National Organic Standards Board

Livestock Subcommittee

Petitioned Material Proposal

Vitamins in Organic Aquatic Animals Production

June 17, 2013

Summary of Proposed Action:

The use of synthetic vitamins in organic aquatic animal production was petitioned by the Aquaculture Working 

Group (AWG). The National Organic Program (NOP) allows the use of vitamins in organic livestock production 

as feed additives, under §205.603(d)(3) as “Vitamins, used for enrichment or fortification when FDA approved.”

Vitamins are essential for animals raised on land or in water. Natural vitamins are found in sources that include 

fish, fish oils, green leafy vegetables, soybean, and many livestock by-products. The commercial availability is 

a major impediment and concern. Synthetic vitamins can be processed via chemical and fermentation 

methods. 

The use of synthetic vitamins should help reduce the harvesting of our fish populations worldwide. As our fish 

population declines, its can have a negative impact on individuals of various communities, countries, and 

cultures. 

Most of the major standards for organic aquaculture allow the use of synthetic vitamins. These included the 

Canadian General Standards Board, European Economic Community Council (EEC), United Kingdom Soil 

Association Standards, Codex Alimentarius, International Federation of Organic Agricultural Movements 

(IFOAM). In the United States, synthetic vitamins are NOP approved for use in land-based livestock 

production. For consistency, the allowance for synthetic vitamins is fair and balance approach for meeting the 

essential nutrient demand of vitamins in aquatic animal diets, until viable non-synthetic vitamins sources are in 

the market place. 

 

The Livestock Subcommittee has received a petition for the use of synthetic vitamins in aquatic animals feed 

on January 6, 2012. A Technical Report (TR) was requested by the subcommittee. The TR provided new and 

helpful information for the LSC and full NOSB to consider in the evaluation of synthetic vitamins in aquatic 

animals diets. 

 

Evaluation Criteria (see attached checklist for criteria in each category)

 Criteria Satisfied? 

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 

Substance Fails Criteria Category: None Comments: No criteria category failed.

Subcommittee Action & Vote

Classification Motion: Move to classify vitamins as petitioned for aquatic animals as synthetic 

Motion by: Jean Richardson 

Seconded by: C. Reuben Walker

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

Listing Motion: Move to list vitamins as petitioned for aquatic animals on section 205.611 of the National 

List 

Motion by: C. Reuben Walker 

Seconded by: Mac Stone 

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

Fall 2013 209 of 268
 Proposed Annotation (if any): None 

Approved by Tracy Favre, Subcommittee Chair, to transmit to NOSB June 17, 2013

NOSB Evaluation Criteria for Substances Added To the National List

Livestock

Category 1. Adverse impacts on humans or the environment? Substance: Vitamins for 

Aquatic Animals

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is there a probability of environmental 

contamination during use or misuse? 

[§6518(m)(3)]

X X Environmental contamination could 

possibly occur; however, the risks are low 

when manufacturers exercise good 

standard operating procedures for vitamins 

production, use, and disposal. 

[See 2013 Vitamins for Aquatic Animals 

TR, pgs. 19-24] 

2. Is there a probability of environmental 

contamination during manufacture or 

disposal? [§6518(m)(3)]

X X The environmental risks are low when 

manufacturers exercise good standard 

operating procedures. 

[See 2013 Vitamins for Aquatic Animals 

TR, pgs. 19-24] 

3. Does the substance contain inerts 

classified by EPA as “inerts of 

toxicological concern?” [§6517 

(c)(1)(B)(ii)] 

X 

According to the 2013 Vitamins for Aquatic 

Animals TR, pg. 24) it is unlikely that any of 

the petitioned vitamins would cause 

bioaccumulation in aquatic life. Practicing 

good aquatic animal husbandry practices 

for feeding intervals and volumes are 

approaches to mitigate potential harm to 

the environment and biodiversity. 

[See 2013 Vitamins for Aquatic Animals 

TR, pg. 24] 

4. Is there potential for detrimental chemical 

interaction with other materials used in 

organic farming systems?

[§6518(m)(1)] X 

Most of the chemical interactions of 

vitamins occur inside the aquatic animal 

body. The proper incorporation of the 

various vitamins in aquatic animals feed 

should bring about good health and negate 

or minimize any detrimental chemical 

interactions with other materials used. 

[See 2013 Vitamins for Aquatic Animals 

TR, pgs. 22-23] 

5. Is there a toxic or other adverse action of 

the material or its breakdown products?

[§6518(m)(2)] X X See #3

6. Is there persistence or concentration of X X

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Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

the material or breakdown products in 

the environment? [§6518(m)(2)]

See #3

7. Would the use of the substance be 

harmful to human health or the 

environment? [§6517 (c)(1)(A)(i); §6517 

(c)(2)(A)(i); §6518(m)(4)]

X No harmful effect is expected to result from 

the petitioned used (i.e. aquatic vitamin 

feed supplement).

[See 2013 Vitamins for Aquatic Animals 

TR, pgs. 24-25] 

8. Are there adverse biological and 

chemical interactions in the agroecosystem, including biodiversity? 

[§6518(m)(5)]

X It is unlikely that adverse biological and 

chemical interactions in the agroecosystem environment would occur. 

[See 2013 Vitamins for Aquatic Animals 

TR, pg. 23] 

9. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518(m)(5)]

X

See #8

NOSB Evaluation Criteria for Substances Added To the National List

Livestock

Category 2. Is the Substance Essential for Organic Production? Substance: Vitamins for Aquatic 

Animals 

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is the substance agricultural? [§6502(1)] X

2. Is the substance formulated or 

manufactured by a chemical process? 

[§6502(21)] X 

Vitamins can be produced using 

chemicals, fermentation, excluded 

method, or extraction from natural 

materials sources.

[See 2013 Aquatic Animals TR, pgs. 13-

19]. 

(7 CFR 205.105) prohibits certain 

excluded methods, including use of 

genetically modified organisms (GMO) 

2008 NOSB aquaculture 

recommendation - 205.252(j) (6) 

prohibits the use of any GMO or any 

organism produced by any other 

excluded method

3. 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

See #1

4. Is the substance created by naturally 

occurring biological processes? 

X

See #1

Fall 2013 211 of 268
Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

[§6502(21)]

5. Is there a natural source of the 

substance? [§ 205.600(b)(1)] X X 

There are natural sources such as forage 

fish, wild caught fish, shrimp, zooplankton 

and a combination plant-based and 

animal based feeds. The best source is 

fish meal. However, the availability and 

fragile commercial supply make is a 

major impediment in formulating fish 

diets. 

See 2013 Aquatic Animals TR, pgs. 28-

29]. 

6. Is there an organic substitute? 

[§205.600(b)(1)] X X See #5

7. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

X X See #5

8. Are there any alternative substances? 

[§6518(m)(6)] X X 

Vitamins are essential. Forage fish, wild 

caught fish, shrimp, zooplankton and a 

combination plant-based and animal 

based feeds.

[See 2013 vitamins for Aquatic Animals 

TR, pgs. 28-29].

9. Are there other practices that would 

make the substance unnecessary? 

[§6518(m)(6)]

X X 

See #8. However, the issue of 

commercially availability and viable 

alternatives are major impediments. 

[See 2013 Vitamins for Aquatic Animals 

TR, pgs. 28-29].

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NOSB Evaluation Criteria for Substances Added To the National List

Livestock

Category 3. Is the substance compatible with organic production practices? Substance: Vitamins for 

Aquatic Animals 

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is the substance consistent with organic 

farming and handling? 

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

X 

Synthetic vitamins are consistent with 

organic farming principles of several 

organic entities to include (1) European 

Union, (2) Canadian General Standards 

Board, (3) United Kingdom (UK) Soil 

Association, (4) IFOAM, and (5) 

Naturland Organics. [See 2013 Vitamins 

for Aquatic Animals TR, pgs. 11-13]. 

2. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518(m)(7)]

X 

See #1.

3. If used in livestock feed or pet food, is 

the nutritional quality of the food 

maintained with the substance? 

[§205.600(b)(3)]

X 

4. If used in livestock feed or pet food, is 

the primary use as a preservative? 

[§205.600(b)(4)]

X 

5. If used in livestock feed or pet food, is 

the primary use to recreate or improve 

flavors, colors, textures, or nutritive value 

lost in processing (except when required 

by law)? [§205.600(b)(4)]

X 

6. Is the substance used in production, and 

does it contain an active synthetic

ingredient in the following categories: 

[§6517(c)(1)(B)(i); 

copper and sulfur compounds X 

toxins derived from bacteria X

pheromones, soaps, horticultural oils, 

fish emulsions, treated seed, vitamins 

and minerals

X 

livestock parasiticides and medicines X

production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleansers

X 

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