FORMAL RECOMMENDATION EXECUTIVE SUMMARY BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP)

Chair: __Rigoberto Delgado _______ Final Vote Date: _ May 22, 2008 

Subject: __Re-Affirmation of Recommendation for Cellulose for re-listing on § 205.605b 

 

Type of Recommendation (Petitioned Materials should use Materials Recommendation Form):

 Sunset Material(s): ____X_____ 

 Non-Material: _________ 

The NOSB hereby recommends to the NOP the following:

Rulemaking Action: ___X__ 

Guidance Statement: ________ 

Other: ________ 

Summary Statement of the Recommendation (including Vote) and attach more complete narrative, 

and/or original committee narrative and recommendation, if sufficient:

The Board Re-affirms it’s recommendation made at it’s Fall 2007 Meeting for the continuation of 

Cellulose on the National List under section 205.605b Nonagricultural (non-organic) substances allowed 

as ingredients in or on processed products labeled as “organic” or “made with organic (specified 

ingredients or food group(s)).” 

NOSB Vote: 

Motion: Julie Weisman Second: Steve DeMuri 

Board vote: Yes - 13 No - 0 Abstain - 1 Absent- 1 Recuse - 0 

Summary Rationale Supporting Recommendation (cite consistency with OFPA and NOP) and attach 

with more complete narrative: 

Demonstrated continued use in handling. No organic substitute available at this time. 

An additional ANPR for the continued listing on § 205.605b of Cellulose published after the Fall 2007 

meeting elicited a number of public comments in support and none opposing the re-listing of these 

materials on the National List. 

Response by the NOP:
National Organic Standards Board 

Formal Recommendation for Sunset Review of Materials on 

§ 205.605b 

May 22, 2008 

I. List: 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on 

processed products labeled as “organic” or “made with organic (specified ingredients or 

food groups.” 

(b) Synthetics allowed 

II. Committee Summary: 

Public notice of the sunset of this material, which was embedded in the Federal Register Notice 

of the Fall 2007 NOSB meeting, had elicited no public comments by early October when this 

committee was due to give its recommendation on the continued use of Cellulose. An additional 

ANPR for materials due to Sunset in the Fall of 2008, was published on December 28, 2007. 

Review of the original TAP did not reveal unacceptable risks to the environment, human or 

animal health as a result of the use or manufacture of this material. There is no new information 

contradicting the original TAP review which was the basis for previous NOSB decisions to list 

this substance. 

 Even though this material appeared not to present a risk to the environment, the sunset process 

requires public comment to support the continuation of this regulation. For this reason the initial 

recommendation of the Handling Committee in early October for the re-listing of this material 

failed. 

In the eight weeks prior to the Board meeting, numerous comments were received requesting that 

these materials be re-listed and there had been no comments received opposing their continued 

use in organic handling. Motion for the Handling Committee to reconsider their earlier votes was 

made and seconded prior to discussion at the November NOSB meeting where the full Board 

voted to recommend these materials for re-listing. 

The ANPR in December elicited numerous additional comments in favor of and none opposing 

the re-listing each of these materials. 
III. Board Recommendation(s): 

The Board re-affirms it recommendation of November 2007 for the re-listing of the following 

substances in this use category as published in the final rule: 

Cellulose 

Moved: Julie Weisman Second: Jennifer Hall 

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