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Agricultural Marketing Service Room 2646-South Building Page 1 of 3

National Organic Program Washington, DC 20250

NOP 5030-1 Response to Comments on Livestock Feed Rev02 09 05 18 Authorized Distribution: Public

Response to Comments

Evaluating Allowed Ingredients and Sources of Vitamins and Minerals

For Organic Livestock Feed

Links Update: September 5, 2018

This document summarizes comments received on the “Evaluating Allowed Ingredients and 

Sources of Vitamins and Minerals for Organic Livestock Feed, Feed Supplements, and Feed 

Additives (NOP 5030),” which was posted on the NOP website for public comment. The public 

was notified in a Federal Register notice (77 FR 5415) on Feb. 3, 2012.

• CHANGES MADE IN RESPONSE TO COMMENTS

1) The Use of Incidental Ingredients and Processing Aids. The U.S. Food and Drug 

Administration (FDA) does not require that incidental ingredients or processing aids be listed 

on ingredient labels, making it difficult for a farmer or certifying agent to determine if such a 

substance has been used. The draft guidance at section 4.2(d) used language from the FDA 

regulations to identify those uses for which a substance did not need to be either organic or 

from the National List of Allowed and Prohibited Substances (National List). The National 

Organic Program (NOP) agrees with the commenters that use of this language is confusing 

and conflicting with requirements for organic agricultural carriers, and has removed this 

language.

2) Use of Agricultural Carriers in Feed Additives. Commenters were concerned that 

requirements for organic carriers in feed additives would be unfairly applied at the retail level 

for products purchased by farmers, while organic feed mills might not be required to meet the 

same standard. Several certifiers and a trade organization noted that the proposed policy 

would have allowed organic feed mills to use vitamin and mineral premixes with non-organic 

agricultural carriers, since the non-organic carriers would be considered “incidental” when 

blended to form a final formulated feed. However, livestock farmers who purchase vitamin 

and mineral premixes and mix with feed on-farm would have been required to use premixes 

containing organic carriers since they would appear on the retail label in that case.

The NOP agrees that the same rules should apply to all formulators, either on a farm or in a 

feed mill. The NOP expects that purchasers and organic certifiers should review carriers and 

diluents or other additives when included on the label in mixtures of vitamins and minerals 

used to formulate feed. However, if a farmer or feed mill purchases a generic single 

ingredient allowed as a vitamin or mineral on the National List at 205.603(d) and meeting a 

definition provided by the Association of American Feed Control Officials (AAFCO) or 

FDA, there is no need to review other minor ingredients within the formulation. For example, 

an individual vitamin E supplement is purchased by a feed manufacturer, and then is directly 

mixed with other vitamins and minerals in batches of organic feed. In this case, no further 

review of minor formulation ingredients within the Vitamin E supplement is necessary. In 

another case, a vitamin and mineral premix containing Vitamins A supplement, riboflavin, 
United States Department of Agriculture 1400 Independence Avenue S.W. NOP 5030-1

Agricultural Marketing Service Room 2646-South Building Page 2 of 3

National Organic Program Washington, DC 20250

NOP 5030-1 Response to Comments on Livestock Feed Rev02 09 05 18 Authorized Distribution: Public

calcium chloride, iron sulfate, magnesium phosphate, and wheat middlings is purchased, and 

then blended with organic feed. In this case, the premix product will be labeled with a list of 

ingredients identifying all ingredients according to AAFCO definitions, including the 

agricultural carrier (wheat middlings), which must be organic.

Commenters also questioned whether the handlers who mix vitamin and mineral premixes 

containing organic carriers have to be certified organic. While certification of feed additive 

premixes is permitted for products that have organic agricultural content and meet the feed 

composition requirements of § 205.301(e) and § 205.306, the NOP does not require 

certification of all feed additives that may have a small content of agricultural substances. 

Handlers who create feed additives do not need to be certified organic, but they must use 

organic agricultural products for multi-ingredient products, and the products must be verified 

by certifiers in the review of the Organic System Plan.

3) Prohibition on the Use of Excluded Methods in the Production of Yeast, Probiotics and 

Enzymes. Commenters noted that the guidance specifically prohibited excluded methods for 

the production of vitamins and minerals, yet did not note whether this prohibition applied to 

the production of yeast, probiotics and enzymes. The NOP added language to clarify that 

excluded methods are prohibited in the production of yeast, probiotics and enzymes.

 

4) Clarification of 100% organic livestock feeds. A commenter noted that for the 100% 

organic label claim to be used, no non-organic products could be used. The NOP agreed and 

made this change.

• CHANGES REQUESTED BUT NOT MADE

1) Use of the Food and Drug Administration (FDA) or the Association of American Feed 

Control Officials (AAFCO) References for Approved Vitamins and Minerals. Several 

certifying agencies and a feed manufacturer requested that the NOP allow any vitamin or 

mineral that is approved by the FDA or appears in the current edition of the AAFCO 

Official Publication (Mineral Products or Vitamins), including those sourced from slaughter 

by-products and excluded methods. The certifiers stated that the handlers of vitamins and 

minerals are often several steps removed from the manufacturer of the individual nutrients, 

and that information is not readily available regarding the manufacturing of specific 

vitamins and minerals. The commenters stated that most vitamins and minerals are highly 

refined synthetic substances, and should not be considered agricultural products subject to 

the restrictions on slaughter by-products used in feed at § 205.237(b)(5).

The NOP recognizes that many manufacturers of vitamins and minerals are not the direct 

seller to organic farms and feed mills, which can make source verification difficult. The 

NOP also acknowledges a lack of technical review or specific recommendation from the 

National Organic Standards Board (NOSB) to clarify this issue regarding sources of 

livestock mineral and vitamins, and agrees that FDA and AAFCO listed vitamins and 

minerals meet the specifications of the National List at § 205.603(d)(2) and § 205.603(d)(3).
United States Department of Agriculture 1400 Independence Avenue S.W. NOP 5030-1

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NOP 5030-1 Response to Comments on Livestock Feed Rev02 09 05 18 Authorized Distribution: Public

However, § 205.237(b)(5) applies to crude slaughter by-products in livestock feed such as 

bone meal, bone charcoal, bone phosphate, proteinated mineral sources and other crude 

extracts as these substances contain animal by-products in a recognizable form. The USDA 

organic regulations also prohibit use of excluded methods at § 205.105(e), and thus vitamins 

used in livestock feed should be reviewed for excluded methods. The NOP may seek 

technical reviews in the future to address the commenter’s concerns and provide more 

information as it becomes available.