Formal Recommendation

From: National Organic Standards Board (NOSB)

To: National Organic Program (NOP)

Date: November 18, 2016

Subject: Petitioned Material Proposal - Ammonium Citrate

NOSB Chair: Tracy Favre

The NOSB hereby recommends to the NOP the following: (mark with an X)

Rule Making Action: 

Guidance Statement: 

Other: X

Statement of the Recommendation:

The Board determined that there was insufficient information in the justification statement regarding 

the necessity of the material for organic crop production. Chelates occur naturally in soils, so chelates, 

per se, are not incompatible with a system of sustainable agriculture. However, over reliance on 

synthetic materials is not compatible with a system of sustainable agriculture. The Subcommittee has 

determined that there are insufficient grounds for adding this substance to the National List as there are 

natural alternatives and one allowed synthetic already available.

Rationale Supporting Recommendation (including consistency with OFPA and Organic

Regulations):

The petitioner did not make a convincing case that the permitted products already on the market are 

inadequate to meet farmers’ needs. The petitioner did not provide evidence that chelates made 

with synthetic citrate are needed to replace lignin sulfonate and nonsynthetic chelating agents such as 

fulvic acids, humic acids, and nonsynthetic citrate currently in use by organic growers.

NOSB Vote: 

Classification Motion: 

Motion to classify ammonium citrate as synthetic

Motion by: Emily Oakley

Seconded by: Francis Thicke

Yes: 14 No: 0 Abstain: 0 Absent: 1 Recuse: 0 
Listing Motion: 

Motion to list ammonium citrate as petitioned at 205.601 

Motion by: Emily Oakley

Seconded by: Francis Thicke

Yes: 0 No: 14 Abstain: 0 Absent: 1 Recuse: 0

 Motion Failed
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National Organic Standards Board

Crops Subcommittee

Petitioned Material Proposal

Ammonium Citrate

September 6, 2016

Summary of Petition:

Alpha Chelates has petitioned for the inclusion of Ammonium Citrate on the National List at 205.601 

(synthetic substances allowed for use in organic crop production). Ammonium Citrate is used as a 

chelating agent. Ammonium Glycinate was petitioned at the same time for an equivalent use and will 

be addressed in a separate proposal. 

Ammonium Citrate is reacted with copper, iron, manganese, or zinc to form a chelate. The petitioner 

manufactures liquid micronutrient chelates using ammonium citrate as the chelating agent. Chelates 

are used to provide micronutrients that are readily available to plants in deficient soils. 

Ammonium Citrate is manufactured though a reaction of ammonium hydroxide and citric acid. The 

petition argues that approval of ammonium hydroxide is understood in the listing of ammonium 

carbonate in 205.601(e)(1) since it is a salt of ammonium hydroxide and carbonic acid (ammonium 

carbonate is listed for use “in insect traps only, no direct contact with crop or soil”). Further, the 

petitioner claims that since lignin sulfonate is listed as a chelating agent in 205.601(j)(4) and because 

OMRI approves the use of ammonium lignosulfonate, ammonium citrate should be allowed.

The petition states that chelated trace minerals are necessary in high pH soils because the simple metal 

micronutrient salts allowed in 205.601(j)(6)(ii) otherwise need to be applied at four to five times the rate 

of plant up-take because unchelated micronutrients precipitate quickly when they come into contact 

with soils high in pH. Additionally, the petitioner claims that although nonsynthetic chelating agents can 

be produced, they are incompatible with the manufacturing of chelates as a result of unpredictable 

variations in species and composition.

In addition to the information on ammonium citrate, the petition puts forth a case that the use of the 

term “chelating agent” in the regulations needs to be revisited. The petitioner contends that both the 

cation and anion of a salt approved for use as a chelating agent should be on National List. The 

petitioner requests that the NOP define which bases can be used to neutralize acids used to synthesize

chelating agents. However, these claims and request are beyond the purview of this Subcommittee

whose role in this case is the review of substances petitioned for inclusion on the National List. 

Summary of Review:

Upon review of the petition, the Subcommittee determined that there was insufficient information in 

the justification statement regarding the necessity of the material for organic crop production. The 

Subcommittee sent a request to the petitioner, asking why the petitioned materials would be better 

than the nonsynthetic and/or synthetic chelating agents that are already allowed. The petitioner 

submitted an addendum but still did not completely address the question of alternatives. The 

addendum claims that there are no nonsynthetic substances, nor any substances already on the 

National List, that could be used in place of ammonium citrate. The petitioner subsequently 

volunteered a second addendum. 
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Despite the submission of the second addendum, the petitioner did not make a convincing case that the 

permitted products already on the market are inadequate to meet farmers’ needs. The petitioner does 

not provide evidence that chelates made with synthetic citrate are needed to replace lignin sulfonate 

and nonsynthethic chelating agents such as fulvic acids, humic acids, and nonsynthetic citrate currently 

in use by organic growers.

The Subcommittee did not request a technical review after determining that the petitioned material was 

not necessary for organic production.

The Subcommittee has concluded that the petitioned substance does not meet the OFPA criteria and 

therefore should not be added to the National List.

Category 1: Classification 

1. For CROP use: Is the substance _______ Non-synthetic or ___X____ Synthetic?

 Is the substance formulated or manufactured by a process that chemically changes a substance 

extracted from naturally occurring plant, animal, or mineral sources? [OFPA §6502(21)] If so, 

describe, using NOP 5033-1 as a guide. 

No

2. Reference to appropriate OFPA category:

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; toxins derived from 

bacteria; pheromones, soaps, horticultural oils, fish emulsions, treated seed, vitamins and 

minerals; livestock parasiticides and medicines and production aids including netting, tree wraps 

and seals, insect traps, sticky barriers, row covers, and equipment cleansers; or (ii) is used in 

production and contains synthetic inert ingredients that are not classified by the Administrator 

of the Environmental Protection Agency as inerts of toxicological concern? 

No 

Category 2: Adverse Impacts 

1. What is the potential for the substance to have detrimental chemical interactions with other 

materials used in organic farming systems? [§6518(m)(1)]

Chelates occur in nature and are used at low rates in organic farming, so there should be no 

detrimental chemical interactions with other materials used in organic farming systems. 

2. What is the toxicity and mode of action of the substance and of its breakdown products or any 

contaminants, and their persistence and areas of concentration in the environment? 

[§6518(m)(2)]

Ammonium hydroxide and citric acid are introduced in a reaction vessel to produce ammonium 

citrate, a salt. The amino acid citric acid is neutralized by the alkali ammonium hydroxide. 

Ammonium citrate is reacted in a solution with copper, iron, manganese, or zinc salt to form a 

liquid chelate of the given metal. Chelates are applied in low dosages; application rates for the 

chelates manufactured by the petitioner are 1.2-2.5 kg/ha. 
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3. Describe the probability of environmental contamination during manufacture, use, misuse or 

disposal of such substance? [§6518(m)(3)]

The petition states that there is minimal chance of environmental or human contamination 

during the manufacturing process as the reaction takes place inside a sealed vessel. As stated 

above, the petitioned substance is an ingredient in a finished product and is converted into a 

metal salt chelate and is therefore not subject to questions of disposal. However, ammonium 

hydroxide is used in the manufacture of the substance, and ammonium hydroxide is produced 

by the reaction of ammonia with water. Ammonia can be harmful to human health and aquatic 

life if spilled or improperly handled.

4. Discuss the effect of the substance on human health. [§6517(c)(1)(A)(i); §6517(c)(2)(A)(i); 

§6518(m)(4)].

The petition states that “in the unlikely event of contact of reaction vessel contents with human 

skin, there is a very low level of hazard as the substance is at a low concentration, is not toxic, 

and can be easily washed off with water”.

5. Discuss any effects the substance may have on biological and chemical interactions in the 

agroecosystem, including the physiological effects of the substance on soil organisms (including 

the salt index and solubility of the soil), crops and livestock. [§6518(m)(5)] 

The Subcommittee is not aware of negative effects of the petitioned material on biological and 

chemical interactions in the agroecosystem.

6. Are there any adverse impacts on biodiversity? (§205.200)

None known.

Category 3: Alternatives/Compatibility

1. Are there alternatives to using the substance? Evaluate alternative practices as well as 

nonsynthetic and synthetic available materials. [§6518(m)(6)]

Alternatives to the petitioned substance exist and are currently in use, including lignin sulfonate, 

humic acids, fulvic acids, and nonsynthetic citrate. 

2. In balancing the responses to the criteria above, is the substance compatible with a system of 

sustainable agriculture? [§6518(m)(7)]

Chelates occur naturally in soils, so chelates, per se, are not incompatible with a system of 

sustainable agriculture. However, overreliance on synthetic materials is not compatible with a 

system of sustainable agriculture. The subcommittee has determined that there are insufficient 

grounds for adding this substance to the National List as there are natural alternatives and one 

allowed synthetic already available.

Classification Motion: 
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Motion to classify ammonium citrate as synthetic

Motion by: Emily Oakley

Seconded by: Francis Thicke

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

National List Motion:

Motion to add ammonium citrate as petitioned at 205.601

Motion by: Emily Oakley

Seconded by: Francis Thicke

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