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Response to Comments

Materials for Organic Crop Production

Links Update: September 5, 2018

This document summarizes comments received on the draft guidance document, “Materials for 

Organic Crop Production (NOP 5034),” which was posted on the NOP website for public 

comment. The public was notified in a Federal Register notice (78 FR 19637) on April 2, 2013.

• CHANGES MADE IN RESPONSE TO COMMENTS

1) Phase-In Period for Compliance. One commenter requested a phase-in period for 

compliance that would apply if changes to current practices are needed to comply with 

the guidance. The commenter did not specify an appropriate length for phase-in period. 

NOP agrees that a phase-in period may be appropriate because, in the absence of 

guidance, different interpretations on the status of materials may have been made in good 

faith by certifying agents and material review organizations. As such, we have allowed 

for a one year phase-in period from the date of publication of this document. This one 

year period is intended to allow for certifying agents to notify organic crop producers of 

the guidance and for organic crop producers to make updates to their Organic System

Plans if needed.

2) Instructions for NOP 5034-1. Some commenters requested that NOP 5034-1 include 

introductory information on how to use this document, as is provided in NOP 5034. We 

agree with the commenters that it would be useful to also include this at the beginning of 

document NOP 5034-1 and we have amended the document to include a reference to 

NOP 5034 for ease of use.

3) Use of Examples. Some commenters requested that NOP amend the guidance to clarify 

that when the term “includes” is used to provide examples, it is not intended to exclude 

other substances in that category. In response, NOP has amended several listings to read 

“includes, but not limited to,” as appropriate.

4) Changes to Specific Materials, NOP 5034-1. In response to comments received, NOP 

has amended the following material listings in the final guidance NOP 5034-1:

• Agricultural Substances. We amended this listing to clarify that agricultural substances 

are permitted unless specifically prohibited at section 205.602 and have also clarified the 

reference to section 205.606 to avoid confusion. The text was also amended to clarify that 

agricultural substances used in organic crop production do not need to be organic. We 

have not adopted a suggestion by one commenter to clarify whether commercial 

availability is applicable for agricultural substances used in crop production. We believe 

the regulations are sufficiently clear on this issue whereby commercial availability only 
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applies to agricultural materials listed on section 205.606 and used in organic handling. 

We have not included any reference to commercial availability within guidance on crop 

materials to avoid any confusion on this issue.

• Aquatic Plant Products. We have amended this listing to clarify that nonsynthetic plant 

extracts include products extracted with nonsynthetic materials.

• Azadirachtra Indica. We have amended the description provided at the cross-reference 

to “Neem and Neem Derivatives” to distinguish between azadirachtra and neem.

• Bagasse. We have accepted a commenter’s suggestion to delete a portion of the text 

which was not needed to clarify the identity of the substance.

• Biochar. We have amended the listing for biochar to clarify its description and use. We 

have eliminated the term “terra preta” in the description based on comments that

indicated terra preta is carbon-rich soil, but is not biochar itself. We have included the 

suggestion made by commenters to describe biochar as “biomass that has been 

carbonized or charred.”

We have also replaced the term “feedstocks” with “sources,” and included “animal 

material” as an allowed source, as requested by commenters. We have considered that the 

inclusion of “animal material” may raise questions about the allowance of manure as a 

feedstock for biochar, since the use of ash from manure burning is prohibited under 

section 205.602(a) of the USDA organic regulations. Although the pyrolysis process for 

biochar production is different than burning, we clarified in NOP 5033, Classification of 

Materials, that, for purposes of classification, pyrolysis may be treated as equivalent to 

burning or combustion. As the issue of biochar has not been considered by the NOSB, we 

are not providing clarification at this time on whether the use of biochar derived from 

manure is appropriate for organic production.

Further, we have not amended the listing to specify “gasification” as production process 

for biochar. This was suggested by a commenter to align with NRCS Conservation 

Practice Code 735 entitled “Waste Gasification Facilities.” We have also not accepted the 

suggestion to reference the International Biochar Initiative (IBI) Standards or additional 

information on prohibited additives, such as specifying no more than 2% contaminants by 

dry weight, as is done under the IBI Biochar standards. We feel that this level of detail 

and prescriptive guidance would first need evaluation by the NOSB. Parties interested in 

further evaluation of biochar are encouraged to submit a petition to the NOSB according 

to the current National List petition guidelines so that this material may be further 

considered.

• Biodynamic Preparations. We have amended the listing to clarify that horn manure 

spray is an example of the biodynamic preparations subject to the restrictions for animal 

manure.
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• Calcium Chloride. We have amended the listing to clarify that synthetic forms of 

calcium chloride are prohibited.

• Cannery Wastes and Cannery Waste Water. We have amended the listing to clarify 

that chemical changes caused by naturally occurring biological processes or by heating or 

burning biological matter are allowed.

• Chelating Agents. We have amended the listing to include information on synthetic 

chelating agents listed at section 205.601 of the National List.

• Chlorine / Electrolyzed Water. Several comments indicated that the listing for chlorine 

be amended to state that electrolyzed water is allowed. One commenter stated that the 

reference to electrolyzed water in a previous technical evaluation report for chlorine1

infers that electrolyzed water is an allowed alternative to chlorine. On September 11, 

2015, NOP published Policy Memo 15-4, Electrolyzed Water, which is available through 

the NOP Handbook.2 This memo clarifies that electrolyzed water (hypochlorous acid) is 

an allowed form of chlorine under the USDA organic regulations. The listing for chlorine 

materials in the guidance has been amended to be consistent with the policy memo.

• Citric Acid. We have amended the listing to further clarify that synthetic forms of citric 

acid are prohibited except as specified at section 205.601 of the National List.

• Cobalt. This listing was amended to fix a typographical error.

• Compost. This listing was amended to clarify that animal materials includes materials 

besides manure.

• Compost Inoculants. We have amended the listing to clarify the allowance of substances 

listed on section 205.601 used in inoculants.

• Crab Meal. We have replaced the description with a cross-reference to a new broader 

listing for “Shellfish Meal.”

• Diatomaceous Earth. We have amended the listing to clarify that calcined diatomaceous 

earth is also nonsynthetic, as is described in the 1995 Technical Advisory Panel review 

for diatomaceous earth for organic handling.

• Fulvic Acid. We have amended the listing to clarify that fulvic acids extracted with 

nonsynthetic acids are also nonsynthetic.

 1 Chlorine/Bleach, Technical Evaluation Report, 2011. Available on the NOP website at 

http://www.ams.usda.gov/sites/default/files/media/Chlorine%202%20TR%202011.pdf. 2 Available on the NOP website at https://www.ams.usda.gov/rules-regulations/organic/handbook
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• Growth Regulators. We have amended the listing to distinguish between synthetic and 

nonsynthetic growth regulators and to fix a typographical error.

• Gums. We have amended the listing for gums to remove xanthan gum as explained under 

the entry for “xanthan gum” below.

• Homeopathic Preparations. We have amended the listing to further clarify that 

synthetic materials used in homeopathic preparations for crop production must be 

included at section 205.601 of the National List.

• Inoculants / Compost Inoculants / Microbial Biopesticides / Microbial Products. We 

have amended these listings to provide consistent information as to whether growth 

media for products of and/or with microbes is relevant to determining compliance.

• Humic Acid. In response to several comments that humic acids may be either 

nonsynthetic or synthetic, we have amended the classification to indicate “Synthetic or 

Nonsynthetic.” We agree with commenters that stated that water extracted and naturally 

occurring deposits may be considered nonsynthetic. We did not adopt the commenters’ 

suggestions to distinguish between forms that are synthetic and nonsynthetic within the 

listing. This was requested to clarify an issue with products intended for export market

and has since been resolved under a new trade partnership agreement.

• Manure. We have amended the listing to include the definition for manure under section 

205.2 of the USDA organic regulations. In addition, we have further clarified that fish 

feces and insect frass do not fall within the definition of manure. We have also clarified 

that manure from organic or conventional livestock may be used for organic crop 

production. In addition, on May 6, 2016, the NOP sent a memo to the NOSB regarding 

the topic of treated manure products.3 NOP will consider updates to this entry following 

any NOSB recommendation on this topic.

• Mined Minerals. This listing was amended to correct the regulatory reference. The 

corrected reference now reads: 7 CFR 205.203(d)(2) & 205.203(d)(3).

• Molasses. This listing was amended to clarify that both organic and nonorganic 

nonsynthetic molasses are permitted. The listing was also amended for clarity.

• Neem and Neem Derivatives. This listing was amended to clarify that azadirachtin is an 

extract of neem, rather than a synonym for this substance.

 3 Available on the NOP website at 

https://www.ams.usda.gov/sites/default/files/media/2016%20NOSB%20Manure%20Treatments%20FINAL.pdf.
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• Oystershell Lime. This listing was amended to clarify that calcined oystershell lime is 

synthetic and prohibited as a fertilizer or soil amendment.

• Potassium Sulfate. This listing was amended to clarify that synthetic sources of 

potassium sulfate are prohibited.

• Rhizobium spp. This listing was amended to correct a spelling error.

• Seed Treatments (Seed Preparations). The listing for “seed treatments” was changed to 

“seed preparations” to avoid confusion with conventional seed treatments. We have also 

clarified that seed preparations refer to materials used prior to planting.

• Soap and “Soaps, Ammonium”. The listing for “Soaps, Ammonium” consolidated into 

the listing for “Soap.” The listing for “Soaps, Ammonium” was also amended for clarity.

• Streptomycin. One comment indicated that streptomycin should not be allowed in 

organic production. Since the listing for streptomycin expired on October 21, 2014, we 

have removed the entry for streptomycin and listed this substance on NOP 5034-2, 

Prohibited Materials for Organic Crop Production.

• Sulfur. The listing for sulfur was amended to distinguish between nonsynthetic and 

synthetic sulfur.

• Tetracycline. One comment indicated that tetracycline should not be allowed in organic 

production. Since the listing for tetracycline expired on October 21, 2014, we have 

removed the entry for tetracycline and listed this substance on NOP 5034-2, Prohibited 

Materials for Organic Crop Production.

• Vegetable Protein Hydrolysate. We have amended the text to clarify that soybean 

hydrolysate (soy protein isolate) falls within the listing for vegetable protein hydrolysate.

• Vinasse. One comment requested deferring inclusion of vinasse pending review of a 

petition for this substance by the NOSB. Another commenter indicated that vinasse

should be classified as synthetic due to the use chemicals used in making molasses, from 

which vinasse is derived. On May 2, 2014, the NOSB issued a recommendation regarding 

the classification of this substance, which classifies certain forms of vinasse as 

nonsynthetic if it does not contain prohibited additives. In response, NOP has amended 

this listing in order to implement the NOSB recommendation for this substance.

• Multiple Sources. Some commenters requested that NOP amend certain listings where 

both synthetic and nonsynthetic sources are available. The following listings have been 

amended in response to these comments:
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• Acetic acid

• Alcohol

• Calcium chloride

• Chelating agents

• Citric acid

• Growth regulators

• Fish products, liquid

• Gypsum

• Magnesium sulfate

• Micronutrients

• Potassium sulfate

• Potting soil

• Sulfur

• Vegetable protein hydrolysate

4) Removal of Materials from NOP 5034-1. In response to comments received, NOP has 

removed the following materials from the final guidance NOP 5034-1:

• Agave. This listing was removed in response to a comment that there is insufficient 

publicly available information to confirm that the manufacturing process for conventional 

agave syrup or agave nectar production is nonsynthetic. We encourage stakeholders in 

further consideration of this substance to submit a petition for the National List.

• Dextrin. This listing was removed on the basis that the NOSB has previously classified 

this substance as synthetic. The cross-reference to dextrose was also removed.

• Glycerin. At its April 2015 public meeting, the NOSB voted to reclassify some forms of 

glycerin as agricultural, nonsynthetic. This recommendation is currently under review by 

NOP for a future rulemaking action. Pending the outcome of this rulemaking, an entry for 

glycerin has been removed but will be considered for future addition to NOP 5034-1.

• Xanthan gum. This listing was removed on the basis that the NOSB has previously 

classified this substance as synthetic.

NOP received some comments indicating that dextrin, glycerin, and xanthan gum should be 

retained in the guidance as nonsynthetic. However, we have deferred to the NOSB’s 

classification for these substances.

NOP understands that accredited certifying agents and material evaluation programs may 

have approved the use of materials listed above as nonsynthetic based on an independent 

review of the manufacturing process. In addition, some materials may have more than one

method of manufacture.
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Accordingly, this guidance is not intended to be exhaustive. Certifying agents and material 

evaluation programs may use the guidance provided at NOP 5033, Classification of 

Materials, in evaluating these materials for compliance with the USDA organic regulations. 

Interested parties may also submit a petition according to the National List petition 

guidelines for these materials to the NOSB.

4) New Materials Added to NOP 5034-1. In response to comments received, NOP has added 

shell fish meal as a new nonsynthetic material to the final guidance NOP 5034-1.

5) Changes to Specific Materials, NOP 5034-2. In response to comments received, NOP has 

amended the following materials from the final guidance NOP 5034-2:

• Nickel. One commenter noted that the petition for nickel which was rejected by the 

NOSB included only synthetic inorganic salts of nickel and suggested amending the text 

to clarify. We have accepted the commenter’s suggestion and amended the name of the 

substance to read “nickel salts, synthetic.”

• Kiln dust. One commenter noted that in a few instances, they have been able to confirm 

that kiln dust is nonsynthetic. As the NOSB has not classified this substance as synthetic, 

we have removed this material from NOP 5034-2, pending further review.

• CHANGES REQUESTED BUT NOT MADE

1) Additional Comment Period. Two comments requested that NOP reissue a revision of 

the guidance for an additional comment period. NOP has not accepted this request. 

Instead, the Office of Management and Budget (OMB) Good Guidance Policy allows for 

commenters to submit comments on guidance at any time; therefore, we did not feel an 

additional period for consideration of draft guidance was warranted.

2) Updates. NOP received one comment indicating that the guidance does not go far 

enough toward resolving disputes at the “edges” of current understanding and 

interpretation. In addition, we received a comment urging NOP to keep the guidance 

document up to date. We understand that new issues may emerge that are not specifically 

addressed in the guidance document. We encourage certifiers and other interested parties 

to submit these topics to the NOP at NOP.Guidance@ams.usda.gov as they come up so 

that they may be considered for future updates.

3) Excluded Methods Verification. Two commenters requested specific feedback on areas 

where certifiers must verify that excluded methods were not used in the production of 

inputs and/or ingredients of inputs. We understand that certifiers may be taking different 

approaches on this issue and believe that more information is needed to determine 

appropriate guidance on this issue. Therefore, we have not included this specific feedback 

in this document.
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4) Ancillary Substances. Several commenters requested clarification on the use of ancillary 

substances in crop inputs. This topic is under consideration by the NOSB for substances 

used in organic handling. As previously stated in NOP memo of November 23, 2011, the 

use of formulants or “other ingredients” is provided for under section 205.601.4

5) Specific Materials. NOP has not made the following changes in the final guidance NOP 

5034-1 or NOP 5034-2 that were requested by commenters:

• Algae. One commenter requested that NOP clarify that algae in the microorganism or 

bacteria form be classified as nonagricultural and nonsynthetic, unless specifically listed 

as agricultural on section 205.606. The commenter indicated that large aquatic seaweeds 

remain classified as agricultural as listed on section 205.606. For purposes of NOP 5034, 

which applies only to substances used in organic crop production, the distinction between 

agricultural and non-agricultural algae is not applicable; therefore, we have retained the 

listing as originally proposed.

• Animal By-Products and Materials and Meat By-Products and Waste. One 

commenter requested further explanation on the source and handling of each of these 

substances. In the absence of additional information, we have not amended this listing. 

We suggest that parties interested in further consideration of this issue provide additional 

information to NOP.Guidance@ams.usda.gov.

• Clay. One commenter requested clarification on whether the intent is to have the end user 

determine when calcined clay becomes synthetic or if all calcined clay should be 

considered synthetic. We have not made this distinction within the list and encourage 

certifiers and material evaluation programs to refer to the guidance document NOP 5033, 

Classification of Materials, when determining whether a material is synthetic.

• Compost. We have not adopted a commenter’s suggestion to clarify whether compost is 

limited to aerobic composting, or whether it can be derived from anaerobic methods. 

Additional information may be needed on this topic.

• Corn Steep Liquor. Commenters provided mixed feedback on whether corn steep liquor 

should be classified as synthetic or nonsynthetic. Consistent with a previous NOP Notice 

dated January 31, 2011,5 we have retained the listing as an allowed nonsynthetic

substance pending a classification of this substance by the NOSB. One commenter also 

requested inclusion of the common and usual name, “condensed fermented corn 

solubles,” to ensure that only nonsynthetic corn steep liquor is used in organic 

production. We have included this alternative name for clarity.

 4 Memo to NOSB, Request for Clarification of “Other Ingredients” in Processed Organic Products, November 23, 

2011. 5 NOP Notice 11-3. Available on the NOP website at http://www.ams.usda.gov/sites/default/files/media/NOPNotice-11-3-CornSteepLiquor.pdf.
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• Corn Gluten. One commenter requested that corn gluten produced by wet corn milling 

be classified as synthetic, rather than nonsynthetic, due to chemical changes that occur 

during manufacturing. Other comments claimed that corn gluten is nonsynthetic. We 

have retained classification as nonsynthetic due to the historical consideration of corn 

gluten as nonsynthetic; however, further consideration of this issue may be warranted by 

the NOSB. Parties interested in further consideration of corn gluten are encouraged to 

submit a petition to the NOSB according to the National List petition guidelines.

• Biodynamic Preparations. One commenter indicated that the listing for biodynamic 

preparations should be amended to allow the use of horn manure spray without the preharvest interval that is required for raw manure. AMS disagrees with the commenter on 

this issue. Horn manure spray is produced by filling a horn with raw animal manure, 

burying the horn in soil for a specified period of time, unburying the horn, and diluting 

the contents with water for application to crops or fields. In general, this process does not 

satisfy the requirements for composted manure or processed manure that would exempt 

the use from the pre-harvest interval requirements that apply to raw manure under section 

205.203(c)(1) of the USDA organic regulations or NOP Guidance 5006. Certifying 

agents may need to review the manufacturing process on a case-by-case basis to 

determine whether the raw manure restriction applies; however, for purposes of the 

guidance, we have not amended the listing.

• Green Waste. One commenter requested that NOP clarify whether green waste from 

genetically engineered crops would qualify for use in organic crop production. A 

proposed rule to address green waste is under development. In the interim, accredited 

certifying agents must continue to review and approve all materials used by organic 

producers, including compost, as part of an operation’s organic system plan.

• Guano. One commenter indicated that fossilized guano should not be subject to the 

restrictions that apply to raw manure. NOP has not accepted the commenter’s suggestion. 

The term “fossilized guano” is not defined under the USDA organic regulations; 

therefore, the restrictions that apply to raw manure would apply, unless the material is 

composted, heat-processed, or fossilized to the extent to which is considered a “mined 

mineral” under 205.203(d)(2). Producers that use products that are sold, labeled, or 

advertised as “guano” are expected to comply with the NOP requirements for manure or 

compost, as appropriate.

• Indole-3-butyric acid. One commenter requested that indole-3-butyric acid (IBA) be 

removed from NOP 5034-2, the list of prohibited substances for crop production. The 

commenter indicated that IBA should be allowed since the synthetic form is chemically 

identical to the naturally occurring form. NOP disagrees with the commenter, as the 

classification of materials guidance classifies substances based on their production 

method, rather than based on comparison with naturally occurring forms of the 

substances. Since commercially produced IBA has been previously classified by the 
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NOSB as synthetic and was not recommended for inclusion on section 205.601 of the 

National List, we have retained this material on NOP 5034-2, Appendix of Prohibited 

Materials for Organic Crop Production.

• Inert Ingredients (EPA List 3 and 4). Two commenters requested that the outdated 

reference to inert ingredients (inerts) be amended. The NOSB and NOP are currently 

working on a process to update the outdated regulatory reference to inert ingredients. 

This update must occur through the rulemaking process, rather than through guidance. As 

such, we are unable to update the allowance for inerts through this final guidance.

• Mushroom Compost. One commenter requested clarification to confirm that spent 

substrate that contained urea that was completely consumed by the (conventional) 

mushrooms and is not present in the spent substrate would still not be permitted. This 

interpretation was consistent with our intent; therefore, the listing has not been amended.

6) Additional Materials. NOP has not included the following additional materials to the 

final guidance NOP 5034-1 that were requested by commenters:

• Wood Vinegar. Two commenters requested clarification on the status of wood vinegar, 

which is a by-product of biochar production. As this substance was not listed in the draft 

guidance for public comment, we have not included this substance at this time. Interested 

parties are encouraged to submit a petition for wood vinegar to the NOSB for review of 

the manufacturing process so that a determination on its classification can be made.

• OTHER CHANGES MADE

The following additional changes were made to the guidance document. These changes were not 

based on comments received on the draft guidance, but were made for the reasons described 

below.

1) Copper Products. We have amended the listing to correct the reference to the EPA 

regulations.

2) Peracetic Acid. The listing for peracetic acid was updated to reflect amendments to two 

listings for this substance on the National List that became effective May 29, 2013. The 

amendment for peracetic acid in organic crop production was published as a Final Rule in the 

Federal Register on May 28, 2013 [78 FR 31815].

3) Materials added to NOP 5034-2. In response recent reviews of petitions by NOP and the

NOSB, the following new materials were added to the Appendix of Prohibited Materials for 

Organic Crop Production, NOP 5034-2:
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• Exhaust gas (carbon monoxide)

• Magnesium dihydrogen phosphite monohydrate

• Polyoxin D zinc salt

4) Materials Moved from NOP 5034-1 to NOP 5034-2. The following materials have been 

moved from NOP 5034-1 to NOP 5034-2 as their allowance under the USDA organic 

regulations expired on October 21, 2014:

• Streptomycin

• Tetracycline

5) Corrections to NOP 5034-2.

• 1,4-Dimethylnaphthalene. The spelling of this substance was corrected.

6) Other Amendments to NOP 5034-2. The introductory text for NOP 5034-2 was amended to 

clarify that the list includes substances whose use has expired from the National List.