United States Department of Agriculture 1400 Independence Avenue SW. NOP 5033-1

Agricultural Marketing Service Room 2646-South Building Effective Date: December 2, 2016

National Organic Program Washington, DC 20250 Page 1 of 3

File Name: NOP 5033-1 Decision Tree for Classification Syn/NS 12/02/2016 Authorized Distribution: PUBLIC

Guidance 

Decision Tree for Classification of Materials

as Synthetic or Nonsynthetic

Underlined terms defined on page 2

* Excerpted from NOP 5033, 4.6 Extraction of Nonorganic Materials:

• At the end of the extraction process, the material has not been transformed into a 

different substance via chemical change; 

• The material has not been altered into a form that does not occur in nature; and

• Any synthetic materials used to separate, isolate, or extract the substance have been 

removed from the final substance (e.g., via evaporation, distillation, precipitation, or 

other means) such that they have no technical or functional effect in the final product.
United States Department of Agriculture 1400 Independence Avenue SW. NOP 5033-1

Agricultural Marketing Service Room 2646-South Building Effective Date: December 2, 2016

National Organic Program Washington, DC 20250 Page 2 of 3

File Name: NOP 5033-1 Decision Tree for Classification Syn/NS 12/02/2016 Authorized Distribution: PUBLIC

Definitions (bolded terms in 7 CFR 205.2)

Agricultural inputs. All substances or materials used in the production or handling of organic 

agricultural products.

Agricultural product. Any agricultural commodity or product, whether raw or processed, including 

any commodity or product derived from livestock, that is marketed in the United States for human or 

livestock consumption.

Allowed synthetic. A substance that is included on the National List of synthetic substances allowed 

for use in organic production or handling.

Chemical change. A process (i.e. chemical reaction) whereby a substance is transformed into one or 

more other distinct substances.

Enzyme. A protein that catalyzes a chemical reaction.

Extract. To separate, withdraw, or obtain one or more constituents of an organism, substance, or 

mixture by use of solvents (dissolution), acid-base extraction, or mechanical or physical methods.

Formulate. To combine different materials according to a recipe or formula.

Generic. The common and familiar non-proprietary name.

Manufacture. To make a substance from raw materials.

Natural source. Naturally occurring mineral or biological matter.

Naturally occurring biological process. A process that occurs due to the action of biological 

organisms or subcomponents of biological organisms, such as enzymes. Examples of naturally 

occurring biological processes include, but are not limited to, fermentation, composting, manure 

production, enzymatic processes, and anaerobic digestion.

Nonagricultural substance. A substance that is not a product of agriculture, such as a mineral or a 

bacterial culture, that is used as an ingredient in an agricultural product. For the purposes of this part, 

a nonagricultural ingredient also includes any substance, such as gums, citric acid, or pectin, that is 

extracted from, isolated from, or a fraction of an agricultural product so that the identity of the 

agricultural product is unrecognizable in the extract, isolate, or fraction.

Nonsynthetic (natural). A substance that is derived from mineral, plant, or animal matter and does 

not undergo a synthetic process as defined in section 6502(21) of the Act (7 U.S.C. 6502(21)). For 

the purposes of this part, nonsynthetic is used as a synonym for natural as the term is used in the Act.
United States Department of Agriculture 1400 Independence Avenue SW. NOP 5033-1

Agricultural Marketing Service Room 2646-South Building Effective Date: December 2, 2016

National Organic Program Washington, DC 20250 Page 3 of 3

File Name: NOP 5033-1 Decision Tree for Classification Syn/NS 12/02/2016 Authorized Distribution: PUBLIC

Substance. A generic type of material, such as an element, molecular species, or chemical 

compound, that possesses a distinct identity (e.g. having a separate Chemical Abstracts Service 

(CAS) number, Codex International Numbering System (INS) number, or FDA or other agency 

standard of identity).

Synthetic. A substance that is formulated or manufactured by a chemical process or by a process 

that chemically changes a substance extracted from naturally occurring plant, animal, or mineral 

sources, except that such term shall not apply to substances created by naturally occurring biological 

processes.

Table 1. Classification examples of inputs:

Substance Classification Explanation

Ash (burned wood) Nonsynthetic Substance is created by burning biological matter.

Calcium carbonate 

(limestone)

Nonsynthetic Substance is produced from a natural source (mined 

mineral) and does not undergo chemical change.

Calcium oxide 

(quicklime)

Synthetic Substance is produced from a natural source (mined 

mineral), but undergoes chemical change caused by 

heating the mineral.

Citric acid Nonsynthetic Substance is created from a naturally occurring 

biological process (microbial fermentation of 

carbohydrate substances).

Gibberellic acid Nonsynthetic Substance is extracted from a natural source without 

further chemical change

Liquid fish products –

pH adjusted with 

phosphoric acid

Synthetic Substance is derived from a natural source, but is 

treated with synthetic acids for pH adjustment.

Molasses Nonsynthetic Substance is derived from a natural source and 

chemical change is due to heating or naturally 

occurring biological processes.

Newspaper Synthetic Substance is manufactured via a chemical process.

Raw manure Nonsynthetic Substance is from a natural source and used without 

further processing.

Rosemary oil Nonsynthetic Substance is extracted from a natural source.