Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

Date: May 25, 2012

Subject: Cellulose: Listing at § 205.605(a) for Sunset 2013 

Chair: Barry Flamm

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action X

Statement of the Recommendation (Including Recount of Vote): 

The recommendation is to re-list cellulose to 205.605(b) with the following 

modified annotation: 

Cellulose—for use in regenerative casings, powdered cellulose as an anticaking agent (non-chlorine bleached) and filtering aid.

The vote was 14 yes, 1 no, 0 abstentions or recusals. 

The board also passed a backup recommendation to re-list the material with the 

existing annotation, in accordance with the NOSB policy on annotation changes 

during sunset review. 

The vote was 11 yes, 3 no, 1 abstention, 0 recusals

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

Review of the original recommendation, the 2001 TAP review, historical 

documents, the 2007 sunset recommendation, and public comments does not 

reveal unacceptable risks to the environment, human, or animal health as a result 

of the use or manufacture of this material. There is no new information 

contradicting the original recommendation which was the basis for the previous 

NOSB decisions to list and again re-list this material.

Committee Vote Motion 1: To Relist

Moved: Joe Dickson Second: Zea Sonnabend

Yes: 14 No: 1 Abstain: 0 Absent: 0 Recusal: 0
Committee Vote Motion 2: Backup vote

Moved: Joe Dickson Second: Harold Austin

Yes: 11 No: 3 Abstain: 1 Absent: 0 Recusal: 0
National Organic Standards Board

Handling Committee

2013 Sunset Proposal

Cellulose on § 205.605(b)

March 20, 2012

List: 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on 

processed products labeled as “organic” or “made with organic (specified ingredients 

or food group(s)).” 

(b) Synthetics allowed 

Cellulose—for use in regenerative casings, as an anti-caking agent (non-chlorine 

bleached) and filtering aid.

Committee Summary

Cellulose, in its natural form, is the main component of plant cell wells and one of the most 

abundant organic substances on earth. However, most commercially available cellulose is 

produced from wood pulp or other plant sources through a delignification process that results 

in sufficient chemical change to render the substance synthetic. While there are many uses for 

cellulose in food production, the 2002 Technical Advisory Panel (TAP) report focused on the 

petitioned uses for and forms of the substance – as a filtering aid, as a component of 

processed meat casings, and as an anti-caking agent. The current annotation restricts the 

substances use to these specific areas. While the production of non-synthetic (and even 

organic) cellulose is technically possible, no commercial sources of non-synthetic cellulose are 

currently known. 

Review of the original recommendation, the 2001 TAP review, historical documents, the 2007 

sunset recommendation, and public comments does not reveal unacceptable risks to the 

environment, human, or animal health as a result of the use or manufacture of this material. 

There is no new information contradicting the original recommendation which was the basis for 

the previous NOSB decisions to list and again re-list this material. 

Committee Recommendation(s)

The handling committee recommends the renewal of the following substance in this use 

category as published in the final rule:

Cellulose—for use in regenerative casings, as an anti-caking agent (non-chlorine 

bleached) and filtering aid.

Committee Vote

Motion: Harold Austin Second: Zea Sonnabend

Yes: 5 No: 0 Abstain: 0 Recuse: 0 Absent: 1 

HC 1 Sunset 2013 Cellulose