Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

Date: May 25, 2012

Subject: Petition to add Citrus hystrix leaves and fruit 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 Citrus hystrix leaves and fruit are agricultural.

Vote: 15 yes 0 no

Listing Motion: 1. Move to add Citrus hystrix leaves and fruit to the National List 

205.606.

 Vote: 12 yes 2 no 1 abstain

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): Considerations of commercial availability as defined in under 

§205.2 (appropriate form, quality, quantity) indicate that Citrus hystrix is not 

commercially available for organic producers in the quantity required and should 

be listed on §205.606.

Committee Vote-Classsification:

Moved: John Foster Second: Jean Richardson

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

Committee Vote-Listing:

Moved: John Foster Second: Joe Dickson

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

Handling Committee

Petition Proposal

Citrus hystrix leaves and fruit

March 31, 2012

Introduction

A petition has been received to add the leaves and fruit of Citrus hystrix to §205.606- Nonorganically 

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

“organic.” The species is also known by several common names including kieffer lime, kaffir lime, and 

makrut lime.

Background

Citrus hystrix leaves and fruit are traditional ingredients in Lao and Thai cuisine/curries. The 

ingredient is known for its “bumpy” skin and for imparting a unique intense flavor and aroma in foods 

(particularly curries) due to its high concentration of essential oils. Citrus hystrix is not a common crop 

in the United States; and is limited in its potential to be cultivated in that there a plant quarantine 

exists from the USDA due to citrus greening disease (Asian citrus psyllid) and the threat of spreading 

this debilitating plant disease throughout the country. Citrus greening disease is not limited to Citrus 

hystrix and it may be spread to other varieties of citrus. Due to this threat of disease, and the 

relatively unknown status of the ingredient in cuisines most common in the United States, this plant 

and its products are currently not well known or propagated.

Relevant areas in the Rule

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

products labeled as “organic.”

Discussion

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

directories (CCOF) have yielded exceedingly few suppliers for Citrus hystrix fruit or its products. The 

NOP database was the only source that identified a supplier (two distinct organic certificates but one 

farm name) that has these items listed in the NOP database. Given the limited supply availability, and 

the threat of spreading the area afflicted by citrus greening disease, there appears to be little 

likelihood of procuring organic Citrus hystrix leaves and fruit in the immediate future in any significant 

quantity. With this knowledge, and the considerations of commercial availability as defined in under 

§205.2 (appropriate form, quality, quantity) it seems that Citrus hystrix is not commercially available 

for organic producers in the quantity that is required and should be listed on §205.606.

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): 

HC 1 Citrus hystrix
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

Listing Motion: Motion to add Citrus hystrix leaves and fruit

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: Citrus hystrix leaves and fruit

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?

x

HC 2 Citrus hystrix
[§6517c(1)(A)(i);6517(c)(2)(A)i] 

4. Does the substance contain List 1, 2 

or 3 inerts? [§6517 c (1)(B)(ii); 

205.601(m)2]

x

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.

HC 3 Citrus hystrix
NOSB Evaluation Criteria for Substances Added To the National List

Category 2. Substance Essential for Organic Production? 

Substance: Citrus hystrix leaves and fruit

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.

HC 4 Citrus hystrix
NOSB Evaluation Criteria for Substances Added To the National List

Category 3. Substance compatible with organic production practices? 

Substance: Citrus hystrix leaves and fruit

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.

HC 5 Citrus hystrix
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: Citrus hystrix leaves and fruit

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 

x

HC 6 Citrus hystrix
barriers, or civil unrest that may 

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.

HC 7 Citrus hystrix