National Organic Standards Board 

Materials/GMO Subcommittee Proposal

Excluded Methods Terminology 

August 30, 2016

Introduction and Background

In April 2013 the project was started to grapple with the definition of "excluded methods" in the USDA 

organic regulations. This is the definition that appears in the rule (7 CFR 205.2; Terms Defined):

Excluded methods. A variety of methods used to genetically modify organisms or influence their 

growth and development by means that are not possible under natural conditions or processes and 

are not considered compatible with organic production. Such methods include cell fusion, 

microencapsulation and macroencapsulation, and recombinant DNA technology (including gene 

deletion, gene doubling, introducing a foreign gene, and changing the positions of genes when 

achieved by recombinant DNA technology). Such methods do not include the use of traditional 

breeding, conjugation, fermentation, hybridization, in vitro fertilization, or tissue culture. (Federal 

Register / Vol. 65, No. 246 / Thursday, December 21, 2000 / Rules and Regulations p. 80639)

The definition was based on the best efforts of the NOSB in 1995 and has provided adequate guidance to 

prohibit the use of the most obvious genetically engineered crops such as herbicide-resistant corn and 

soybeans and Bt cotton, as well as prohibit processing inputs such as genetically engineered yeasts and 

enzymes. However, this definition is in need of re-examination and updating due to rapid advances in 

recombinant DNA biotechnology since 1995 that have made for gray areas for the organic standards 

regarding interpretation and enforcement.

In 2011 and 2012 a number of confusing issues came before the NOSB and to the NOP which made it 

necessary to revisit the definition. These include genetically engineered vaccines for livestock, the use of cell 

fusion within plant families to create male sterility in brassica hybrids, whether or not GMOs could be used 

in biodegradable bioplastic mulches, and the question of whether mutated algae might therefore be 

genetically engineered. The current definition is inadequate to clarify these issues. In the last few years the 

rise of gene editing with no insertion of foreign DNA, synthetic biology, and the genetically engineered 

insects that are starting to appear make this effort even more important.

The first NOSB Discussion Document on excluded methods in 2013,1 discussed each of the terms in the 

above definition, defined and discussed other terms involved in traditional breeding, such as mutagenesis 

and conjugation, and brought up new terms that may be considered to be genetic engineering. No 

conclusions were suggested except that there is a need to do more work on the subject. The discussion

questions posed asked commenters to suggest principles on which to base GE distinctions, to offer opinions 

on what terms were and were not excluded methods, and to bring forward new terms that may need 

consideration. 

The second NOSB Discussion Document posted in September 2014 and in April 20152 analyzed the 

comments received and proposed several options for an updated definition, and principles and criteria to 

use when evaluating the various genetic modification issues. Additional terms were collected and the 

beginnings of some definitions were started. A structure was proposed similar to the one in use by the 

Research Institute of Organic Agriculture (FiBL) in Europe that involves an itemized chart with a yes/no 

column where the specific techniques could be itemized and evaluated. The Subcommittee made an 

informal recommendation, which was not voted upon, that these revisions to the definition and structure 
for evaluating techniques be regulated through NOP guidance rather than additional rulemaking. Lastly it 

was acknowledged that there will be some unresolved issues that will need continued public discussion 

because they pose enforcement challenges, are totally hidden from view, or not enough is known about 

them yet.

Both a Proposal and a Discussion Document were posted for the April 2016 NOSB meeting. While comment 

was generally favorable to the approach taken, there clearly was the need for some refinement of the 

definitions and criteria. There was also confusion about which techniques were part of the proposal and 

which remained to be discussed further.

Goals of This Proposal/Document

The need for forward motion on this subject is more pressing every month. The fact that over 1000 pages of 

scientific references were submitted in public comment, with most of it being papers that came out since 

the NOSB GMO ad hoc Subcommittee was formed in 2012, indicates that the biotech community is rapidly 

outpacing any regulatory structure. The U.S. Department of Agriculture (USDA) has already ruled that 

certain plants produced with novel approaches to genetic manipulation will not be regulated as genetically 

modified organisms in the United States3

. It is more imperative than ever that the organic community be 

very clear about where the line is drawn regarding genetic engineering.

Public Comment from the past two and a half years has indicated strong support for this effort on the whole, 

although there is not consensus on some details. Every organic stakeholder is clear that genetic engineering 

is an imminent threat to organic integrity. Every effort must be made to protect that integrity to the extent 

that the NOSB is able to contribute to that.

The Materials Subcommittee is ready to move forward to create a structure for reviewing new technologies,

and disseminating the results of this review in a transparent manner. To this end, the proposal portion of 

this document includes supplements to the definition in the rule based on internationally accepted language, 

criteria to use in the reviews based on that definition, and a chart of those techniques that are clearly 

"excluded methods" based on the definition and criteria.

A separate discussion document contains the technologies, terms, and issues that we have not been able to 

agree on or do not yet have enough information on or that pose challenges that we have not yet taken up. 

These items are put out for discussion to collect further public comment. They will be reviewed at future 

NOSB meetings.

Definitions 

In the previous Discussion Document we suggested a couple of possible definitions that would update the 

text in the rule to a more comprehensive one that would be flexible enough to accommodate future 

technologies and terms. We were inclined to favor the definitions in use by Codex Alimentarius that were 

also in the Cartagena Protocol. 

During the course of public comment and subsequent discussion, it has become clear that more than one 

definition is important to the organic community, but that all the terms we suggest defining here would fall 

under the Excluded Methods definition in the rule and would not change, but would strengthen that 

definition. These definitions are to be used in Guidance to supplement and update the definition in the 

regulations, while leaving the rule itself intact. It is important to adopt some definitions that are widely 
accepted internationally and thus provide common ground with other countries who are concerned about 

GMOs in organics.

Based on public comment from the spring 2016 proposal, we decided to add a definition for 

Classical/Traditional Plant Breeding. Traditional breeding is a term used in the Excluded Methods definition 

in the rule and is therefore important to clarify what it means. However because the other definitions and 

criteria are not unique to plants, we slightly changed the wording so that they are applicable to all organisms.

In October 2015 the International Federation of Organic Agriculture Movements (IFOAM) published a 

Discussion Paper on a proposed revision to their Position on Genetic Engineering.45 Since other countries do 

not use the concept of "Excluded Methods", IFOAM proposed new definitions for three terms: Genetic 

Engineering (GE), Genetically Modified Organism (GMO), and Synthetic Biology. After examining their 

definitions, the Materials/GMO Subcommittee (MS) agrees that these three terms are important to define in 

the guidance we are proposing. However, we do not wish to take the old approach (that IFOAM is still using) 

of trying to capture all the methods and terms into one definition, because it will be out of date as soon as 

the next round of new technologies arrives.

Therefore we are proposing that the following definitions of terms and acronyms, with sources, be adopted 

by the NOSB as Excluded Methods1

:

Genetic engineering (GE) – A set of techniques from modern biotechnology (such as altered and/or 

recombinant DNA and RNA) by which the genetic material of plants, animals, organisms, cells and other 

biological units are altered and recombined. (First sentence modified from IFOAM Position cited above)

Genetically Modified Organism (GMO) – A plant, animal, or organism that is from genetic engineering as 

defined here. This term will also apply to products and derivatives from genetically engineered sources. 

(Modified slightly from IFOAM Position cited above)

Modern Biotechnology – (i) in vitro nucleic acid techniques, including recombinant DNA and direct injection 

of nucleic acid into cells or organelles, or (ii) fusion of cells beyond the taxonomic family, that overcomes 

natural, physiological reproductive or recombination barriers, and that are not techniques used in traditional

breeding and selection. (From Codex Alimentarius6

)

Synthetic Biology7 – A further development and new dimension of modern biotechnology that combines

science, technology and engineering to facilitate and accelerate the design, redesign, manufacture and/or 

modification of genetic materials, living organisms and biological systems. (Operational Definition developed 

by the Ad Hoc Technical Expert Group on Synthetic Biology of the UN Convention on Biological Diversity8

)

Non-GMO – The term that is used to describe or label a product that was produced without any of the 

excluded methods defined in the organic regulations and corresponding NOP policy. The term "non-GMO" is 

consistent with process-based standards of the NOP where preventive practices and procedures are in place 

to prevent GMO contamination while recognizing the possibility of inadvertent presence. (Modified based 

on public comment from Spring 2016 NOSB)

 1 Both definitions and criteria were worked on in between the Spring and Fall NOSB meetings by an ad hoc group with 

the following members: Julie Dawson, University of Wisconsin; David Gould, International Federation of Organic 

Agriculture Movements (IFOAM); Michael Hansen, Consumers Reports; Jaydee Hanson, Center for Food Safety; Kristina 

Hubbard, Organic Seed Alliance; Melody Meyer, United Natural Foods; James Myers, Oregon State University; Dana 

Perls, Friends of the Earth; Erica Renaud, Vitalis Organic Seeds; Dan Seitz, National Organic Standards Board (NOSB); 

Michael Sligh, Rural Advancement Fund International; Zea Sonnabend, Fruitilicious Farm and NOSB; Jim thomas, ETC 

Group; William Tracy, University of Wisconsin; Gwendolyn Wyard, Organic Trade Association.
Classical/Traditional plant breeding – Classical (also known as traditional) plant breeding relies on 

phenotypic selection, field based testing and statistical methods for developing varieties or identifying 

superior individuals from a population, rather than on techniques of modern biotechnology. The steps to 

conduct breeding include: generation of genetic variability in plant populations for traits of interest through 

controlled crossing (or starting with genetically diverse populations), phenotypic selection among genetically 

distinct individuals for traits of interest, and stabilization of selected individuals to form a unique and 

recognizable cultivar. Classical plant breeding does not exclude the use of genetic or genomic information to 

more accurately assess phenotypes, however the emphasis must be on whole plant selection.

This series of definitions provides a better framework than the existing definition, as it elaborates the 

various technologies that would be prohibited as well as those which would be allowed. We propose to 

combine these definitions, the principles and criteria discussed below, and the terminology chart presented 

into this Proposal for Guidance on Excluded Methods.

Principles and Criteria

The NOSB has its own set of Principles of Organic Production and Handling in the Policy and Procedures 

Manual9

. The principles start with:

1.1 Organic agriculture is an ecological production management system that promotes and 

enhances biodiversity, biological cycles, and soil biological activity. It emphasizes the use of 

management practices in preference to the use of off-farm inputs, taking into account that regional 

conditions require locally adapted systems. These goals are met, where possible, through the use of 

cultural, biological, and mechanical methods, as opposed to using synthetic materials to fulfill 

specific functions within the system.

Regarding Genetic Engineering:

1.11 Genetic engineering (recombinant and technology) is a synthetic process designed to control 

nature at the molecular level, with the potential for unforeseen consequences. As such, it is not 

compatible with the principles of organic agriculture (either production or handling). Genetically 

engineered/modified organisms (geo/gmos) and products produced by or through the use of 

genetic engineering are prohibited.

The following principals of Organic Agriculture are used by IFOAM10 and summarize well the guidance for 

developing a position on GMO technology.

• Principle of Health: Organic Agriculture should sustain and enhance the health of soil, plant, animal, 

human and planet as one and indivisible.

• Principle of Ecology: Organic Agriculture should be based on living ecological systems and cycles, 

work with them, emulate them and help sustain them.

• Principle of Fairness: Organic Agriculture should build on relationships that ensure fairness with 

regard to the common environment and life opportunities.

• Principle of Care: Organic Agriculture should be managed in a precautionary and responsible 

manner to protect the health and well-being of current and future generations and the environment.

Using the principles above, biotechnology processes will be reviewed to the following criteria to determine if 

they are excluded methods:

1. The genome is respected as an indivisible entity and technical/physical insertion, deletions, or 

rearrangements in the genome is refrained from (e.g. through transmission of isolated DNA, RNA, or 

proteins). In vitro nucleic acid techniques are considered to be invasion into the plant genome.
2. The ability of a variety to reproduce in species-specific manner has to be maintained and genetic use 

restriction technologies are refrained from (e.g. Terminator technology).11

3. Novel proteins and other molecules produced from modern biotechnology must be prevented from 

being introduced into the agro-ecosystem and into the organic food supply.

4. The exchange of genetic resources is encouraged. In order to ensure farmers have a legal avenue to 

save seed and plant breeders have access to germplasm for research and developing new varieties, 

the application of restrictive intellectual property protection (e.g., utility patents and licensing 

agreements that restrict such uses to living organisms, their metabolites, gene sequences or 

breeding processes are refrained from.12

Most of the techniques that are considered to be genetic engineering are clearly not compatible with the 

principal of ecology because they do not work within living ecological systems or sustain them. They are also 

at odds with the Principal of Fairness because they are not available equally to all stakeholders and are often 

patented or used to create patented traits. There are significant questions around the Principle of care for 

the health and well-being of future generations and the environment. These concerns do not change just 

because a technique cannot be tested for or does not use DNA foreign to the target organism.

The secondary effects from the use of GMOs are starting to emerge clearly in parallel with the new 

technologies. Issues such as reduction in diversity on farms where GMOs are grown, the demise of beneficial 

species both above and below the soil, the decline in soil fertility and resilience from increased use of 

herbicides, the evolution of weeds resistant to those herbicides, the altered nutritional profiles of the GMO 

crop products, and the displacement of small farmers from their land are all violations of the principals of 

organic agriculture.13

Process and Product

Since the whole underpinning of the U.S. organic regulations is a process-based system, it makes sense that 

this concept carry over to defining excluded methods. This is indeed the basis of the current definition. 

However, this is not currently how U.S. government agencies regulate GMOs14, or handle other issues such 

as pesticide residues or water quality standards. 

Newer technologies, known as Targeted genetic modification (TagMo) or targeted genome editing, are 

emerging and being adopted quickly.15 These are very clearly genetic engineering techniques but are not

regulated by the current government structure because they do not involve DNA from a "pest" under the 

USDA APHIS regulatory structure. Many of these techniques involve precise changes in existing DNA without 

using foreign DNA from a different species. These new technologies make genetic modification much more 

accessible and less expensive. The resulting plants may not show up as genetically engineered in the 

commonly used testing methods because they contain no foreign DNA, just native DNA that has been 

changed at the allele level by humans.

Forward Movement towards Structure

FiBL Research Institute for Organic Agriculture from Switzerland submitted a comment in 2013 that included 

a chart that describes methods with a yes/no column for compatibility with organic standards for both 

plants and animals16. The NOSB posed adopting such a chart on the methods that receive consensus and can 

be incorporated into guidance. It is important to identify all of these terms so that it is clear that they fall 

under the definition of excluded methods, but these terms do not need to be added to the definition itself.
The first version of such a chart for the NOSB is presented here. Appendix A provides a brief description of 

each term with additional citations for those who want to find out more about the terms. There is so much 

terminology and so many techniques with similar or multiple names that we have added a column for 

additional names and types used for each general process. Along with lack of regulation of some of these 

processes, there is lack of standardization of the terms, so that new names and sometime proprietary ones 

are emerging all the time.

We would especially like to acknowledge the work done by the Center for Food Safety in their public 

comment for the April 2015 meeting. They have helped organize all the various terminology and provided 

substantial scientific papers that discuss all the terms.17 The technologies are grouped by the tasks that the 

methods accomplish and the types of changes made to the engineered organism. In the context of this 

proposal we are not able to discuss most of the terms at length so please see the Appendix and the CFS cited 

comment for the full reference list.

For this version of the proposal, the ones that were marked "TBD" in the previous chart below are now 

moved to the accompanying Discussion Document. The ones presented here are those that we are voting on 

as either Excluded or Allowed. A column has been added for which criteria apply to the excluded techniques 

that have led to our conclusion to exclude them.

Terminology Chart

Method and 

synonyms

Types Excluded 

Methods

Criteria

Applied

Notes

Targeted genetic 

modification (TagMo)

syn. Synthetic 

gene technologies

syn. Genome 

engineering

syn. Gene editing

syn. Gene 

targeting

Sequence-specific nucleases 

(SSNs)

Meganucleases

Zinc finger nuclease (ZFN)

Mutagenesis via 

oligonucleotides

CRISPR-Cas system*

TALENs**

Oligonucleotide directed 

mutagenesis (ODM)

Rapid Trait Development 

System (RTDS) (Cibus)

YES 1, 3, 4 Most of these new 

techniques are not 

regulated by USDA and 

are hard to test for.

Gene Silencing RNA-dependent DNA 

methylation (RdDM)

Silencing via RNAi pathway

RNAi pesticides

YES 1, 2, 4

Accelerated plant 

breeding techniques

Reverse Breeding

Genome Elimination

FasTrack

Fast flowering

Dupont Seed Production 

Technology (SPT)

YES 1, 2, 4 These may pose an 

enforcement problem 

for organics because 

they are not detectable 

in tests.

Synthetic Biology Creating new DNA sequences

Synthetic chromosomes

Engineered biological 

functions and systems.

YES 1, 3, 4

Cloned animals and 

offspring

Somatic nuclear transfer YES 1, 3
Plastid 

Transformation

YES 1, 3, 4

Marker Assisted 

Selection

NO

Transduction NO

* CRISPR-Cas = Clustered regularly interspaced short palindromic repeats and associated protein genes.

** TALENs = Transcription activator-like effector nucleases.

Proposal

This proposal has three sections, to be used in NOP Guidance on Excluded Methods:

1. Approve the definitions of Genetic Engineering (GE), Genetically Modified Organism (GMO), Modern 

Biotechnology, Synthetic Biology, Non-GMO, and Classical/Traditional Plant Breeding as written above.

2. Approve the Principles and Criteria above that will be used in the evaluation of new technologies and 

terminologies.

3. Adopt the Terminology chart proposed above and the listings in it as presented, recognizing that this will 

be added to as further deliberations occur in the future.

Subcommittee Vote

Motion to accept the three sections of this proposal as stated above.

Motion by: Zea Sonnabend

Second: Emily Oakley

Yes: 4 No: 0 Absent: 1 Abstain: 1 Recuse: 0
Appendix A –

Brief Description and Additional Citations for Terms used in Excluded Methods Terminology Chart.

Only terms that are marked YES or NO as Excluded Methods are defined here. All those marked TBD are still 

being worked on in discussion. Those marked "syn." are defined in cited reference from Center for Food 

Safety Public Comment in April 201518. Some other definitions are from the NOSB previous discussion 

document19 and from the FiBL 2015 plant breeding dossier.20

Targeted genetic modification (TaqMo) (Kuzma and Kokotovich 2011, Kokotovich and Kuzma 2014) - a 

collective term for the zinc finger nuclease techniques that create DNA double-stranded breaks at 

specific genomic locations that can then be used to alter the target gene. The genetic modification 

would not necessarily involve transfer of nucleic acids from another species, nor would it be easy to 

detect in a final product. 

• syn. Synthetic gene technologies (Then 2015) 

• syn. Genome engineering (Voytas and Gao 2014)

• syn. Gene editing (Puchta and Fauser 2013) 

• syn. Gene targeting (GT) (Puchta and Fauser 2013, Endo et al. 2015)

• syn. Sequence-specific nucleases (SSNs) (Voytas and Gao 2014): 

• syn. Meganucleases (Gao et al. 2011, as cited in FSANZ 2013) 

• syn. Site directed mutagenesis via oligonucleotides, zinc finger nuclease (ZFN) (Dow, APHIS 

2012) - an introduction of recombinant DNA through transient molecules that are identified by 

zinc-finger nucleases, with or without a repair template. The techniques resemble transgenesis 

but the end products are similar to, and indistinguishable from, conventionally bred plants.

• syn. Clustered regularly interspaced short palindromic repeats and associated protein genes 

(CRISPR-Cas system) (NYTs 3/20/2015) – a protein called Cas9 enables breaks in DNA at specific 

spots so that additional pieces of DNA and RNA can be inserted.

• syn. Transcription activator-like effector nucleases (TALENs) (Sprink et al. 2014).

• syn. Oligonucleotide directed mutagenesis (ODM) (Lusser et al. 2011)

• syn. Cibus Rapid Trait Development System (RTDS) (Beetham et al. 2012 patent) - Similar to the 

oligonucleotide targeted DNA modification it does not leave behind transgenic material, only 

uses it to create a change in a precise area of a gene.

Gene silencing via RNAi and DNA methylation - Interfering with the regulation of gene expression through 

inserting methyl groups onto RNA and DNA that then suppress the expression of the gene. Can occur 

in nature, but is used as a recombinant technique in cancer research and plant breeding.

• syn. RNA-dependent DNA methylation (RdDM) (Lusser et al. 2011)

• syn. Gene silencing via RNAi pathway (Casacuberta et al. 2015, Baier et al. 2014, Lubasik and 

Zielenkiewicz 2014, Hirschi 2012, Heinemann et al. 2013, Lundgren and Duan 2013, Wagner et al. 

2015) – A technique in which a small strand of RNA is inserted into a DNA sequence to regulate the 

expression of the gene. There is no change to the DNA sequence, but there is technical interference 

with the genome.

• RNAi-based pesticides (Palli 2014, Zhu 2013) – RNA interference (RNAi) is a technique in which gene 

silencing RNA strands are inserted into a target genome in order to regulate the expression of target 

genes. It was used to engineer rootworm resistant corn as well as to genetically engineer insects 

themselves.

Accelerated Plant Breeding Techniques

• Reverse Breeding (Dirks et al. 2009) – A process that uses several other techniques such as RNAi to 

suppress meiotic recombination, tissue culture, and then double haploidization to create parental 

lines that are homozygous to use in breeding F1 hybrids.

• Genome elimination (Comai 2014)
• FasTrack (Waltz 2012) – a breeding scheme that has so far been used in plums where an earlyflowering gene from poplar is inserted into a plum tree. When the plum flowers in less than a year, 

it is crossed with non-transgenic varieties carrying desirable traits. Markers are used to identify the 

right traits and, at the end of the breeding program, only those are selected that do not have the 

transgene.

• Fast flowering (Flachowsky et al. 2011)

• DuPont’s Seed Production Technology (SPT) (Waltz 2012)

Synthetic Biology (see definition in main document)

• Synthetic chromosomes (Shenoy and Sarma 2010, pp. 12-13; Gaeta et al. 2012)

Embryo Transfer in animals – a technique used in animal breeding. It involves inducing superovulation of 

donor with gonadotropins, artificial insemination, recovery of embryos, isolation and storage of 

embryos, transfer of embryos back into animals, and then pregnancy.

Plastid transformation (Maliga 2004, as cited in NOSB discussion 2014) – Plastids are semi-autonomous 

organelles within higher plants with a small, highly polyploid genome. Technology has been 

developed for genetic modification of this genome independent of nuclear DNA. Currently used 

commercially in tobacco, and widely researched.

Marker Assisted Selection – Molecular markers are used as diagnostic aids to determine differences in the 

DNA sequence. They can help in selecting desired traits. The markers do not change the DNA of 

living plants and are not considered to be genetic engineering.

 1 NOSB 2013. Excluded Methods Terminology Discussion Document. April 2013.

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5102656

2 National Organic Standards Board Materials/GMO Subcommittee. (2014). Discussion Document on Excluded Methods 

Terminology. August 22.

3 Waltz, E. (2012). Tiptoeing around transgenics. Nature Biotechnology, 30, 215-217. doi:10.1038/nbt.2143 4 IFOAM – Organics International, 2015, 2015 Discussion Paper on a Proposed Revision to Position on Genetic 

Engineering and Genetically Modified Organisms in Organic Agriculture. 

https://gallery.mailchimp.com/75bdff144a46c1e451eecde10/files/Discussion_paper_on_GMO_position_2015.pdf 5 IFOAM – Organics International, 2002, Postition on Genetic Engineering and Genetically Modified Organisms, P01, 

https://gallery.mailchimp.com/75bdff144a46c1e451eecde10/files/IFOAM_GMO_Position_Paper.pdf 6 Codex Alimentarius Commission (2003). “Principles for the Risk Analysis of Foods Derived from Modern 

Biotechnology,” CAC/GL 44>2003. Amended 2008, 2011, available at: http://www.fao.org/faoDwhoD 

codexalimentarius/shD 

proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandar 

ds%252FCAC%2BGL%2B44D2003%252FCXG_044e.pdf. 7 Two other definitions were looked at when this one was chosen: Synthetic Biology – Designing and constructing 

biological devices, biological systems, biological machines and biological organisms using a range of methods derived 

from molecular biology and biotechnology, including in virtually all cases the techniques of genetic engineering or 

genetic modification. (From IFOAM Position cited above). Synthetic biology is a maturing scientific discipline that 

combines science and engineering in order to design and build novel biological functions and systems. This includes the 

design and construction of new biological parts, devices, and systems...as well as the re-design of existing, natural 

biological systems for useful purposes.” (from SynBerc, the University of California/Department of Energy synthetic 

biology research consortium)

8 Link to the European Commission's draft definition with discussion: 

http://ec.europa.eu/health/scientific_committees/consultations/public_consultations/scenihr_consultation_21_en.ht

m

9 NOSB Policy and Procedures Manual: https://www.ams.usda.gov/sites/default/files/media/NOSBPolicyManual.pdfhttps://www.ams.usda.gov/sites/default/files/media/NOSB-PolicyManual.pdf

10 http://www.ifoam.bio/sites/default/files/poa_english_web.pdf

11 FiBL Research Institute of Organic Agriculture 2013. Public Comment to NOSB. Docket AMS-NOP-12-0070

12 FiBL Research Institute of Organic Agriculture 2015. Dossier No. 2 Plant Breeding Techniques: an assessment for 

organic farming.
 13 IFOAM – Organics International, 2015, 2015 Discussion Paper on a Proposed Revision to Position on Genetic 

Engineering and Genetically Modified Organisms in Organic Agriculture. 

https://gallery.mailchimp.com/75bdff144a46c1e451eecde10/files/Discussion_paper_on_GMO_position_2015.pdf 

14 Kuzma J, Kokotovich A (2011) Renegotiating GM crop regulation. EMBO reports 12: 883–888. 15 Kokotovich A, Kuzma J (2014) Conflicting Futures: Environmental Regulation of Plant Targeted Genetic Modification. 

Bulletin of Science, Technology & Society 34: 108–120. 16 FiBL Research Institute of Organic Agriculture 2013. Public Comment to NOSB. Docket AMS-NOP-12-0070 17 CFS Comments to the NOSB, 2015, Docket #AMS_NOP_15-0002-0874

18 CFS Comments to the NOSB, 2015. Reference List. http://www.regulations.gov/#!documentDetail;D=AMS-NOP-15-

0002-0875

19 National Organic Standards Board Materials/GMO Subcommittee. (2014). Discussion Document on Excluded 

Methods Terminology. August 22.

20 FiBL Research Institute of Organic Agriculture 2015. Dossier No. 2 Plant Breeding Techniques: an assessment for 

organic farming.