United States Department of Agriculture 1400 Independence Avenue SW. Policy Memo 13-3

Agricultural Marketing Service Room 2648-South Building Page 1 of 2

National Organic Program Washington, DC 20250

PM 13-3 Synthetic Algicides, Disinfectants, and Sanitizers Allowed in Organic Authorized Distribution: Public 

Crop Production Rev03 03 20 24

Policy Memorandum

To: Stakeholders and Interested Parties 

From: Miles V. McEvoy, Deputy Administrator

Subject: Synthetic Algicides, Disinfectants, and Sanitizers Allowed in Organic Crop 

Production

Date: Approved on June 6, 2014

Links and References Updated March 20, 2024

This memorandum clarifies the allowance of synthetic algicides, disinfectants, and sanitizers in 

organic crop production.

Issue:

The National Organic Program (NOP) received a request to clarify whether a material allowed 

under 7 CFR 205.601(a) may be used as an ingredient to control algae within a product 

formulation if the formulated product is not labeled (registered) as an algicide for crop

production under the authority of the U.S. Environmental Protection Agency (EPA). 

Policy:

Synthetic materials that are allowed as algicides, disinfectants, and sanitizers in organic crop 

production are included on the National List of Allowed and Prohibited Substances (National 

List) at 7 CFR 205.601(a). Substances listed at § 205.601(a) may be used by organic crop 

operations only in accordance with the allowances on the National List.

In addition, pesticide products, including algicides, disinfectants, and sanitizers, used in the 

United States must be registered (licensed) by EPA.

1 Under EPA authority, pesticide use must be 

consistent with use directions contained on the label or labeling.2

This means that in order to comply with both the EPA and USDA organic regulations, pesticide 

products containing any substance listed at § 205.601(a) as an active ingredient must be 

registered with the EPA and labeled as an algicide, disinfectant, or sanitizer.

1 Minimum risk pesticides are exempt from EPA registration under FIFRA 25(b) criteria. Pesticide devices, such as ozone 

generators, are also exempt from registration. For more information, see https://www.epa.gov/minimum-risk-pesticides and 

https://www.epa.gov/pesticides. 2 EPA FIFRA Web site: https://www.epa.gov/laws-regulations/summary-federal-insecticide-fungicide-and-rodenticide-act.
United States Department of Agriculture 1400 Independence Avenue SW. Policy Memo 13-3

Agricultural Marketing Service Room 2648-South Building Page 2 of 2

National Organic Program Washington, DC 20250

PM 13-3 Synthetic Algicides, Disinfectants, and Sanitizers Allowed in Organic Authorized Distribution: Public 

Crop Production Rev03 03 20 24

The use of an algicide, disinfectant, or sanitizer for a technical or functional effect within a

product formulation, when the final product is not labeled as an algicide, disinfectant or sanitizer, 

is not consistent with the allowance of materials listed at § 205.601(a) of the National List.

This policy memo does not affect the use of inert ingredients that are otherwise permitted in 

pesticide products at § 205.601(m) of the National List.

In compliance with NOP 3012: Interim Instruction – Material Review, this memorandum serves 

as clarification to all certifying agents and material evaluation programs about the status of 

algicides, sanitizers, and disinfectants allowed in organic crop production. Prior use of a branded 

(formulated) input product that was previously approved by an accredited certifying agent is not 

affected by this memorandum.

Each year, USDA accredited certifying agents (certifiers) must review and approve the use of all 

crop input products for all applicants for certification and certified operations. During the next 

review and approval cycle, certifiers must ensure that all crop input products used by organic 

crop producers comply with this memorandum.

References:

USDA Organic Regulations (7 CFR PART 205)

7 CFR 205.601 Synthetic substances allowed for use in organic crop production.

NOP Program Handbook: Guidance and Instructions for Accredited Certifying Agents 

and Certified Operations

NOP 3012: Interim Instruction – Material Review, August 30, 2016