FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: __March 18, 2005_______

Subject: ___Proteinated and Chelated Mineral Complexes Used as Feed Additives___ 

Chair: ____Jim Riddle______________________________________ 

 (sign) 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: ________ 

Guidance Statement: ____X____ 

Other: ________ 

Statement of the Recommendation (including Recount of Vote): 

The NOSB recommends that the USDA National Organic Program post the following questions 

and answers as guidance to producers, manufacturers, consumers, and accredited certifying 

agents. 

Q1. Can proteinated and chelated mineral complexes be used in organic livestock production? 

A1. Yes. Section 205.237(a) allows the use of synthetic feed additives and feed supplements that 

appear on the National List. Section 205.603(d)(2) includes “trace minerals, used for enrichment 

or fortification when FDA approved.” The FDA recognizes the list of feed additives published in 

the Official Publication of the Association of American Feed Control Officials, which is updated 

annually. (see Addendum A). 

§ 205.237 Livestock feed. 

The producer of an organic livestock operation must provide livestock with a total feed ration 

composed of agricultural products, including pasture and forage, that are organically produced 

and, if applicable, organically handled: Except, That, nonsynthetic substances and synthetic 

substances allowed under § 205.603 may be used as feed additives and supplements. 

§ 205.603(d)(2) Trace minerals, used for enrichment or fortification when FDA approved. 

Q2. Can all proteinated and chelated mineral complexes listed by AAFCO be used in organic 

livestock production? 

A2. No, not all formulations of the proteinated minerals may be used. Section 205.105(e) of the 

NOP Final Rule prohibits use of products of excluded methods (genetic engineering). Section 

205.237(b)(5) prohibits the feeding of poultry or slaughter by-products to mammals or poultry. 

Therefore, proteinated mineral complexes that are derived from or contain products of excluded 

methods or slaughter by-products are not allowed in organic livestock production. 
§ 205.237(b) The producer of an organic operation must not: 

(5) Feed mammalian or poultry slaughter by-products to mammals or poultry; 

§205.105 To be sold or labeled as “100 percent organic,” “organic,” or “made with organic 

(specified ingredients or food group(s)),” the product must be produced and handled without the 

use of: 

(e) Excluded methods, except for vaccines, Provided, That, the vaccines are approved in 

accordance with § 205.600(a). 

March 1, 2005 NOSB vote: 12 yes, 0 no, 2 abstain 

Rationale Supporting Recommendation (including consistency with OFPA and NOP):

Rationale provided in text of recommendation. 

Response by the NOP: 

Updated 2/25/05
NOSB Livestock Committee 

Recommendation on Proteinated and Chelated Mineral Complexes 

Used as Feed Additives 

Adopted by NOSB March 1, 2005 

Introduction 

In 2002, the NOSB was petitioned to allow proteinated and chelated mineral complexes 

for use as feed additives or supplements in organic livestock production. After a TAP 

review and supplemental review were conducted, the NOSB has learned that 

proteinated and chelated mineral complexes are listed by the Association of American 

Feed Control Officials (AAFCO) as allowed feed additives. 

The American Association of Feed Control Officials (AAFCO) has defined the various 

types of metal chelates/complexes. Metal proteinates (§57.23) are defined as the 

product resulting from the chelation of a soluble (trace mineral) salt with amino acids 

and/or partially hydrolyzed protein. Protein sources used in these compounds may be 

derived from slaughter byproducts, and some may contain products of excluded 

methods. Such forms are not allowed in organic production. 

In order to provide clarity on the status of these materials, the NOSB has developed 

several questions and answers to provide guidance on proteinated and chelated mineral 

complexes when used as feed additives or supplements in organic livestock production. 

Recommendation 

The NOSB recommends that the USDA National Organic Program post the following 

questions and answers as guidance to producers, manufacturers, consumers, and 

accredited certifying agents. 

Q1. Can proteinated and chelated mineral complexes be used in organic livestock 

production? 

A1. Yes. Section 205.237(a) allows the use of synthetic feed additives and feed 

supplements that appear on the National List. Section 205.603(d)(2) includes “trace 

minerals, used for enrichment or fortification when FDA approved.” The FDA recognizes 

the list of feed additives published in the Official Publication of the Association of 

American Feed Control Officials, which is updated annually. (see Addendum A). 

§ 205.237 Livestock feed. 

(a) The producer of an organic livestock operation must provide livestock with a total 

feed ration composed of agricultural products, including pasture and forage, that 

are organically produced and, if applicable, organically handled: Except, That, 

nonsynthetic substances and synthetic substances allowed under § 205.603 may 

be used as feed additives and supplements. 

§ 205.603(d)(2) Trace minerals, used for enrichment or fortification when FDA approved. 
Q2. Can all proteinated and chelated mineral complexes listed by AAFCO be used in 

organic livestock production? 

A2. No, not all formulations of the proteinated minerals may be used. Section 205.105(e) 

of the NOP Final Rule prohibits use of products of excluded methods (genetic 

engineering). Section 205.237(b)(5) prohibits the feeding of poultry or slaughter byproducts to mammals or poultry. Therefore, proteinated mineral complexes that are 

derived from or contain products of excluded methods or slaughter by-products are not 

allowed in organic livestock production. 

§ 205.237(b) The producer of an organic operation must not: 

(5) Feed mammalian or poultry slaughter by-products to mammals or poultry; 

§205.105 To be sold or labeled as “100 percent organic,” “organic,” or “made with 

organic (specified ingredients or food group(s)),” the product must be produced and 

handled without the use of: 

(e) Excluded methods, except for vaccines, Provided, That, the vaccines are approved in 

accordance with § 205.600(a). 

NOSB vote: 12 yes, 0 no, 2 abstain 
Addendum A: AAFCO list of proteinated and chelated mineral complexes 

57.23 Metal Proteinates: 

IFN 6-09-896 Copper proteinate 

IFN 6-09-897 Zinc proteinate 

IFN 6-26-149 Magnesium proteinate 

IFN 6-26-150 Iron proteinate 

IFN 6-26-151 Cobalt proteinate 

IFN 6-26-834 Manganese proteinate 

IFN 6-16-833 Calcium proteinate 

57.151 Metal (Specific Amino Acid) Complexes: 

IFN Copper lysine complex 

IFN Zinc lysine complex 

IFN 6-16-294 Ferric methionine complex 

IFN 6-19-212 Manganese methionine complex 

IFN 6-16-293 Zinc methionine complex 

57.150 Metal Amino Acid Complexes: 

IFN 6-32-053 Copper amino acid complex 

IFN 6-32-054 Zinc amino acid complex 

IFN 6-32-055 Magnesium amino acid complex 

IFN 6-32-056 Iron amino acid complex 

IFN 6-32-058 Calcium amino acid complex 

IFN 6-32-059 Potassium amino acid complex 

IFN 6-32-060 Manganese amino acid complex 

57.142 Metal Amino Acid Chelates: 

IFN 6-20-981 Calcium amino acid chelate 

IFN 6-20-982 Cobalt amino acid chelate 

IFN 6-20-983 Copper amino acid chelate 

IFN 6-20-984 Iron amino acid chelate 

IFN 6-20-985 Magnesium amino acid chelate 

IFN 6-20-986 Manganese amino acid chelate 

IFN 6-20-987 Zinc amino acid chelate 

57,29 Metal Polysaccharide Complexes: 

IFN 8-09-822 Copper polysaccharide complex 

IFN 8-09-898 Iron polysaccharide complex 

IFN 8-09-899 Zinc polysaccharide complex 

IFN 8-19-206 Magnesium polysaccharide complex 
Addendum B: Excerpts from Comments on the Feb. 12, 2003 Metal Chelates TAP 

Supplement 

Submitted to the NOSB by Dr. Alfred Walker 

• Source of proteins and amino acids for the proteinates 

 The TAP review states that the "nature and method of production of the protein 

component of metal proteinates is confidential to the manufacturer and has not been 

disclosed" and gives no information about the source of the proteins used in these 

supplements. The exact sources of the protein fraction in these products may be 

confidential, but the general sources and processes used are well described in the 

patent literature. There are two main types of protein sources in these products which 

conform to the AAFCO definition of metal proteinates1

: (1) metal- amino acid chelates, 

and (2) loose associations of a soluble metal ion and single or mixture of proteins. 

Association between a metal salt and a hydrolyzed protein: The protein in these 

compounds would be natural. Cost considerations would encourage manufacturers to 

use waste products from other processes and also to alternate protein sources due to 

price fluctuations when possible. Anderson, (1969) describes a Zn proteinate which 

uses the dry residue of yeast fermented corn mash used to produce alcohol (Solulac). 

The protein source consists of 70 % of soluble and 30 % of grains (yeast bodies and 

partially fermented corn). The patent also lists the following natural protein sources that 

could be used to make the Zn proteinate: 

 Non-antibiotic fermentation residue 

 Feed grains like corn and soy bean 

 Livestock and fish by-product meal 

 Molasses soluble 

 Whey 

 Yeast 

 Feather meal 

 Corn gluten feed and meal 

 Dairy by-products 

 Oil seed meal 

 Casein. 

Erickson and Uhren, 2002 describe a method for making metal proteinates for animal 

feed from Chromium leather waste (chrome tanned, unfinished leather shavings, scrap, 

or fleshings). The leather scraps are hydrolyzed and the Cr is precipitated by caustic 

Hydroxide. The resulting soluble protein is then mixed with a soluble metal salt to form 

the proteinate. Proteinates can also be produced from soy protein isolate (Johnson, 99). 

 These protein sources present several potential problems for Organic producers and 

certifiers. All of these sources would still contain intact or partially denatured proteins 

from the original organism. Corn and soy bean proteinates could still contain original 

plant proteins, some of which would be trans-genes. Animal derived protein could be 

from ruminates, and a decision would be needed to determine if they could be fed to 

other ruminates. Since the supplement manufacturer does not need to label the protein 

 

1

 A product resulting from the chelation of a soluble salt with amino acids and/or partially hydrolyzed 

protein. 
source, it would be difficult to impossible for certifiers to verify the protein sources. The 

most workable course would be to allow the use of all metal proteinates, regardless of 

the source of the protein. However, alternatives to metal proteinates are readily 

available. 

References

Anderson, D. R., 1969, Organic Zinc feed additive & method of making same, USP # 

3463858. 

Erickson, P. R., and Uhren, L. J., 2002, Method of producing a metal nutrient for an 

animal feed, USP # 6352714. 

Johnson, L. A., 1999, Process for producing improved soy protein concentrates from 

genetically- modified soybeans, USP # 5936069.