seconded by: Zea Sonnabend

Yes: 0 No: 13 Abstain: 0 Absent: 1 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Phosphoric acid

Reference: 205.605(b) - cleaning of food-contact surfaces and equipment only

Technical Report: 2003 TAP

Petition(s):N/A

Past NOSB Actions: 10/1999 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove phosphoric acid from 205.605(b)

Motion by: Ashley Swaffar

Seconded by: Zea Sonnabend

Yes: 1 No: 12 Abstain: 0 Absent: 1 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Potassium acid tartrate

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove potassium acid tartrate from 205.605(b)

Motion by: Jean Richardson

Seconded by: Tracy Favre

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Potassium carbonate

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove potassium carbonate from 205.605(b)

Motion by: Jean Richardson

Seconded by: Tracy Favre 

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Potassium citrate

Reference: 205.605(b)

Technical Report: 1995 TAP; 2015 TR

Petition(s):N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove potassium citrate from 205.605(b)

Motion by: Jean Richardson

Seconded by: Ashley Swaffar

Yes: 1 No: 13 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Potassium phosphate

Reference: 205.605(b) - for use only in agricultural products labeled “made with organic (specific 

ingredients or food group(s)),” prohibited in agricultural products labeled “organic”. 

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

Public comment from organic handling stakeholders provided both in written comments and by oral 

testimony showed a strong continued support for re-listing, as well as an overall continued need. 

However, there were also several comments that raised a concern regarding the cumulative effect on 

human health associated with the use of inorganic forms of phosphates as a whole, caused by an overall 

increase in usage. Other comments argued against the validity of those claims.

The NOSB supported (in a split vote) the continued listing of these materials, while discussing the need 

for the Handling subcommittee to continue to look into the concerns raised and comeback to the full 

NOSB with any further additional information that they could provide on this matter, after conducting 

further research looking into the concerns raised. 

Vote

Motion to remove potassium phosphate from 205.605(b)

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 2 No: 9 Abstain: 3 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Sodium citrate

Reference: 205.605(b)

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove sodium citrate from 205.605(b)

Motion by: Ashley Swaffar

Seconded by: Tracy Favre 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.

Sodium hydroxide

Reference: 205.605(b) - prohibited for use in lye peeling of fruits and vegetables.

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 sunset 

recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove sodium hydroxide from 205.605(b)
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Motion by: Jean Richardson

Seconded by: Harold Austin

Yes: 0 No: 13 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Sodium phosphates

Reference: 205.605(b) - for use only in dairy foods.

Technical Report: 2001 TAP

Petition(s): 1995 N/A, 2001 Sodium Phosphate

Past NOSB Actions: 10/1995 NOSB minutes and vote; 10/2001 NOSB minutes and vote; 11/2005 sunset 

recommendation; 10/2010 sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

Public comment from organic handling stakeholders provided both in written comments and by oral 

testimony showed a strong continued support for re-listing, as well as an overall continued need. 

However, there were also several comments that raised a concern regarding the cumulative effect on 

human health associated with the use of inorganic forms of phosphates as a whole, caused by an overall 

increase in usage. Other comments argued against the validity of those claims. The necessity of sodium 

phosphate was also questioned as it was not always used in cited dairy applications.

The NOSB supported (in a split vote) the continued listing of these materials, while discussing the need 

for the Handling subcommittee to continue to look into the concerns raised and comeback to the full 

NOSB with any further additional information that they could provide on this matter, after conducting 

further research looking into the concerns raised. 

Vote

Motion to remove sodium phosphates from 205.605(b)

Motion by: Jean Richardson

Seconded by: Harold Austin 

Yes: 2 No: 11 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Sulfur dioxide

Reference: 205.605(b) for use only in wine labeled “made with organic grapes,” Provided, That, total 

sulfite concentration does not exceed 100 ppm. 

Technical Report: 1995 TAP; 2011 TR

Petition(s): 1995 N/A; 2010 Sulfur Dioxide

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation; 12/2011 petition review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB completed the sunset review for this material. Based on the Subcommittee review and public 

comment, the NOSB finds this material compliant with OFPA criteria, and does not recommend removal 

from the National List. 

Vote

Motion to remove sulfur dioxide from 205.605(b)

Motion by: Tom Chapman

Seconded by: Harold Austin 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Tocopherols

Reference: 205.605(b) derived from vegetable oil when rosemary extracts are not a suitable alternative

Technical Report: 1995 TAP; 2015 limited scope TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 04/2011 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that the substance itself is critical to organic 

production. Those in favor of removal noted non-synthetic version were available and wanted the listing 

changed to non-synthetic. The majority of the NOSB concluded that it meets the criteria in OFPA, is not 

available in an organic form and should be renewed.

Vote

Motion to remove tocopherols from 205.605(b)

Motion by: Tracy Favre

Seconded by: Ashley Swaffar 

Yes: 4 No: 9 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Xanthan gum

Reference: 205.605(b)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 06/27/2017

Subcommittee Review

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that the substance itself is critical to the 

production of several organic products. Those in favor of removal questioned its necessity. The majority 

of the NOSB concluded that it meets the criteria in OFPA, is not available in an organic form and should 

be renewed.

Vote

Motion to remove xanthan gum from 205.605(b)

Motion by: Zea Sonnabend

Seconded by: Harold Austin

Yes: 5 No: 8 Abstain: 1 Absent: 0 Recuse: 0 

Outcome: Motion failed. NOSB completed its sunset review.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Sunset 2017 

NOSB Final Review

Handling Substances §205.606

October 2015

As part of the National List Sunset Review process, the NOSB has evaluated the need for the continued 

allowance for or prohibition of the following substances for use in organic handling.

Reference: 7 CFR §205.606 Nonorganically produced agricultural products allowed as ingredients in or 

on processed products labeled as “organic.”

Casings

Celery powder

Chia (Salvia hispanica L.)

Colors (proposed removals)

Colors (proposed relisting)

Dillweed oil

Fish oil

Fructooligosaccharides

Galangal, frozen

Gelatin

Gums: Arabic, Carob bean, Guar, Locust bean

Inulin-oligofructose enriched

Kelp

Konjac flour

Lecithin—de-oiled

Lemongrass-frozen

Orange pulp, dried

Orange Shellac - unbleached

Pectin (non-amidated forms only)

Peppers (Chipotle chile)

Seaweed, Pacific kombu

Starches, Cornstarch (native), Sweet potato

Turkish bay leaves

Wakame seaweed (Undaria pinnatifida)

Whey protein concentrate

Links to additional references and supporting materials for each substance can be found on the NOP 

website: http://www.ams.usda.gov/rules-regulations/organic/national-list/petitioned
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Casings

Reference: 205.606(a) casings, from processed intestines

Technical Report: N/A

Petition(s): 2006 Petition

Past NOSB Actions: 04/2007 NOSB recommendation; 10/2010 NOSB sunset recommendation 

Recent Regulatory Background: Added to NL effective 06/21/07 (72 FR 35137); Sunset renewal notice 

published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote

Motion to remove Casings from 205.606(a)

Motion by: Jean Richardson

Seconded by: Tracy Favre

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Celery powder

Reference: 205.606(b) 

Technical Report: N/A

Petition(s): 2007 Petition

Past NOSB Actions: 04/2007 NOSB recommendation; 10/2010 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that the substance itself is critical to the 

production of several traditional processed meat products and that efforts made to find organic 

alternatives have been unsuccessful. Those in favor of removal questioned if the production methods 

were compatible with organic production. The majority of the NOSB concluded that it meets the criteria 

in OFPA, is not available in an organic form and should be renewed.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Vote 

Motion to remove celery powder from 205.606(b)

Motion by: Tom Chapman

Seconded by: Ashley Swaffar

Yes: 5 No: 9 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Chia (Salvia hispanica L.)

Reference: 205.606(c)(Salvia hispanica L.)

Technical Report: N/A

Petition(s): 2007 Petition

Past NOSB Actions: 03/2007 NOSB recommendation; 10/2010 NOSB sunset recommendation 

Recent Regulatory Background: : Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB found this material is available from organic sources and no longer needs to be listed. 

Vote 

Motion to remove Chia (Salvia hispanica L) from 205.606(c)

Motion by: Tom Chapman

Seconded by: Zea Sonnabend 

Yes: 12 No: 1 Abstain: 0 Absent: 1 Recuse: 0

Outcome: Motion passed. NOSB completed its sunset review and recommended removal of Chia (Salvia 

hispanica L) from 205.606(c)

Colors - Beet juice extract color, Black Currant juice color, Black/Purple Carrot Juice color,

Blueberry Juice color, Carrot Juice color, Cherry Juice color, Chokeberry/Aronia Juice 

color, Elderberry Juice color, Grape Juice color, Grape Skin Extract color, Paprika color, 

Pumpkin Juice color, Purple Potato juice color, Red Cabbage Extract color, Red radish 

Extract color, Saffron Extract color, Turmeric Extract color

Reference: 205.606(d) Colors derived from agricultural products - Must not be produced using synthetic

solvents and carrier systems or any artificial preservative

 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

(1) Beet juice extract color (pigment CAS #7659-95-2)

(3) Black currant juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-30-7, 

and 134-04-3)

(4) Black/Purple carrot juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-

30-7, and 134-04-3)

(5) Blueberry juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-30-7, and 

134-04-3)

(6) Carrot juice color (pigment CAS #1393-63-1)

(7) Cherry juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-30-7, and 134-

 04-3)

(8) Chokeberry—Aronia juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-

30-7, and 134-04-3)

(9) Elderberry juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-30-7, and 

134-04-3)

(10) Grape juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-30-7, and 

134-04-3)

(11) Grape skin extract color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-30-7, 

and 134-04-3)

(12) Paprika color (CAS #68917-78-2)—dried, and oil extracted

(13) Pumpkin juice color (pigment CAS #127-40-2)

(14) Purple potato juice (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-30-7, and 

134- 04-3)

(15) Red cabbage extract color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-30-7, 

and 134-04-3)

(16) Red radish extract color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-30-7, 

and 134-04-3

(17) Saffron extract color (pigment CAS #1393-63-1).

(18) Turmeric extract color (CAS #458-37-7)

Technical Report: 2015 TR - Colors (all)

Petition(s): 2007 Petition

Past NOSB Actions: 04/2007 NOSB recommendation; 10/2010 NOSB sunset recommendation

Recent Regulatory Background: Added to NL effective 06/21/07 (72 FR 35137); Sunset renewal notice 

published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that colors were not clearly available in an organic 

form and that commercial availability criteria will force handlers to use organic versions when available. 

Those in favor of removal questioned why products were not available in organic forms if similar raw 

materials are commonly farmed organically. Votes on each color material varied but no single color 

received enough votes to be removed. The NOSB concluded that these materials continue to meet the 

criteria in OFPA and are not available in an organic form and therefore should be renewed. The NOSB 

urges producers to strengthen the commercial availability of organic colors and recommends future 

NOSBs do not renew colors in whole on 205.606.

Vote

Motion to remove beet juice extract color (pigment CAS #7659-95-2) from 205.606

Motion by: Jean Richardson

Seconded by: Zea Sonnabend 

Yes: 6 No: 6 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove black currant juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 

1429-30-7, and 134-04-3) from 205.606

Motion by: Jean Richardson

Seconded by: Zea Sonnabend 

Yes: 3 No: 6 Abstain: 5 Absent: 0 Recuse: 0

Vote

Motion to remove black/purple carrot juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-

01-0, 1429-30-7, and 134-04-3) from 205.606

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 2 No: 10 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove blueberry juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-

30-7, and 134-04-3) from 205.606

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 5 No: 5 Abstain: 4 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Vote

Motion to remove carrot juice color (pigment CAS #1393-63-1) from 205.606

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 4 No: 7 Abstain: 3 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove cherry juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-30-

7, and 134-04-3) from 205.606

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 3 No: 9 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove chokeberry—aronia juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-

01-0, 1429-30-7, and 134-04-3) from 205.606

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 7 No: 5 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove elderberry juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 

1429-30-7, and 134-04-3) from 205.606

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 7 No: 5 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove grape juice color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-30-

7, and 134-04-3) from 205.606
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 7 No: 5 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove grape skin extract color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 

1429-30-7, and 134-04-3) from 205.606

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 6 No: 6 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove paprika color (CAS #68917-78-2)—dried, and oil extracted from 205.606

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 5 No: 7 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove pumpkin juice color (pigment CAS #127-40-2) from 205.606

Motion by: Jean Richardson

Seconded by: Zea Sonnabend 

Yes: 2 No: 11 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove purple potato juice (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 1429-

30-7, and 134-04-3) from 205.606

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 5 No: 7 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove red cabbage extract color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

1429-30-7, and 134-04-3) from 205.606

Motion by: Jean Richardson

Seconded by: Zea Sonnabend 

Yes: 2 No: 11 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove red radish extract color (pigment CAS #'s: 528-58-5, 528-53-0, 643-84-5, 134-01-0, 

1429-30-7, and 134-04-3) from 205.606

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 6 No: 6 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove saffron extract color (pigment CAS #1393-63-1) from 205.606

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 7 No: 5 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Vote

Motion to remove Turmeric extract color (CAS #458-37-7) from 205.606

Motion by: Jean Richardson

Seconded by: Lisa de Lima 

Yes: 3 No: 9 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Dillweed oil

Reference: 205.606(e) Dillweed oil (CAS # 8006-75-5)

Technical Report: none

Petition(s): 2006 Petition

Past NOSB Actions: 2007 NOSB recommendation; 10/2010 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Subcommittee Review

NOSB Review:

The NOSB found this material is available as organic and no longer needs to be listed. 

Vote 

Motion to remove dillweed oil from 205.606(e)

Motion by: Tom Chapman

Seconded by: Harold Austin 

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion passed. NOSB completed its sunset review and recommended removal of dillweed oil 

from 205.606(e)

Fish oil

Reference: 205.606(f) Fish oil (Fatty acid CAS #'s: 10417-94-4, and 25167-62-8) - stabilized with organic 

ingredients or only with ingredients on the National List, §§205.605 and 205.606

Technical Report: 2015 TR

Petition(s): 2007 Petition

Past NOSB Actions: 04/2007 NOSB recommendation; 10/2010 NOSB sunset recommendation 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that the substance is widely used in current organic 

products and organic version are not available. Those in favor of removal questioned the necessity of 

the material and raised concerns about impacts on the environment. The NOSB noted marine products 

used in organic production and handling should be reviewed holistically. A 2/3 majority was not 

reached to remove the material therefore the NOSB concludes that this material continues to meets the 

criteria in OFPA, is not available in an organic form and should be renewed.

Vote 

Motion to remove fish oil from 205.606(f)

Motion by: Jean Richardson

Seconded by: Lisa de Lima

Yes: 8 No: 5 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Fructooligosaccharides 

Reference: 205.606(h) Fructooligosaccharides (CAS # 308066-66-2)

Technical Report: 2006 TAP; 2015 TR

Petition(s): 2006 Petition

Past NOSB Actions: 04/2007 NOSB recommendation; 10/2010 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that the substance is not currently available in an 

organic form. Those in favor of removal questioned the necessity of the material. A 2/3 majority was 

not reached to remove the material, therefore the NOSB concludes that this material continues to 

meets the criteria in OFPA, is not available in an organic form and should be renewed.

Vote 

Motion to remove Fructooligosaccharides from 205.606(h)

Motion by: Tom Chapman

Seconded by: Lisa de Lima 

Yes: 8 No: 6 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Galangal, frozen 

Reference: 205.606(i) Galangal, frozen

Technical Report: none

Petition(s): 2006 Petition

Past NOSB Actions: 04/2007 NOSB recommendation; 10/2010 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB found this material is available from organic sources and no longer needs to be listed. 

Vote 

Motion to remove galangal, frozen from 205.606(i)

Motion by: Tom Chapman
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Seconded by: Ashley Swaffar 

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion passed. NOSB completed its sunset review and recommended removal of galangal, 

frozen from 205.606(i)

Gelatin 

Reference: 205.606(j) Gelatin (CAS # 9000-70-8)

Technical Report: 2002 TAP

Petition(s): 2001 Petition; 2007 Petition

Past NOSB Actions: 05/2002 NOSB recommendation for addition to the National List; 10/2010 NOSB 

sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote 

Motion to remove gelatin from 205.606(j) 

Motion by: Zea Sonnabend

Seconded by: Jean Richardson 

Yes: 3 No: 9 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Gums: (Arabic, Guar, Locust bean , and Carob bean)

Reference: 205.606(k) Gums - water extracted only (Arabic; Guar; Locust bean; and Carob bean)

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 10/2010 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote 

Motion to remove Gums - water extracted only (Arabic; Guar; Locust bean; and Carob bean) from 

205.606(k) 

Motion by: Zea Sonnabend

Seconded by: Ashley Swaffar 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Inulin-oligofructose enriched 

Reference: 205.606(l) Inulin-oligofructose enriched (CAS # 9005-80-5)

Technical Report: 2015 TR

Petition(s): 2007 Petition

Past NOSB Actions: 04/2007 recommendation; 2010 NOSB sunset recommendation 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB found this inulin is available from organic sources. Oligofructose (Fructooligosaccharides) 

are listed separately. Therefore The NOSB found this inulin is available as organic and no longer needs 

to be listed.

Vote 

Motion to remove inulin-oligofructose enriched from 205.606(l)

Motion by: Tom Chapman

Seconded by: Jean Richardson

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion passed. NOSB completed its sunset review and recommended removal of inulinoligofructose enriched from 205.606(l)

Kelp 

Reference: 205.606(m) Kelp—for use only as a thickener and dietary supplement.

Technical Report: 1995 TAP
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB recommendation; 10/2010 NOSB sunset recommendation 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that the substance is not currently available in an 

organic form. Those in favor of removal questioned the availability given organic kelp is available as a 

livestock feed. The NOSB noted marine products used in organic production and handling should be 

reviewed holistically. The majority of the NOSB concluded that it meets the criteria in OFPA, is not 

available in an organic form and should be renewed.

Vote 

Motion to remove Kelp from 205.606(m)

Motion by: Tracy Favre

Seconded by: Harold Austin

Yes: 4 No: 8 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Konjac flour 

Reference: 205.606(n) Konjac flour (CAS # 37220-17-0).

Technical Report: None

Petition(s): 2001 Petition

Past NOSB Actions: 05/2002 NOSB minutes (determined to be agricultural); 10/2010 NOSB sunset 

recommendation

Recent Regulatory Background: 2007 Interim Rule (72 FR 35137); Sunset renewal notice published 

06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that there is insufficient information to show the 

substance is available in an organic form. Those in favor of removal argued the product was available in 

an organic form internationally. A 2/3 majority was not reached to remove the material, therefore the 

NOSB concludes that this material continues to meets the criteria in OFPA, is not available in an organic 

form and should be renewed.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Vote 

Motion to remove konjac flour from §205.606(n)

Motion by: Zea Sonnabend

Seconded by: Harold Austin 

Yes: 9 No: 5 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Lecithin -de-oiled 

Reference: 205.606(o) Lecithin—de-oiled.

Technical Report: 1995 TAP; 2009 TR

Petition(s): Lecithin, bleached (remove 2008)

Past NOSB Actions: 04/1995 minutes and vote; 05/2009 recommendation (remove from 605b);

05/2009 Recommendation (amend 606)

Recent Regulatory Background: Annotation change effective 03/15/2012 (77 FR 8089)

Sunset Date: 03/15/17

Subcommittee Review

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that there is was insufficient supply in an organic 

form, specifically from raw materials other than soy. Additionally other sources were not yet in 

production and were located in a country under political turmoil. Those in favor of removal argued the 

product was available in an organic form internationally. The majority of the NOSB concluded that it 

meets the criteria in OFPA, is not available in an organic form and should be renewed. 

Vote 

Motion to remove Lecithin - de-oiled from §205.606

Motion by: Zea Sonnabend

Seconded by: Jean Richardson 

Yes: 5 No: 9 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

 Lemongrass 

Reference: 205.606(p) Lemongrass - frozen.

Technical Report: N/A

Petition(s): 2006 Petition

Past NOSB Actions: 04/2007 recommendation; 10/2010 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB found this material is available from organic sources and no longer needs to be listed. 

Vote 

Motion to remove lemongrass - frozen from 205.606(p) 

Motion by: Tom Chapman

Seconded by: Ashley Swaffar 

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion passed. NOSB completed its sunset review and recommended removal of lemongrass 

- frozen from 205.606(p)

Orange pulp, dried 

Reference: 205.606(q) Orange pulp, dried.

Technical Report: N/A

Petition(s): 2008 Petition

Past NOSB Actions: 11/2008 NOSB recommendation for addition to the National List

Recent Regulatory Background: Added to NL effective 03/15/2012 (77 FR 8089)

Sunset Date: 03/15/17

Subcommittee Review

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that the material is not available in an organic 

form. Those in favor of removal argued that the product was not necessary given no organic handler 

commented in favor of the material. A 2/3 majority was not reached to remove the material, therefore 

the NOSB concludes that this material continues to meet the criteria in OFPA, is not available in an 

organic form and should be renewed.

Vote 

Motion to remove orange pulp, dried, from 205.606(q)

Motion by: Tom Chapman

Seconded by: Jean Richardson

Yes: 5 No: 7 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Orange shellac 

Reference: 205.606(r) Orange shellac-unbleached (CAS # 9000-59-3).

Technical Report: 2002 TAP; 2014 TR

Petition(s): N/A

Past NOSB Actions: 10/1999 NOSB minutes and vote; 10/2010 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote 

Motion to remove Orange Shellac from 205.606(r)

Motion by: Zea Sonnabend

Seconded by: Harold Austin 

Yes: 0 No: 13 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Pectin 

Reference: 205.606(s) Pectin (non-amidated forms only).

Technical Report: 1995 TAP; 2009 TR; 2010 supplemental TR; 2015 TR (limited scope)

Petition(s): 2005 Petition – low methoxy pectins

Past NOSB Actions: 04/1995 minutes and vote; 11/2005 sunset recommendation; 10/2010 NOSB 

recommendation on petition

Recent Regulatory Background: Sunset Review effective 06/27/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote 

Motion to remove Pectin (non-amidated forms only) from §205.606(s)

Motion by: Zea Sonnabend

Seconded by: Jean Richardson 

Yes: 0 No: 14 Abstain: 0 Absent: 0 Recuse: 0
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Outcome: Motion failed. NOSB completed its sunset review.

Peppers (Chipotle chile) 

Reference: 205.606(t) Peppers (Chipotle chile)

Technical Report: N/A

Petition(s): 2006/2007 Petition

Past NOSB Actions: 04/2007 NOSB recommendation; 10/2010 NOSB sunset recommendation 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB found this material is available from organic sources and no longer needs to be listed. 

Vote 

Motion to remove peppers (chipotle chile) from §205.606(t)

Motion by: Tom Chapman

Seconded by: Lisa de Lima

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion passed. NOSB completed its sunset review and recommended removal of peppers 

(chipotle chile) from §205.606(t)

 Seaweed, Pacific kombu 

Reference: 205.606(u) Seaweed, Pacific kombu

Technical Report: N/A

Petition(s): 2007 Petition

Past NOSB Actions: 05/2008 NOSB recommendation

Recent Regulatory Background: Added to NL effective 03/15/12 (77 FR 8089)

Sunset Date: 03/15/17

Subcommittee Review

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that the substance is not currently available in an 

organic form. Those in favor of removal questioned the availability given organic seaweed is available as 
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

a livestock feed. The NOSB noted marine products used in organic production and handling should be 

reviewed holistically. The majority of the NOSB concluded that it meets the criteria in OFPA, is not 

available in an organic form and should be renewed.

Vote 

Motion to remove seaweed, Pacific kombu from §205.606(u)

Motion by: Tracy Favre

Seconded by: Ashley Swaffar

Yes: 1 No: 11 Abstain: 2 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Starches; cornstarch, sweet potato 

Reference: 205.606(v) Starches.

(1) Cornstarch (native).

(2) Sweet potato starch - for bean thread production only.

Technical Report: 1995 TAP - Cornstarch

Petition(s): N/A – Cornstarch; 2007 Petition - Sweet Potato Starch

Past NOSB Actions: 10/1995 NOSB minutes and vote; 10/2010 sunset review Sweet potato starch; 

10/2010 sunset recommendation on cornstarch 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB found no concerns regarding the continued listing of this material. This material satisfies all 

OFPA criteria, and public comment confirmed its current use and need. 

Vote 

Motion to remove cornstarch (native), and sweet potato starch from §205.606(v)

Motion by: Zea Sonnabend

Seconded by: Harold Austin 

Yes: 2 No: 12 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Turkish bay leaves 

Reference: 205.606(x) Turkish bay leaves.

Technical Report: N/A

Petition(s): 2006 Petition

Past NOSB Actions: 04/2007 recommendation; 10/2010 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB found this material is available from organic sources and no longer needs to be listed. 

Vote 

Motion to remove turkish bay leaves from 205.606(x)

Motion by: Tom Chapman

Seconded by: Lisa de Lima

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion passed. NOSB completed its sunset review and recommended removal of turkish bay 

leaves from 205.606(x)

Wakame seaweed 

Reference: 205.606(y) Wakame seaweed (Undaria pinnatifida).

Technical Report: N/A

Petition(s): 2007 Petition

Past NOSB Actions: 04/2007 NOSB recommendation; 10/2010 NOSB sunset recommendation

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB reviewed the points in favor of renewing the substance as well as those in favor of removal 

from the list. Those in favor of renewing pointed out that the substance is not currently available in an 

organic form. Those in favor of removal questioned the availability given organic seaweed is available as 

a livestock feed. The NOSB noted marine products used in organic production and handling should be 

reviewed holistically. The majority of the NOSB concluded that it meets the criteria in OFPA, is not 

available in an organic form and should be renewed.
National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture

Vote 

Motion to remove Wakame seaweed from 205.606(y)

Motion by: Tracy Favre

Seconded by: Ashley Swaffar 

Yes: 1 No: 12 Abstain: 1 Absent: 0 Recuse: 0

Outcome: Motion failed. NOSB completed its sunset review.

Whey protein concentrate 

Reference: 205.606(z) Whey protein concentrate.

Technical Report: 2015 TR

Petition(s): 2007 Petition

Past NOSB Actions: 05/2007 NOSB recommendation; 10/2010 NOSB sunset recommendation 

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290)

Sunset Date: 6/27/2017

Subcommittee Review

NOSB Review:

The NOSB found this material is available from organic sources and no longer needs to be listed. 

Vote 

Motion to remove whey protein concentrate (WPC) from 205.606(z)

Motion by: Tom Chapman

Seconded by: Jean Richardson

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Outcome: Motion passed. NOSB completed its sunset review and recommended removal of whey 

protein concentrate (WPC) from 205.606(z)