This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy.

Revised January 20, 2014

National Organic Standards Board

Livestock Subcommittee

Petitioned Material Checklist

Micronutrients for use in aquatic plant production

+February 3, 2014

Summary of Proposed Action:

Micronutrients are proposed to be added to the National List at 205.609 for use in aquatic plant 

production. Section 205.609 of the National List will contain the list of synthetic substances 

allowed in organic aquatic plant production.

There are 18 to 21 elements (depending on the plant) considered essential for plants to 

properly grow and develop. Three come from air and water (C, H, O) and the rest must 

be otherwise supplied. Three are considered primary nutrients (N, P, K), three are 

considered secondary nutrients (Ca, Mg, S) and the other 12 are considered 

micronutrients: Fe, B, Cu, Cl, Mn, Mo, Zn, Co, Ni, Na, Se and Cr. Micronutrients are 

needed by plants at 10 to 100,000 times lower concentrations than primary nutrients.

Previous to the development of micronutrient media for plant aquaculture systems, it 

was common practice to add aqueous extracts of soil to culture water to supply 

micronutrients. Today, there are available micronutrient mixtures – such as the Guillard 

f/2 media – that are commonly added to culture water to supply micronutrients for plant 

aquaculture. These micronutrient mixtures generally supply six micronutrients: Fe, Cu, 

Zn, Co, Mn and Mo. However, “deficiencies of one or more additional micronutrients

may develop depending upon the source of growing water and the species of aquatic 

plant in culture” (petition, p.2).

All micronutrients are allowed for use in terrestrial organic crop production with the 

exception of those containing nitrate or chloride. In terrestrial agriculture, chloride is

avoided to avoid salt buildup in the soil. However, in aquaculture, “most water sources, 

including marine, brackish and fresh water contain much larger amounts of chloride 

salts than would be added by these nutrients at the very low levels employed” (petition, 

p. 6). None of the micronutrient formulations listed in the 2010 Micronutrient Technical 

Report for crop production (lines 59-95) contain nitrate, although several of them 

contain ammonium (a nitrogen-containing ion). However, at the low levels trace 

minerals are used at, the amount of nitrogen added with nitrogen-containing 

micronutrient supplements would be very small.

In terrestrial organic crop production, soil testing is required to document deficiencies 

before micronutrients can be applied. In aquatic plant production, micronutrients are 

generally added to culture media at the outset and supplemented occasionally, and 

“testing of dissolved ionic forms of micronutrients at very low concentrations, other than 

ferric ions, is extremely difficult or prohibitively expensive” (petition, p.4).

It should be noted that at the time of drafting this proposal there are no federal 

standards promulgated for aquatic plant or animal production and this proposal is based 

on the NOSB Recommendations voted in 2007, 2008 and 2009.
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy.

Revised January 20, 2014

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

Criteria Satisfied? 

1. Impact on Humans and Environment ☒ Yes ☐ No ☐ N/A 

2. Essential & Availability Criteria ☒ Yes ☐ No ☐ N/A

3. Compatibility & Consistency ☒ Yes ☐ No ☐ N/A 

Substance Fails Criteria Category: [ ] Comments: NA

Subcommittee Action & Vote, 

Classification Motion: Move to classify micronutrients as petitioned for aquatic plants as 

synthetic 

Motion by: Francis Thicke 

Seconded by: C. Reuben Walker

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

Listing Motion: Motion to list micronutrients at §205.609 with the following annotation: For 

non-vascular plants only.

Motion by: Francis Thicke 

Seconded by: C. Reuben Walker

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

 Basis for annotation: x☐ To meet criteria above ☐ Other regulatory criteria ☐ Citation 

Notes: 

Approved by Tracy Favre, Subcommittee Chair, to transmit to NOSB February 3, 2014

NOSB Evaluation Criteria for Substances Added To the National List: Crops

Category 1. Adverse impacts on humans or the environment? Micronutrients for use in aquatic 

plant production

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 Because micronutrients are used at very 

low concentrations there is little 

probability of environmental 

contamination. Petition (pg.4): “any 

residual trace elements released into 

environment will be extremely low 

concentrations below any physiologically 

significant level, & will be rapidly 

absorbed by microorganisms.”
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy.

Revised January 20, 2014

2. Is there a probability of environmental 

contamination during, manufacture or 

disposal? [§6518(m)(3)]

X Little specific information is available on 

micronutrient manufacturing in either the 

petition or TR, other than that 

micronutrients are manufactured in many 

different ways.

TR line 323: “Commercial micronutrients 

are generally manufactured as byproducts or intermediate products of

metal mining and processing industries.” 

Petition, page 3: “various trace minerals 

are obtained from sources in a number of 

countries, including China. 

Manufacturing processes are 

proprietary.” 

3. Are there any adverse impacts on 

biodiversity? (§205.200)

X Crops TR line 534: “Micronutrients are 

essential for normal plant growth, but 

levels above that required for good 

growth can be toxic and suppress plant 

growth, and may cause adverse 

biological or chemical 

interactions in the agro-ecosystem.” 

However, there would be no incentive to 

add micronutrients at higher-than-needed 

levels for aquatic plant production.

4. Does the substance contain inerts 

classified by EPA as ‘inerts of 

toxicological concern’? [§6517 

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

X

5. Is there potential for detrimental chemical 

interaction with other materials used in 

organic farming systems?

[§6518(m)(1)]

X TR 504-508: reactivity of micronutrients is 

low towards other chemicals/substances, 

these components exist naturally in soil; 

must follow application rates. As noted 

above, there would be no incentive to 

apply at rates higher than necessary.

6. Is there a toxic or other adverse action of 

the material or its breakdown products?

[§6518(m)(2)]

X TR 656-659: micronutrients may be 

applied as different compounds-most 

applied micronutrients are simple ionic 

forms & will not breakdown any further. 

7. Is there persistence or concentration of 

the material or breakdown products in 

the environment? [§6518(m)(2)]

X As noted above, micronutrients are 

simple ions that will not break down 

further, and they are applied at very low 

levels, which should be expected to be 

mostly consumed by the plants.

8. 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 The micronutrients used in aquatic plant 

production are also essential elements in 

humane nutrition, so at the levels used 

they will not be harmful to human health.
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy.

Revised January 20, 2014

9. Are there adverse biological and 

chemical interactions in the agroecosystem? [§6518(m)(5)]

X TR 545: toxicity could occur if 

micronutrients are applied in excess. 

However, in aquatic plant systems they 

are used at very low levels

10. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518(m)(5)]

X See #9 above.

Category 2. Is the Substance Essential for Organic Production? Micronutrients for use in 

aquatic plant production

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 TR line 323: “Commercial micronutrients 

are generally manufactured as byproducts or intermediate products of 

metal mining and processing industries.” 

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 Micronutrients are manufactured in a 

wide variety of ways, generally involving 

chemical change of mineral sources.

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

X See #2 above.

5. Is there a natural source of the 

substance? [§ 205.600(b)(1)]

X TR line 867: Most naturally available 

minerals of micronutrient components not 

soluble or are only very slowly soluble in 

water.

6. Is there an organic substitute? 

[§205.600(b)(1)]

X Minerals are inorganic

7. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

X See #5.

8. Are there any alternative substances? 

[§6518(m)(6)]

X Micronutrients are essential elements for 

plant growth. There are no alternatives

9. Are there other practices that would 

make the substance unnecessary? 

[§6518(m)(6)]

X In some cases, recirculating water from 

other ecological systems could make 

adding micronutrients unnecessary.
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy.

Revised January 20, 2014

NOSB Evaluation Criteria for Substances Added To the National List: Crops/Livestock

Category 3. Is the substance compatible with organic production practices? Micronutrients for 

use in aquatic plant production 

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

2. Is the substance compatible with a 

system of sustainable agriculture?

[§6518(m)(7)]

X

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