Updated June 17, 2010 

Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

Date: April 29, 2011

Subject: Pheromones Sunset

Chair: Tracy Miedema

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action X

Guidance Statement 

Other 

Statement of the Recommendation (Including Recount of Vote): 

Relist: §205.601 Synthetic substances allowed for use in organic crop 

production. (f) As insect management. Pheromones.

A motion that would have qualified the listing “provided that they are formulated 

with only approved inert ingredients” was withdrawn.

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

Because pheromones, understood to be an important tool in organic 

production, represent such a broad range of formulations and chemical 

ingredients, the Crops Committee sought to define the class of chemicals 

allowed in this listing by originally recommending the approval of pheromone 

products that are in passive dispensers, have no added toxicants, and only 

include inert ingredients that are approved by this Board. Passive dispensers, 

as understood by the Committee, are those which emit pheromones by 

volatilization rather than by spray and produce a concentration of pheromones 

in a limited area. The committee felt hampered by the lack of technical 

information..

Committee Vote:

Moved: John Foster Second: Tina Ellor

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recusal: 0
National Organic Standards Board 

Crops Committee 

2012 Sunset Recommendation 

Pheromones 

April 29, 2011 

List: §205.601 Synthetic substances allowed for use in organic crop production. 

(f) As insect management. Pheromones. 

Summary 

Pheromones were approved for listing in 1995. In 2002, the board voted to allow List 3 

inerts used in passive pheromone dispensers, through approval of the following 

annotation: 

Pheromones -includes only EPA-exempt pheromone products, EPA-registered 

pheromone products with no additional synthetic toxicants unless listed in this 

section, and any inert ingredients used in such pheromone formulations that are not 

on EPA List 1 (Inerts of toxicological concern) or EPA List 2 (Potentially toxic inerts), 

Provided the pheromone products are limited to passive dispensers. Pheromone 

products containing only pheromones, active ingredients listed in this section, and 

List 4 inerts may be applied without restriction. 

The Crops Committee requested, but did not receive, a Technical Review (TR) for 

pheromones. Although the committee was concerned about making a decision about a 

diverse class of materials without adequate technical information, especially knowing 

that there have been problems with pheromone product ingredients —such as those 

used for the light brown apple moth— the committee wants to preserve the use of these 

products, which have become essential to organic fruit growing. There was discomfort 

around the issue of List 3 inerts being allowed ingredients in a permitted substance, but 

the committee trusts that the inerts task force will be able to update and clarify the 

limitation on inerts in National List substances, and the board will be able to address this 

issue when inerts come up for review. 

The Crops Committee struggled with trying to define a class of pheromones it felt 

comfortable approving as a class, and originally recommended approving pheromone 

products that are in passive dispensers, that have no added toxicants, and that have 

inerts approved by this board. Passive dispensers are those which emit pheromones by 

volatilization rather than by spray and produce a concentration of pheromones in a 

limited area. Eventually, after hearing public comment and failing to receive technical 

input in the form of a TR, and in an effort to emphasize the committee’s desire to control 
Sunset 2012 Recommendation 

Pheromones 

April 29, 2011

Page 2 of 2

inerts present in formulations allowed, the committee proposed to restrict the 

pheromone products to those with approved inert ingredients. 

Committee Recommendation 

The Crops Committee recommends the continued listing of pheromones for insect 

management with the addition of an annotation that limits their formulations to those 

with only approved inert ingredients. The motion was to amend the current listing of 

pheromones to read: “(f) As insect management. Pheromones, provided that they are 

formulated with only approved inert ingredients.” 

Committee Vote 

Motion: John Foster Second: Steve DeMuri 

Yes: 6 No: 0 Absent: 1 Abstain: 0 Recuse: 0