United States Department of Agriculture 1400 Independence Avenue SW. NOP 5033-2

Agricultural Marketing Service Room 2646-South Building Effective Date: December 2, 2016 

National Organic Program Washington, DC 20250 Page 1 of 4

File Name: NOP 5033-2 Guidance Classification Decision Tree Ag/NonAg 12/02/2016 Authorized Distribution: PUBLIC

Guidance 

Decision Tree for Classification of Agricultural and Nonagricultural Materials

for Organic Livestock Production or Handling

* In the absence of standards for organic aquatic animal production, products derived from aquatic 

animals (e.g., fish and crab meal) may be considered non-agricultural when used as livestock feed 

additives.
United States Department of Agriculture 1400 Independence Avenue SW. NOP 5033-2

Agricultural Marketing Service Room 2646-South Building Effective Date: December 2, 2016 

National Organic Program Washington, DC 20250 Page 2 of 4

File Name: NOP 5033-2 Guidance Classification Decision Tree Ag/NonAg 12/02/2016 Authorized Distribution: PUBLIC

Definitions (bolded terms in 7 CFR 205.2)

Agricultural inputs. All substances or materials used in the production or handling of organic 

agricultural products.

Agricultural product. Any agricultural commodity or product, whether raw or processed, including 

any commodity or product derived from livestock, that is marketed in the United States for human or 

livestock consumption.

Allowed synthetic. A substance that is included on the National List of synthetic substances allowed 

for use in organic production or handling.

Chemical change. A process (i.e. chemical reaction) whereby a substance is transformed into one or 

more other distinct substances.

Enzyme. A protein that catalyzes a chemical reaction.

Extract. To separate, withdraw, or obtain one or more constituents of an organism, substance, or 

mixture by use of solvents (dissolution), acid-base extraction, or mechanical or physical methods.

Formulate. To combine different materials according to a recipe or formula.

Generic. The common and familiar non-proprietary name.

Manufacture. To make a substance from raw materials.

Natural source. Naturally occurring mineral or biological matter.

Naturally occurring biological process. A process that occurs due to the action of biological 

organisms or subcomponents of biological organisms, such as enzymes. Examples of naturally 

occurring biological processes include, but are not limited to, fermentation, composting, manure 

production, anaerobic digestion, and enzymatic hydrolysis.

Nonagricultural substance. A substance that is not a product of agriculture, such as a mineral or a 

bacterial culture, that is used as an ingredient in an agricultural product. For the purposes of this part, 

a nonagricultural ingredient also includes any substance, such as gums, citric acid, or pectin, that is 

extracted from, isolated from, or a fraction of an agricultural product so that the identity of the 

agricultural product is unrecognizable in the extract, isolate, or fraction.

Nonsynthetic (natural). A substance that is derived from mineral, plant, or animal matter and does 

not undergo a synthetic process as defined in section 6502(21) of the Act (7 U.S.C. 6502(21)). For 

the purposes of this part, nonsynthetic is used as a synonym for natural as the term is used in the Act.

Processing. Cooking, baking, curing, heating, drying, mixing, grinding, churning, separating, 

extracting, slaughtering, cutting, fermenting, distilling, eviscerating, preserving, dehydrating, 
United States Department of Agriculture 1400 Independence Avenue SW. NOP 5033-2

Agricultural Marketing Service Room 2646-South Building Effective Date: December 2, 2016 

National Organic Program Washington, DC 20250 Page 3 of 4

File Name: NOP 5033-2 Guidance Classification Decision Tree Ag/NonAg 12/02/2016 Authorized Distribution: PUBLIC

freezing, chilling, or otherwise manufacturing and includes the packaging, canning, jarring, or 

otherwise enclosing food in a container.

Processing aid. (1) Substance that is added to a food during the processing of such food but is 

removed in some manner from the food before it is packaged in its finished form;

(2) a substance that is added to a food during processing, is converted into constituents normally 

present in the food, and does not significantly increase the amount of the constituents naturally found 

in the food; and

(3) a substance that is added to a food for its technical or functional effect in the processing but is 

present in the finished food at insignificant levels and does not have any technical or functional 

effect in that food.

Substance. A generic type of material, such as an element, molecular species, or chemical 

compound, that possesses a distinct identity (e.g. having a separate Chemical Abstracts Service 

(CAS) number, Codex International Numbering System (INS) number, or FDA or other agency 

standard of identity).

Synthetic. A substance that is formulated or manufactured by a chemical process or by a process 

that chemically changes a substance extracted from naturally occurring plant, animal, or mineral 

sources, except that such term shall not apply to substances created by naturally occurring biological 

processes.

Table 1. Classification examples of materials used for organic handling or processing.

Substance Classification Explanation

Bentonite Nonagricultural Substance is a mineral (not from a plant or animal 

source)

Colors derived from 

agricultural products

Agricultural Substances are derived from plants or animals and 

that have not been chemically changed

Diatomaceous earth Nonagricultural Substance is derived from a mineral.

Enzymes Nonagricultural Substance is an enzyme (i.e., isolated protein)

derived from plant or animal material.

Lecithin – deoiled Agricultural Substance is derived from plant material and not 

chemically changed.

Kelp Agricultural Substance is a plant that may be dried, but is not 

further processed.

Nitrogen Nonagricultural Substance is a mineral.

Yeast Nonagricultural Substance is a microorganism. If yeast can meet the 

USDA/NOP organic production, handling, 

processing and labeling standards, it may be eligible 

to be certified under the NOP regulations.

Wine Agricultural Substance is the product of a microorganism and 

produced from agricultural media.
United States Department of Agriculture 1400 Independence Avenue SW. NOP 5033-2

Agricultural Marketing Service Room 2646-South Building Effective Date: December 2, 2016 

National Organic Program Washington, DC 20250 Page 4 of 4

File Name: NOP 5033-2 Guidance Classification Decision Tree Ag/NonAg 12/02/2016 Authorized Distribution: PUBLIC

Table 2. Classification examples of materials used for organic livestock feed.

Substance Classification Explanation

Probiotics 

(microorganisms)

Nonagricultural Substance is a microorganism.

Molasses Agricultural Substance is derived from a plant and is not 

chemically changed during processing. Must be 

certified organic when used for livestock feed.

Yeast Nonagricultural Substance is a microorganism. If yeast can meet the 

USDA/NOP organic production, handling, 

processing and labeling standards, it may be eligible 

to be certified under the USDA organic regulations.