This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy.

 Revised June 20 2013

National Organic Standards Board

Livestock Subcommittee

Petitioned Material Proposal

Lignin Sulfonate in aquatic plant production

+

January 21, 2014

Summary of Proposed Action:

Synthetic lignin sulfonate is proposed to be added to the National List at 205.609 for use only as 

a chelating agent for micronutrients used in aquatic plant production. Section 205.609 of the 

National List will contain the list of synthetic substances allowed in organic aquatic plant 

production. 

Synthetic lignin sulfonate is presently approved for use in organic (soil based) crop production 

as a plant or soil amendment (chelating agent), and as a dust suppressant 205.601(j)(4), and as 

a floating agent in post-harvest handling (205.601(l)(1)). 

Chelating agents are water soluble compounds that have the ability to bind with metal nutrients. 

The soluble nature of the chelate molecule facilitates root and cell uptake of metal nutrients. 

Because most micronutrients are metals (e.g., iron, cobalt, zinc, etc.), many fertilizers with 

micronutrients contain some form of chelating agent.

Micronutrients are essential nutrients to maintain growth, maturation and disease resistance. 

Micronutrients must be chelated to become available for aquatic plants. Mineral deficiencies 

result from inadequate intake and lead to poor plant growth.

Lignin sulfonate is a by-product of the wood pulping industry. It is a derivative of lignin, where 

lignin has been sulfonated in the wood pulping process. There are a number of methods for 

pulping wood, such as sulfite chemical pulping, the acidic sulfite process, and the Kraft pulping 

process. Typically the process consists of cooking softwood chips under pressure in sulfur 

dioxide–containing liquors. Sulfonated lignin is the liquid by-product in the spent liquor when the 

pulping process is complete.

Although “Lignin Sulfonate” is the petitioned material it actually complexes into several salts, 

each with a separate CAS number, namely: sodium lignosulfonate; magnesium lignosulfonate; 

ammonium lignosulfonate; and calcium lignosulfonate. The Organic Materials Review Institute 

(OMRI) places restriction on use of ammonium lignosulfonate, but otherwise lignin sulfonate can 

be used with any allowed micronutrient. Petitioner requests addition to National List of sodium 

lignosulfonate with CAS numbers 8061-51-6 and 9009-75-0, and lignin sulfonic acid, CAS 8062-

15-5 which forms a “sulfonate” when chelated to a metal.

Lignin sulfonate salts are soluble in water. Due to their high biological demand (BOD) during 

breakdown in water, lignosulfonates will remove dissolved oxygen from waterways, and 

decreased pH may result from lignin sulfonate decomposition in water. Lower pH levels can 

increase the level of some metals, such as mercury, in aquatic systems leading to higher 

exposures in fish. However, when lignin sulfonates are used as chelating agents to bind 

micronutrients for production of algae the amounts used are extremely small, with chelated 

micronutrients maintained at levels of microgram moles per litre, parts per billion. Further, such 

use occurs in completely closed systems such as glass flasks, containers, on-shore tanks and 

ponds, and not in open water. For these reasons, the environmental impact of using lignin 

sulfonate in these kinds of systems is expected to be minimal or negligible
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy.

 Revised June 20 2013

In reviewing whether use of synthetic lignin sulfonate is compatible with organic agriculture the 

subcommittee took into consideration the Organic Foods Production Act (OFPA) which limits 

use of synthetics to various categories one of which is “copper and sulfur compounds” and lignin 

sulfonate is listed by inference as part of that group. 

In determining if the petitioned substance is essential to organic agriculture the subcommittee 

reviewed availability of any natural, non synthetic alternative material given that OFPA states 

that “To be sold or labeled as an organically produced agricultural product under this title, an 

agricultural product shall (1) Have been produced and handled without the use of synthetic 

chemicals except as otherwise provided in this title;.........” (6504 (1)). Nonsynthetic chelating 

agents include citric acid. However citric acid is also a nutrient source for algae and when used 

as a trace mineral chelator it can cause high levels of trace minerals to accumulate in the plant 

tissue. Nonsynthetic amino acids, humates, fulvates and organic root exudates can be used in 

soil environments, but presently it is not known if these soil substances would work in aquatic 

conditions. Therefore there are presently no known alternatives to synthetic lignin sulfonate as a 

chelating agent which would permit adequate nutrient uptake by micro and macro algae in 

aquatic containers.

It should be noted that at the time of drafting this proposal there are no federal standards 

promulgated for aquatic plant or animal production and this proposal is based on NOSB 

Recommendations of standards voted in 2007, 2008 and 2009.

Evaluation Criteria (see attached checklist for criteria in each category)

Criteria Satisfied? 

1. Impact on Humans and Environment x☐ Yes No ☐ N/A 

2. Essential & Availability Criteria x☐ Yes No ☐ N/A

 3. Compatibility & Consistency x☐ Yes No ☐ N/A

Substance Fails Criteria Category: Comments: N/A

Subcommittee Action & Vote

Classification Motion: Move to classify Lignin Sulfonate CAS numbers: 8062-15-5 (lignin 

sulfonic acid), 8061-51-6 (sodium lignosulfonate/ lignin sulfonic acid sodium salt) and 9009-

75-0 (sodium lignosulfonate), as synthetic.

Motion by: C. Reuben Walker 

Seconded by: Mac Stone

Yes: 6 No: 1 Absent: 0 Abstain: 0 Recuse: 0

Listing Motion: Motion to list Lignin Sulfonate (CAS #s: 8062-15-5 (lignin sulfonic acid), 

8061-51-6 (sodium sulfonate/lignin sulfonic acid sodium salt), and 9009-75-0 (sodium 

lignosulfonate), as chelating agents at §205.609 of the National List 

Motion by: C. Reuben Walker 

Seconded by: Mac Stone

Yes: 6 No: 1 Absent: 0 Abstain: 0 Recuse: 0

 

Proposed Annotation (if any): none
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy.

 Revised June 20 2013

Basis for annotation: ☐ To meet criteria above ☐ Other regulatory criteria ☐ Citation 

Approved by Tracy Favre, Subcommittee Chair, to transmit to NOSB January 21, 2014

NOSB Evaluation Criteria for Substances Added To the National List: Crops

Category 1. Adverse impacts on humans or the environment? Lignin Sulfonate for aquatic 

plants

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is there a probability of environmental 

contamination during use or misuse,? 

[§6518(m)(3)]

x Lignin sulfonates are soluble in water with 

potential for decrease in BOD and pH 

(TR 332-226), but with chelated 

micronutrients maintained at levels of 

microgram moles per litre, parts per 

billion, (Petition p. 3) and used in 

completely closed tanks, or containers for 

algae production, environmental damage 

through use or misuse is unlikely.

2. Is there a probability of environmental 

contamination during manufacture or 

disposal? [§6518(m)(3)]

x Lignin sulfonates are bi-products of the

Paper Industry. There are several 

processes used for production of lignin 

sulfonates: sulfite chemical pulping, the 

Kraft process, acid sulfite pulping (TR 

239-258). While there may be adverse 

impacts from high levels of lignin 

sulfonates, normal use indicates no 

evidence of toxicity. (TR 300-330). 

Concerns about presence of dioxins and 

furans in lignin sulfonates produced by 

the Kraft process have largely been put to 

rest, with tests indicating non-detect 

levels (TR 339-348). Large spills of paper 

mill effluent could negatively impact 

nearby waterways and environmentally 

sensitive area (TR 366-368). Production 

of chelated micronutrients may require 

that dump water containing 

lignosulfonates be processed in a 

treatment system. 

3. Are there any adverse impacts on 

biodiversity? (§205.200)

X See 1 and 2 above
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy.

 Revised June 20 2013

4. Does the substance contain inerts 

classified by EPA as ‘inerts of 

toxicological concern’? [§6517 

(c)(1)(B)(ii)]

x Lignin sulfonate is listed by inference as 

part of the group “copper and sulfur 

compounds” in the OFPA Section 6517 

c)1) B) i) and

Lignin sulfonate is a synthetic inert 

ingredient that is not classified by EPA as 

an inert of biological concern. 

And it is exempt from requirement of 

tolerance under 40 CFR parts 180.910 

and 180.930 (TR 227-232)

5. Is there potential for detrimental chemical 

interaction with other materials used in 

organic farming systems?

[§6518(m)(1)]

x

6. Is there a toxic or other adverse action of 

the material or its breakdown products?

[§6518(m)(2)]

x As noted in 1 and 2 above. Lignin 

sulfonates are water soluble so it is 

possible for dissolved lignosulfonates to 

enter waterways through direct 

contamination or run off from land 

surfaces, and lignosulfonates may be 

toxic to fish (TR 332-337) However, in the 

ppb amounts and enclosed 

containers/tanks to be used no concerns 

are raised in the TR

7. Is there persistence or concentration of 

the material or breakdown products in 

the environment? [§6518(m)(2)]

x As noted in 1 and 2 and 5 above.

Little information is available on 

bioaccumulation of lignosulfonates (TR 

276-278 )

Lignosulfonates break down in soil in 

about a year

8. Would the use of the substance be 

harmful to human health or the 

environment? [§6517 (c)(1)(A)(i); §6517 

(c)(2)(A)(i); §6518(m)(4)]

x There is no research indicating any 

negative human health impacts (TR 491-

496)

Environmental impacts are noted in 1, 2, 

& 8
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy.

 Revised June 20 2013

9. Are there adverse biological and 

chemical interactions in the agroecosystem, including biodiversity? 

[§6518(m)(5)]

x Lignosulfonates discharged into water 

bodies may cause foaming and 

discoloration (TR 274-276) and may 

contaminate waterways following rain 

events (TR 370-373). Due to their high 

biological oxygen demand (BOD) during 

breakdown in water, lignosulfonates 

increase acidity, lower oxygen and can 

lead to benthic changes, and decreased 

biodiversity unless properly monitored 

and regulated with the goal of increasing 

biodiversity in open systems and can 

corrode aluminum in absence of calcium. 

(TR 452-454). However, chelated 

micronutrients for micro and macro-algal 

production will be used in completely 

closed containers and there should be no 

ecosystem or biodiversity impact

.

10. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518(m)(5)]

x See 6 and 8 above. 

Lignosulfonates used as chelating agents 

in aquatic plant production are used in 

entirely enclosed containers and should 

not run off onto soils.

Category 2. Is the Substance Essential for Organic Production: Lignin Sulfonate for aquatic 

plants

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is the substance agricultural? [§6502(1)] x See 3 below

2. Is the substance formulated or 

manufactured by a chemical process? 

[§6502(21)]

x TR 239-258, and Petition p. 5

3. Is the substance formulated or 

manufactured by a process that 

chemically changes a substance 

extracted from naturally occurring plant, 

animal, or mineral sources? 

[§6502(21)]

x Lignin sulfonate is a by-product of paper 

pulping and thus has already been 

chemically altered prior to use as a 

chelating agent in production of 

micronutrients for algae production

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

x See 3 above

5. Is there a natural source of the 

substance? [§ 205.600(b)(1)]

x Lignin occurs naturally in wood, but lignin 

sulfonate does not have a natural source.

6. Is there an organic substitute? 

[§205.600(b)(1)]

x
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy.

 Revised June 20 2013

7. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

x Nonsynthetic amino acids and 

nonsynthetic citric acid are allowed for 

use as chelating agents (TR 544-547)

However, Citric acid is non-functional in 

aquatic environments and could lead to 

micronutrient toxicity due to uptake of 

excess citric acid and attached metals.

Naturally occurring chelates include 

humates, fulvates and organic root 

exudates in soils (TR 585-590), but are 

not available and cannot be used in 

aquatic substrate.

8. Are there any alternative substances? 

[§6518(m)(6)]

x See 7 above

9. Are there other practices that would 

make the substance unnecessary? 

[§6518(m)(6)]

x None provided in Petition or TR for 

aquatic production. Further, it should be 

noted that micronutrients are essential for 

aquatic plant growth, and can only be 

taken up by plants if chelated.

Category 3. Is the substance compatible with organic production practices? Lignin Sulfonate

for aquatic plants

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is the substance consistent with organic 

farming and handling? 

[§6517(c)(1)(A)(iii); 6517(c)(2)(A)(ii)]

x Lignin sulfonate is presently on the 

National List as chelating agent in plant 

or soil amendments. At present there are 

no federal standards for aquatic plant 

production

2. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518(m)(7)]

x As in 1 above and 6 below

3. If used in livestock feed or pet food, is

the nutritional quality of the food 

maintained with the substance? 

[§205.600(b)(3)]

x

4. If used in livestock feed or pet food, is

the primary use as a preservative? 

[§205.600(b)(4)]

x

5. If used in livestock feed or pet food, is

the primary use to recreate or improve 

flavors, colors, textures, or nutritive value 

lost in processing (except when required 

by law)? [§205.600(b)(4)]

x
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy.

 Revised June 20 2013

6. Is the substance used in production, and 

does it contain an active synthetic 

ingredient in the following categories: 

[§6517(c)(1)(B)(i);

copper and sulfur compounds

x Lignin sulfonate is listed by inference as 

part of the group “copper and sulfur 

compounds” in the OFPA section 

6517(c)(1)(B)(i) 

toxins derived from bacteria x

pheromones, soaps, horticultural oils, 

fish emulsions, treated seed, vitamins 

and minerals

x

livestock parasiticides and medicines x

production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleansers

x