FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: _March 18, 2005_

Subject: ___Calcium Carbonate Q & As___________________ 

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):

Question # 1: Does the NOP regulation permit livestock producers to use calcium 

carbonate as a feed supplement for livestock intended to be sold, labeled, or represented 

as organically produced? Please provide your rationale.

NOSB Recommended Answer: Yes. Mined calcium carbonate is a nonsynthetic 

substance allowed for use as a feed supplement or feed additive.

Question # 2: Can a mineral product, such as calcium carbonate, carry the term organic 

on its label? Please provide your rationale.

NOSB Recommended Answer: No. Section 205.2 defines “organic” as “a labeling term that 

refers to an agricultural product produced in accordance with the Act and the regulations 

in this part.” 

Calcium carbonate is not an agricultural product and therefore does not qualify to carry 

the term “organic” under the NOP regulation.

NOSB vote: 14 yes, 0 no, 0 abstain

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

Rationale explained in text below. 

Response by the NOP:

Updated 2/25/05 
NOSB Livestock Committee 

Recommended Answers to the Questions: 

“Can Calcium Carbonate Be Fed to Organic Livestock and 

Carry the Organic Label?” 

Adopted by NOSB March 1, 2005 

Introduction: 

The National Organic Program has asked the National Organic Standards Board to 

submit information concerning the status of calcium carbonate when used in livestock 

feed. 

Background: 

The following scenario has been presented to the National Organic Program (NOP) for 

clarification: 

A manufacturer of calcium carbonate has asked whether his product can be fed to organic 

livestock and carry the organic label (manufacturer does not want to use the USDA 

organic seal). The calcium carbonate is mined, screened, and sold as a feed supplement 

to livestock. The substance can be either mixed with the animal feed or consumed as a 

stand-alone supplement. No synthetic substances are used in the manufacturing process. 

Question # 1: 

1. Does the NOP regulation permit livestock producers to use calcium carbonate as a 

feed supplement for livestock intended to be sold, labeled, or represented as 

organically produced? Please provide your rationale. 

NOSB recommended response:

Yes. Mined calcium carbonate is a nonsynthetic substance allowed for use as a feed 

supplement or feed additive. 

Section 205.237 “Livestock feed” states: 

“(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.” 

Question # 2: 

2. Can a mineral product, such as calcium carbonate, carry the term organic on its 

label? Please provide your rationale. 
NOSB recommended response:

No. Section 205.2 defines “organic” as “a labeling term that refers to an agricultural 

product produced in accordance with the Act and the regulations in this part.” 

Calcium carbonate is not an agricultural product and therefore does not qualify to carry 

the term “organic” under the NOP regulation. 

Section 205.301(e) “Livestock feed” states: 

“(1) A raw or processed livestock feed product sold, labeled, or represented as “100 

percent organic” must contain (by weight or fluid volume, excluding water and salt) not 

less than 100 percent organically produced raw or processed agricultural product. 

Section 205.301(e) further states: 

“(2) A raw or processed livestock feed product sold, labeled, or represented as "organic” 

must be produced in conformance with § 205.237.” 

Since mined calcium carbonate is allowed as a nonsynthetic feed supplement or feed 

additive under 205.237, a blended feed ration containing calcium carbonate, other 

approved ingredients, and 100% organic raw or processed agricultural products can be 

labeled “organic livestock feed.” 

Committee vote: 5 yes, 0 no, 3 absent 

NOSB vote: 14 yes, 0 no, 0 abstain