National Organic Standards Board

Materials Subcommittee Discussion Document

Marine Materials in Organic Crop Production 

June 12, 2018

SUMMARY:

This discussion document explores the issue of environmental impact of harvesting marine vegetation1

for organic crop production inputs through a proposed requirement that aquatic plants under §205.601 

(j)(1) and other nonsynthetic uses of marine vegetation be certified organic to the wild crop standard

§205.207. Guidance is needed to elaborate how the wild crop standard is applied in a marine 

environment and how certifiers and producers can meet the condition that harvesting “will not be 

destructive to the environment”. 

INTRODUCTION: 

Seaweeds have been commonly used throughout human history. They comprise a seemingly unlimited 

renewable resource; however, they are subject to the usual depletion through unintended overharvesting and pollution. The laws that control harvesting, establish conservation zones, and seek to 

ensure sustainable seaweed harvest worldwide are highly variable, typically poorly articulated, and not 

easy to enforce. Some seaweed species grow back very quickly following harvest, while others take 

many years. Because of high demand, harvesting does not necessarily protect biomass and rarely 

involves ecosystem management. Little is understood about the multi-trophic impact of seaweed 

harvesting or cultivation.

There are nine separate listings for marine materials on the National List; however, only one is the 

subject of this discussion document: §205.601 (j)(1) Aquatic Plant Extracts. Aquatic Plant Extracts 

incorporating Ascophyllum nodosum, Sargassum spp., and Laminaria spp. are used as fertilizers for 

organic farming (TR lines 514-16). Marine materials are also used in nonsynthetic form as soil 

conditioners. 

Approximately 50,000 metric tons of wet seaweed is harvested annually, yielding 10,000 metric tons of 

seaweed meal (TR lines 238-39). The Food and Agriculture Organization’s 2004 Report, “The State of 

World Fisheries and Aquaculture” noted:

In 1991, it was estimated that about 10,000 tonnes of wet seaweed were used annually to make 

1,000 tonnes of seaweed extracts with a value of US$5 million. However, since that time the 

market has probably doubled as the usefulness of these products has become more widely 

recognized and organic farming has increased in popularity2

. 

As this report is fourteen years old and the organic industry larger, the current figures is surely

considerably higher. The high fiber content of the seaweed acts as a soil conditioner and assists 

moisture retention, while the mineral content is a useful fertilizer and source of trace elements (TR lines 

241-42). An area of growth in seaweed fertilizers is in the production of liquid seaweed extracts that 

can be produced in concentrated form for dilution by the user. Seaweed fertilizers can be applied 

directly onto plants or watered in around the root areas. Organic farming provides a market for liquid 

1 This Discussion Document looks only at marine vegetation and does not address freshwater vegetation or fish. 2 Food and Agriculture Organization (FAO). 2014. The State of World Fisheries and Aquaculture. FAO of the United Nations. 

Rome, Italy. 154 pp.

NOSB Oct 2018 proposals and discussion documents pg. 27 of 204
seaweed fertilizers as a result of wider recognition of the usefulness of the products and their 

effectiveness in growing of vegetables and some fruits (FAO 2004) (TR lines 247-51). 

BACKGROUND: 

During the 2015 sunset review of almost 200 materials, the NOSB and public comment noted concern 

that in the years since these materials were added to the National List, global harvesting has increased, 

overharvesting of many marine macro-algae has occurred, and the potential for contamination and 

destruction of marine ecosystems has accelerated. 

In order to more fully examine marine materials in organic production, a Technical Report (TR) was 

obtained in 2016. The NOSB submitted brief information on each of the nine materials on the National 

List and posed seven questions regarding nomenclature, overharvesting, selective harvesting, 

contamination, certified organic wild crafting, cultivation, and CO2 sequestration. 

Based on the issues raised in the TR, a Discussion Document was posted in Fall 2016, and the following 

three questions were posed: 

1. Should the naming conventions of the marine plant/algae listings on the National List be 

consolidated and/or clarified to avoid redundancies and duplication, using Latin binomials?

2. Should annotations be written to clarify specific uses or harvesting guidelines for any of the 

marine algae listings, such as “no machine harvesting of Ascophyllum” and “Not harvested from 

a conservation area identified by State, Federal, or International bodies”?

3. Is there a need for further NOP Guidance on marine plants/algae?

Considerable public comment, both written and oral, was provided for the Fall 2016 NOSB meeting and 

was extensive and substantive in nature.

In the Spring of 2017, the Handling Subcommittee brought forth a proposal recommending that the 

marine algae materials be annotated with Latin binomials where possible, or by Class, and that the NOP 

develop Guidance to clarify the term “kelp” as used in organic production and wild harvesting. An 

identical proposal was brought forth in the Crops Subcommittee with a motion to amend the listing for 

Aquatic Plant Extracts to read (proposed changes are underlined): 

Aquatic plant extracts (other than hydrolyzed) derived from brown seaweeds, class 

Phaeophyceae. –Extraction process is limited to the use of potassium hydroxide or 

sodium hydroxide; solvent amount use is limited to that amount necessary for 

extraction.

Upon receipt of public comments stating that the annotations needed further justification and support 

and that stakeholders required more time to reflect upon the potential impacts of the proposals, both 

the Handling and Crop proposals were sent back to subcommittee for additional work. For the Fall 2017 

meeting, the Handling Subcommittee reissued their proposal in the form of a discussion document to 

solicit additional input.

With respect to the Crops proposal to annotate §205.601 (j)(1) Aquatic Plant Extracts, public comment 

revealed that there are a number of aquatic plant products containing more than the brown class of 

seaweed. OMRI conducted a search of OMRI-listed crop input products that contain aquatic plant 

extracts and found: 

“Of the 75 OMRI Listed products that contain aquatic plants as an ingredients:

· 48 contain brown algae (Ascophyllum Nodosum, Sargassum, Durvillaea Potatorum, Egregia 

menziesii, Laminaria spp., Pelagophycus sp. and/or Macrocystis integrifolia)

NOSB Oct 2018 proposals and discussion documents pg. 28 of 204
· 5 contain red (Gelidium sp.) and/or green (Ulva sp.)

· 22 products do not have information about seaweed species”.

Additionally, Table 5 of the 2016 TR lists the following species used for agricultural production and their

country of origin: 

• Chlorophyta (Green)- Dictyosphaeria cavernosa Kenya; Enteromorpha spp. Portugal; Ulva spp.

Italy, Portugal

• Rhodophyta (Red)- Ahnfeltia plicata Chile; Gracilaria spp. Portugal; Gracilaria chilensis New 

Zealand; Halymenia venusta Kenya; Laurencia papillosa Kenya, Philippines; Lithothamnion 

corallioides France, Ireland, UK; Phymatolithon calcareum France, Ireland, UK

• Phaeophyta (Brown)- Ascophyllum nodosum France, Canada, China, Iceland, US; Ecklonia 

maxima South Africa; Fucus spp. France; Fucus gardneri Canada; Hydroclathrus clathratus

Philippines; Laminaria schinzii South Africa; Macrocystis pyrifera Australia; Nereocystis 

luetkaena Alaska, Canada; Sargassum spp. Brazil, Vietman; Turbinaria spp. Vietnam 

Given that there are aquatic plant input products using green, red, and brown algae, the Crops 

Subcommittee determined to re-examine its approach to this issue.

While the Spring 2017 proposal focused on nomenclature, questions over the environmental impact of 

marine material harvesting for organic production are of concern. The TR explores the issue of 

“sustainable harvesting”, but a lack of an agreed-upon means of defining, measuring, and enforcing such

practices makes the term problematic. Consequently, this Discussion Document instead looks at ways of 

addressing the environmental impact of harvesting marine materials for organic crop production. It 

poses the idea of requiring that all marine materials used in crop input products be certified organic. As 

most of these materials would be certified to the wild crop standard, we explore the issue of better 

defining, measuring, and enforcing the requirement under §205.207 (b) that wild harvesting “will not be 

destructive to the environment”.

Note: Much of the research, text, and goals of this Discussion Document are the effort of former NOSB 

member, Dr. Jean Richardson, and were completed prior to the end of her term in January 2017. Thank 

you to Dr. Richardson for spearheading this within the NOSB and for providing a framework from which 

to continue the important work on this topic.

RELEVANT AREAS OF THE RULE, NOP GUIDANCE, NOP POLICY MEMO, and OMRI: 

§205.601 Synthetic substances allowed for use in organic crop production

In accordance with restrictions specified in this section, the following synthetic substances may be used 

in organic crop production: Provided that, use of such substances does not contribute to contamination 

of crops, soil, or water...

(j) As plant or soil amendments. 

(1) Aquatic plant extracts (other than hydrolyzed) –Extraction process is limited to the use of 

potassium hydroxide or sodium hydroxide; solvent amount use is limited to that amount 

necessary for extraction.

§205.207 Wild-crop harvesting practice standard.

(a) A wild crop that is intended to be sold, labeled, or represented as organic must be harvested from a 

designated area that has had no prohibited substance as set forth in §205.105, applied to it for a period 

of 3 years immediately preceding the harvest of the wild crop.

NOSB Oct 2018 proposals and discussion documents pg. 29 of 204
(b) A wild crop must be harvested in a manner that ensures that such harvesting or gathering will not be 

destructive to the environment and will sustain the growth and production of the wild crop.

§205.200 General.

Production practices ... must maintain or improve the natural resources of the operation, including soil 

and water quality.

NOP 5022, effective July 22, 2011, Guidance: Wild Crop Harvesting provides details to clarify §205.207, 

including:

Section 205.200 states that production practices must maintain or improve the natural 

resources of an operation under organic certification. This applies to all types of organic 

certification, including wild crops. Unmanaged, untrained and uninformed harvesting of wild 

products from a wild habitat without maintaining or improving the natural resources can 

disqualify the wild products from organic certification.

Additionally, the Guidance states: 

4. A description of the proposed ecosystem management and harvesting practices, the impact 

of their proposed harvesting on the long-term viability of the wild species and on the area’s 

ecosystem, and information on any equipment planned for use or being used to harvest and 

manage the wild-crop and ecosystem.

a. This should include a description of the monitoring system that will be used to 

ensure that the crop is harvested in a sustainable manner that does not damage the 

environment, including soil and water quality.

5. A list of any rare, threatened, or endangered terrestrial or aquatic plants or animals that 

occur in the harvest area.

a. The presence of rare, threatened, or endangered species in a wild harvest area does 

not automatically disqualify an operation from organic certification, but any 

potential or actual impacts need to be described and addressed.

b. If there are potential or actual negative impacts resulting from the wild crop 

management and harvesting, actions that address and correct these impacts need 

to be described, implemented, and monitored.

6. The procedures employed that prevent contamination from adjoining land use or other 

point or non-point sources contamination.

7. The training provided and the procedures employed to ensure that all collectors harvest 

crops in accordance with the OSP and in a manner that does not damage the environment.

NOP 5020, effective 1/15/16, Guidance: Natural Resources and Biodiversity Conservation clarifies

organic regulations at 7 CFR 205.200 that states, “to maintain or improve the natural resources of the 

operation....”.

NOP Policy Memo 12-1, Production and Certification of Aquatic Plants, issued September 12, 2012 

provides further clarification as follows:

This policy memorandum is issued as a reminder that aquatic plants and their products may be 

certified under the current USDA organic regulations. Certifiers and their clients may use the 

USDA organic regulations, including the National List of Allowed and Prohibited Substances at 7 

Code of Federal Regulations (CFR) 205.601-205.602, as the basis for the production and 

certification of cultured and wild crop harvested aquatic plants. 

NOSB Oct 2018 proposals and discussion documents pg. 30 of 204
While current USDA organic regulations specifically exclude aquatic animals from organic 

certification, no such exclusion exists for aquatic plants. Further, some parts of the USDA organic 

regulations specifically address aquatic plant production. For example, some aquatic plants, 

such as kelps and seaweeds, are listed in 7 CFR 205.606 of the USDA organic regulations, 

allowing their use in non-organic form when certified organic forms are not commercially 

available. Producers and certifiers are required to comply with the USDA organic regulations 

when producing or certifying cultured and wild crop harvested aquatic plants. 

The use of ground and surface waters, ponds, streams, or other waterways for aquatic plant 

production may be regulated by Federal, State, or local authorities. Aquatic plant producers 

should consult with Federal, State, and local authorities to ensure compliance with all applicable 

laws, in addition to the USDA organic regulations, regarding the use of synthetic substances and 

other materials in ponds and waterways. Also, under 7 CFR 205.200, aquatic plant producers 

must ensure, and certifying agents must verify, that production practices maintain or improve 

the natural resources of the operation, including soil and water quality. 

OMRI definition of Kelp in Crop Production: 

The dried marine algae of the botanical divisions of Rhodophyta (red algae), Phaeophyta (brown algae),

and Chlorophyta (green algae) (AAPFCO). 

PREVIOUS PUBLIC COMMENT AND TECHNICAL REPORT: 

Following the receipt of the 2016 limited scope TR, the NOSB presented questions to the public in a 

November 2016 Discussion Document. Thousands of pages of public comment and peer-reviewed 

scientific research articles were received in Fall 2016, providing the NOSB with a substantive body of 

documented research from a number of perspectives which helped form this Discussion Document.

Public comment included concerns for the following:

• Conservation of wild marine algae 

species, and marine ecosystems.

• Lack of clarity as to which species are 

allowed on the National list and 

confusion over names used.

• Overharvesting of some species in some 

geographic areas. 

• Need for clarification of which species 

are used, and from which geographic 

areas. 

• Desire to encourage organic cultivation 

and wild harvesting of marine 

materials.

• Need for clarification of which species 

can or are being cultivated. 

• Clarification of wild harvesting 

techniques. 

• Feasibility of harvesting by individual 

species selection as opposed to multispecies harvesting by littoral or marine 

zone

• Extraction methods. 

• Sequestration of metals or other 

contaminants in some wild and 

cultivated algal species.

Of the seven questions posed in the limited scope TR in 2016, three are most relevant to this discussion 

document:

1. Overharvesting: The nine listings include thousands of species of algae from many different 

geographic locations, the marine intertidal zone, deeper ocean areas, and wild harvested beds. Which 

species, genera, classes are being overharvested? Which geographic regions indicate overharvesting 

NOSB Oct 2018 proposals and discussion documents pg. 31 of 204
impact? What is the trend in harvesting marine algae? What is the present status and trends in 

harvesting and overharvesting of Ascophyllum nodosum?

Public comment received from producers of seaweed materials provided statements that 

overharvesting is not an issue, or if it was that there are regulations in place to control harvesting. By 

contrast, other public comment by marine biologists and the international research community

indicates that overharvesting and harvesting in such a manner that ecosystem structures are destroyed 

is relatively widespread and inadequately monitored or regulated.

The TR provides examples of the following seaweeds being overharvested: Irish Moss (Chondrus 

crispus), Rockweed (Ascophyllum nodosum) and giant Kelp (Macrocustis pyrifera) (TR lines 523-24). 

“Kelp and rockweed, are foundational species forming large expansive marine habitats 

supporting a diverse range of wildlife, including other algal species, marine animals and many 

species of protozoans and bacteria (Seeley and Schlesinger, 2012). Without a good accounting of 

all of the species present it is hard to predict the effects of harvesting rockweed and kelp on 

each ecological niche. Thus, it has been important to recognize that sustainable seaweed 

production perceived as reproducible harvest capacity, may not guarantee the sustained 

subsistence of each resident species. Although not part of any agricultural waste stream, 

extracts from wild-harvested kelp and rockweed are allowed for use in organic production as 

soil amendments (§205.601(j)(1)). (TR lines 528-35)

Rockweed has an important role as habitat, as food and as a nutrient source supporting a 

community of organisms that inhabit its “forests.” Any cutting of rockweed can produce an 

effect on the supported eco-communities. Furthermore, many aspects of this ecosystem have 

not been elucidated, encouraging more precaution as the brown algae “forestry” industry grows 

into the future (Seeley and Schlesinger, 2012).” (TR lines 356-60)

It must also be noted that ocean warming and other environmental factors probably contribute to 

depletion of these species (see also: Halat et al. 20153

, Kay et al. 20164, and TR lines 579-83). 

Overharvesting impacts not only the specific plant species or genus but all the associated plant and 

animal species which form the marine ecosystem in a given location (see also: Keats et al. 19875

, Kelly

20056

, and TR lines 597-611). 

Seaweeds, particularly those that form canopy structures, such as rockweed, are bioengineers and 

contribute to a highly productive habitat. Their presence helps to reduce the physical stresses of the 

intertidal habitat. Some of their key ecological functions include nutrient cycling and maintaining water 

quality. Seaweeds provide a habitat and food source for numerous invertebrates and fish, grazers and 

feeders, and maintain water quality. They also provide a physical barrier against waves, protecting the 

shore and inhabiting species. As such, certain species that are slow to regenerate from moderate 

harvesting or have substantial benthic repercussions from their removal, may not be compatible with 

3Halat L, Galway ME, Gitto S, Garbary D. 2015. Epidermal shedding in Ascophyllum nodosum (Phaeophycea): seasonality, 

productivity and relationship to harvesting. Phycology. 54(6):599-608. 4 Kay LM, Schmidt AL, Wilson KL, Lotze HK. 2016. Interactive effects of increasing temperature and nutrient loading on the 

habitat-forming rockweed Ascophyllum nodosum. Aquatic Botany. 133:70-78. 5 Keats DW, Steele DH, South GR. 1987. The role of fleshy macroalgae in the ecology of juvenile cod (Gadus morhua) in inshore 

waters off eastern Newfoundland. Journal of Zoology. 65:49-53. 6 Kelly E (editor). 2005. The role of Kelp in marine environment. Irish Wildlife Manuals No. 17, National Parks and Wildlife 

Service. Dept. Environment, Heritage, and Local Govt. Dublin. 

NOSB Oct 2018 proposals and discussion documents pg. 32 of 204
organic principles.7

 

For example, maerl harvesting off the northeast Atlantic has long-term repercussions. "Maerl beds 

represent a non-renewable resource as extraction and disruption far out-strips their slow rate of 

accumulation”8

. The authors of a review of branch growth rates noted, "although rapid on a geological 

time-scale these accumulation rates are far too low for the maerl to be regarded as a sustainable 

resource for extraction for agricultural and industrial use"9

. A study of the same region concluded that 

maerl dredging was a major threat to the habitat and that there is more to be gained from protecting 

rather than exploiting these habitats10. 

Some species have relatively rapid growth rates and reproductive techniques that allow for 

replenishment with intentional harvesting rates. Seaweed harvesting must ensure the proper stem 

length is left attached to the underlying substrate. Reproduction will then occur from this stem, 

promoting a second generation of seaweed growth from both the intact stem and the recruitment of 

new plants. The species replenishment rate and frequency of harvest are, therefore, critical factors 

impacting future seaweed generations and the marine habitat. Failing to take species and harvest rate 

into account can result in seaweed plots that are quickly exploited and, over time, lead to long-lasting 

damage to the benthic and trophic communities. Frequent harvests may also have impacts on the 

heterogeneity of age classes within a seaweed population. This means the population will eventually 

only consist of young seaweed that are not only smaller than older seaweeds, but may then be 

harvested before their full life cycle is completed. This could have recruitment and reproductive impacts 

on future generations in terms of sustainability.

11 

In the case of rockweed, even studies that indicate environmental resilience to commercial harvesting 

note that though extraction may, in some cases, represent a low percentage of annual biomass 

production, but “the lack of knowledge of energy pathways prevents us from concluding that this is a 

low level of ecological impact”12. Some research has shown that fallow periods are necessary for 

sustainable harvesting. Fallow periods also prevent the encroachment of faster growing species. The 

7 Maine Department of Marine Resources. 2014. Fishery Management Plan for Rockweed (Ascophyllum Nodosum). Maine 

Department of Marine Resources & Rockweed Plan Development Team. 51 pp.; Werner A, Kraan S. 2004. Review of the 

potential mechanization of kelp harvesting in Ireland. Marine Environment and Health Series 17; McCook LJ, Chapman ARO. 

1991. Community succession following massive ice scour on an exposed rocky shore: effects of Fucus canopy algae and of 

mussels during late succession. Journal of Experimental Marine Biology and Ecology. 154:137-169; Lamote M, Johnson LE. 2008. 

Temporal and spatial variation in the early recruitment of fucoid algae: the role of microhabitats and temporal scales. Marine 

Ecology Progress Series. 368:93-102; Watt CA, Scrosati RA. 2013. Bioengineer effects on understory species richness, diversity, 

and composition change along an environmental stress gradient: Experimental and mensurative evidence. Estuarine, Coastal 

and Shelf Science. 123:10-18; McCook LJ, Chapman ARO. 1997. Patterns and variations in natural succession following massive 

ice-scour of a rocky intertidal seashore. Journal of Experimental Marine Biology and Ecology. 214:121-147.

8 Barbera C, Bordehore C, Borg JA, et al. 2003. Conservation and management of northeast Atlantic and Mediterranean maerl 

beds. Aquatic Conservation: Marine and Freshwater Ecosystems. 13:S65-S76. 9 Bosence D, Wilson J. 2003. Maelr growth, carbonate production rates, and accumulation rates in the northeast Atlantic. 

Aquatic Conservation: Marine and Freshwater Ecosystems. 13:S21-S31. 10 Hall-Spencer JM, Grall J, Moore PG, Atkinson RJA. 2003. Bivalve Fishing and maerl-bed conservation in France and the UK—

retrospect and prospect. Aquatic Conservation: Marine and Freshwater Ecosystems. 13:S33-S41. 11 Jenkins SR, Norton T, Hawkins SJ. 2004. Long term effects of Ascophyllum nodosum canopy removal on mid shore community 

structure. Journal of the Marine Biological Association of the UK. 84(02):327-329.

12 Sharp GJ, Pringle JD. 1990. Ecological impact of marine plant harvesting in the northwest Atlantic: a review. Hydrobiologia. 

204/205:17-24. 

NOSB Oct 2018 proposals and discussion documents pg. 33 of 204
undisturbed seaweed population can therefore sustain other dependent populations for longer periods 

of time, establishing the trophic benefits of a stable ecosystem. Additionally, fallow periods allow 

seaweed to gain biomass overtime. Many species reach peak size after two or three years13. 

2. Selective harvesting: There are about 6,500 species of red algae (Rhodophyta) such as Chondrus 

species, Palmiria, Delessaria; about 2,000 species of brown algae (Phaeophyta) such as Laminaria 

species, Ascophyllum species, Sacharina, Fucus, Sargassum muticum; and about 1,500 green algae 

(Chlorophyta) such as Dunaliella, of which many are not marine. How many species of each class are 

being wild harvested? Can one species be harvested without impacting other species in the same 

location?

The TR indicates that there is limited research on algal species harvested for economic purposes. An 

additional literature search shows some work has been done on multi-tropic consequences of kelp 

harvest on the coast of Norway, indicating negative impacts of kelp harvesting on fish abundance and 

diminishment of coastal seabird foraging efficiency (Lorentsen et al, 201014). Lorentsen points out that 

kelp fisheries are currently managed in order to maximize net harvest of kelp biomass, and the 

underlying effects on the ecosystem are partly ignored. 

A Literature review did not turn up any scientific research comparing certified organic kelp harvesting 

with non-certified wild harvesting.

There is peer-reviewed research on the habitat impact of seaweed on common eider ducks (such as 

Blinn et al. 200815), fish impact in Nova Scotia (such as Black 199116), and impact of mechanical 

harvesting on Ascophyllum (such as Ang 199317, Ang 199618, and Arzel 199819). There is considerable 

research on Ascophyllum harvesting impacts, including findings in the 2016 TR. “As with other areas 

where Ascophyllum nodosum and Laminaria digitata are harvested commercially, ecological concerns 

about changes in species diversity resulting from harvesting have been noted (Ingolfsson 2010) (TR lines 

892-96).

3. Cultivation: Which species are being cultivated, and in which geographic locations? What are the 

environmental issues associated with farming marine algae?

Not all marine algal species are easily or economically cultivated. For example, Ascophyllum nodosum

(Rockweed), a species widely harvested and overharvested for aquatic plant extracts and alginic acid, is 

13 Maine Department of Marine Resources. 2014, supra note 6; Werner A, Kraan S. 2004, supra note 6; Wippelhauser GS. 1996. 

Ecology and Management of Maine’s Eelgrass, Rockweeds, and Kelps. Maine Natural Areas Program, Department of 

Conservation. Maine.

14 Lorentsen SH, Sjotun K, Gremillet D. 2010. Multi-tropic consequences of kelp harvest. Biological Conservation. 143:2054-

2062. 

15 Blinn BM, Diamond AW, Hamilton DJ. 2008. Factors affecting selection of brood-rearing habitat by common eiders (Somateria 

mollissima) in the Bay of Fundy, New Brunswick, Canada. Waterbirds. 31:520-529. 16 Black R, Miller RJ. 1991. Use of intertidal zone by fish in Nova Scotia. Environmental Biology of Fishes. 31:109-121. 17 Ang PO, Sharp GJ, Semple RE. 1993. Change in the population’s structure of Ascophyllum nodosum due to mechanical 

harvesting. Hydrobiologia. 260/261:321-326. 18 Ang PO, Sharp GJ, Semple RE. 1996. Comparison of the structure of populations of Ascophyllum nodosu, (Fucales, 

Phaeophyta) with different harvest histories. Hydrobiologoa 326/237 179-184. 19 Arzel P. Les luminaires sure les cotes bretonnes. Evolotion de l’exploitation et de la flottille de peche, actuel et perspectives. 

Editions IFREMER BP 70-29280. Plouzane, France. 139 pp.

NOSB Oct 2018 proposals and discussion documents pg. 34 of 204
a brown seaweed which is not economic to cultivate. By contrast, Laminaria saccharina is easy to 

cultivate. The TR provides considerable detail on seaweed farming of many species worldwide. 

As with terrestrial agriculture, focusing on the production of any few select species could lead to 

monoculture plots of those species. While this makes harvesting species of interest easier, these plots 

are then susceptible to diseases and may limit the resources available to other organisms in the 

ecosystem. Additionally, some native seaweed beds are wiped out to make room for the more 

profitable species. Various studies have elaborated on the detrimental effects of invasive seaweed 

cultivation. Without competition or predators, invasive seaweeds can colonize on thriving corals 

eventually causing death. There is also the potential for epiphyte outbreaks or species diversity 

declines.20 

DISCUSSION:

This discussion document proposes a new way of looking at the sourcing of materials for organic 

production. Currently, there is inconsistency in the review and use of inputs for organic production. 

Synthetic materials are closely evaluated through the material petition and sunset review processes

while natural materials allowed under the regulations receive relatively little scrutiny. Nonsynthetic 

inputs deserve equal assessment for their impact on the environment, including contamination during 

manufacture or extraction and adverse impacts on biodiversity. While it could be said that organic areas 

of use of marine materials are of least concern in terms of the quantity of the overall harvest, it does not 

prevent the organic community from examining the impact the industry is having on marine ecosystems. 

It is similar in many respects to the requirement that organic livestock be fed organic feed, as in the case 

of NOP 5027 Guidance: The Use of Kelp in Organic Livestock Feed that clarifies that marine materials

used as a livestock feed must be certified organic to the wild crop standard.

The use of seaweed as a fertilizer presents a comparatively unique situation in organic certification: 

materials are largely harvested from wild native ecosystems as inputs for organic crop production 

products—both synthetic (aquatic plant extracts) and natural (soil conditioners). The review above

illustrates the importance of addressing the effects of seaweed harvesting on wild native ecosystems, 

both in terms of cultivated and wild seaweed. 

In the absence of a universal standard for “sustainable harvest” within marine environments, and given 

the goal of limiting ecological harm from seaweed harvesting, this discussion document explores a 

means of addressing the environmental impact of harvesting seaweed for use in organic crop 

production through existing organic certification tools. In addition to addressing environmental impact, 

requiring organic certification to the wild crop standard would also help mitigate potential 

contamination issues which are also dealt with in terrestrial farming systems, particularly in relation to 

drift. Delineated no-cut buffer zones could also serve as conservation areas.

Nevertheless, the wild crop standard is quite general in its language when it requires that “a wild 

crop must be harvested in a manner that ensures that such harvesting or gathering will not be 

20 Cottier-Cook EJ et al. 2016. Safeguarding the future of the global seaweed aquaculture industry. United Nations University 

(INWEH) and Scottish Association for Marine Science Policy Brief. ISBN 978-92-808-6080-1. 12pp.; Werner & Kraan, 2004, supra

note 5; Zemke-White WL, Smith JE. 2006. Environmental Impacts of Eucheuma spp. Farming. In: Critchley AT, Ohno M, Largo 

DB, editors. World Seaweed Resources. Degussa, Amsterdam; Lindeberg MR, Lindstrom SC. 2010. Field guide to seaweeds of 

Alaska. University of Alaska Fairbanks, Alaska: Sea Grant College Program; Aquenal Pty Ltd. 2008. National Control Plan for 

Japanese Seaweed or Wakame Undaria Pinnatifia. Rep. Australian Government.

NOSB Oct 2018 proposals and discussion documents pg. 35 of 204
destructive to the environment and will sustain the growth and production of the wild crop.” This 

standard encompasses both terrestrial and aquatic systems of production and therefore includes a

broad range of crops, from herbs to mushrooms to kelp, for example. NOP 5022 Guidance: Wild Crop 

Harvesting addresses some of this; however, there remains much in the wild crop standard that is 

subjective in interpretation. Each certifying agency is left to develop its own guidelines for enforcing 

these standards. 

Some certifiers who currently certify both wild harvested and cultivated seaweed to the wild crop 

standard have expressed a strong desire for more explicit standards for marine ecosystems, stating that 

it is challenging to try to adopt terrestrial criteria to an aquatic system. Further NOP guidance on 

applying both the wild crop standard, NOP 5022 Guidance: Wild Crop Harvesting, and NOP 5020

Guidance: Natural Resources and Biodiversity Conservation could help elucidate questions of avoiding 

prohibited substances, prohibitions of harvesting in conservations areas, safeguarding biodiversity 

conservation, and evaluating long-term harvest impacts, among other concerns. Organic wild crop 

harvesting should aim at not changing the natural environment. While this may be difficult to predict 

and will vary significantly by location and species, it is important for maintaining the complicated 

interactions that take place within the local ecosystem. Clear demarcations of harvesting areas, 

ecosystem health assessments, detailed species identifications and population figures, and exposure to 

potential contaminants would be base appraisals. Some specific evaluation questions could include:

• How does structural change from harvest benefit/detract from habitat? 

• How does architecture of the harvested species affect associated species? 

• How much loss/change is too much? 

• Assess the long-term effects of harvesting on a large spatial scale. 

• What is the difference between the commercial harvest rate and natural mortality in a given 

year in different areas of the harvest zone? 

• Will cumulative effects of successive harvest restructure habitat and/or ecosystems?21

The topic of marine materials is vast and complicated, and the proposed recommendations below are a 

first step in approaching the issue. Future work to safeguard against negative environmental impact 

might include specifying which species, geographic regions, and/or methods of harvest are allowed or 

prohibited. Currently, there are no plans to prohibit the harvest of any specific species, as that would 

require a case-by-case review with sufficient data that is beyond the preview of this present effort. 

RECOMMENDED PROPOSAL:

1) This discussion document suggests an annotation to §205.601 (j)(1) requiring (proposed changes are 

underlined and in red): 

§205.601 Synthetic substances allowed for use in organic crop production

In accordance with restrictions specified in this section, the following synthetic substances may be used 

in organic crop production: Provided that, use of such substances does not contribute to contamination 

of crops, soil, or water...

(j) As plant or soil amendments.

(1) Aquatic plant extracts (other than hydrolyzed) –Extraction process is limited to the use of 

potassium hydroxide or sodium hydroxide; solvent amount use is limited to that amount 

necessary for extraction. Must be made with certified organic aquatic plants, including, but not 

restricted to, algae. 

21 Maine Department of Marine Resouces. 2014, supra note 6.

NOSB Oct 2018 proposals and discussion documents pg. 36 of 204
2) An additional listing is proposed at §205.602 prohibiting seaweeds unless organically produced to 

address seaweeds used in non-synthetic products and therefore not covered by the annotation under 

Aquatic Plant Extracts. This prohibition, unless certified organic, would help safeguard that seaweeds 

harvested for and used in organic crop production do not harm the environment (proposed changes are 

underlined and in red):

§205.602 Nonsynthetic substances prohibited for use in organic crop production.

The following nonsynthetic substances may not be used in organic crop production:

(e) Marine algae (seaweeds)--unless organically produced. 

3) Recommendation that the NOP develop Guidance on applying §205.207 “Wild-crop 

harvesting practice standard” to the production and harvesting of marine algae. Guidance is needed to 

clarify how marine algae can “be harvested in a manner that ensures that such harvesting or gathering 

will not be destructive to the environment and will sustain the growth and production of the wild crop”. 

In particular, “will not be destructive to the environment” involves a wide range of impacts on the 

marine ecosystem, while “will sustain the growth and production of the wild crop” refers to the ability 

to sustain production of biomass of the crop.

CONCLUSION:

As one public commenter succinctly stated: “A central tenet of organic food production is the 

conservation of biodiversity and natural resources. As such, it is imperative that materials allowed for 

use in organic food and farming be sourced and/or manufactured in a manner that does not contribute 

to ecological damage via resource depletion, species endangerment or extinction, pollution, or 

significant habitat alteration.” 

Each marine material grows in a complex and not fully understood ecological context subject to internal 

and external stressors and never in homeostasis. In order to fully review a material against the required 

OFPA criteria, each marine material must be assessed in the context of where it is growing with an 

understanding of verifiable assurances against environmental harm. The harvest of marine materials for 

organic production must be based on the maintenance of the biodiversity of natural aquatic ecosystems

and the continuing health of the surrounding aquatic and terrestrial ecosystems in a period of rapid 

commercial expansion of both wild and cultivated seaweeds and limited international regulation. 

DISCUSSION QUESTIONS: 

We are seeking comments from the public on the following questions:

1. Please discuss the feasibility of requiring all seaweed harvested for use in organic crop 

production to be certified to the wild crop standards.

2. For certifiers currently certifying marine materials to the wild crop standard, please describe 

how you verify that biodiversity is conserved and how wildlife are maintained in the harvest 

areas.

3. Could species be comprehensively listed on aquatic plant extract product ingredients?

4. Would the establishment of a working group be useful in providing additional guidance on wild 

cropped and farmed marine algae and to clarify the definition and measurement of “not 

destructive to the environment” stipulated in the wild-crop harvesting practice standard

§205.207 (b)? 

NOSB Oct 2018 proposals and discussion documents pg. 37 of 204
5. Is there a potential to replace marine materials with freshwater materials for crop production 

inputs? Many of these freshwater materials are invasive species and are already removed as 

part of restoration efforts.

Vote in Subcommittee 

Motion to accept the marine materials in organic crop production discussion document 

Motion by: Emily Oakley 

Seconded by: Lisa de Lima

Yes: 5 No: 0 Abstain: 0 Absent: 2 Recuse: 0 

Approved by Harriet Behar, Subcommittee Chair, to transmit to NOSB, June 12, 2018

NOSB Oct 2018 proposals and discussion documents pg. 38 of 204