FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB)

TO THE NATIONAL ORGANIC PROGRAM (NOP)

Date: _ 11/05/ 2009 

Subject: _Hydrogen Chloride Sunset

Chair: Jeff Moyer

Recommendation

The NOSB hereby recommends to the NOP the following:

Rulemaking Action: __X __

Guidance Statement: ________

Other: ________

Summary Statement of the Recommendation (including Recount of Vote):

The Board recommends the continued listing of Hydrogen chloride as annotated in §205.601(n):

(n) Seed preparations. Hydrogen chloride (CAS# 7647-01-0) – for delinting cotton seed for planting.

NOSB Vote: Motion: Rigo Delgado Second: Hue Karriman

Board vote: Yes - 12 No- 0 Abstain- 0 Absent - 3 Recuse-0 

Summary Rationale Supporting Recommendation (including consistency with OFPA and NOP):

Hydrogen chloride was added to the list §205.601(n), based on the NOSB recommendation of April, 

2004. This product is needed to eliminate lint form cotton seed making it possible to mechanize planting 

of this important crop. At the time of the NOSB recommendation, chemical alternatives, such as lactic 

acid or acetic acid were considered ineffective. Mechanical processes, on the other hand, were not only 

inadequate, but resulted in considerable damage to the seed.

After contacting several academic experts from Texas and New Mexico, and communicating with 

manufacturers of cotton seed delinting equipment, the Crops Committee concluded that Hydrogen 

chloride remains the only option for organic cotton farmers and should be relisted.

In preparation for its 2009 Spring meeting, the NOSB received numerous comments from the public 

supporting the relisting of Hydrogen chloride and highlighting the importance of this product in the 

organic cotton industry. The Crops Committee found several patents for delinting equipment which had 

been submitted as recently as 2008 and appear to show promise; it is the hope of this Board that 

appropriate mechanical solutions are developed in the near future.

Response by the NOP:

Attach Committee Recommendation here along that includes committee votes and any attachments
National Organic Standards Board

Crops Committee Recommendation for Hydrogen Chloride

Sunset Review 

August 31, 2009

I. List: 

§205.601 Synthetic substances allowed for use in organic crop production.

(n) Seed preparations. Hydrogen chloride (CAS # 7647-01-0) – for delinting cotton seed for 

planting.

II. Committee Summary: 

Hydrogen chloride was added to the list, §205.601 (n), based on the NOSB recommendation of April, 

2004. This product is needed to eliminate lint from cotton seed making it possible to mechanize 

planting of this important crop. At the time of the NOSB recommendation, chemical alternatives, such 

as lactic acid or acetic acid were considered ineffective. Mechanical processes, on the other hand, 

were not only inadequate, but resulted in considerable damage to the seed. 

After contacting several academic experts from Texas and New Mexico, and communicating with 

manufacturers of cotton seed delinting equipment, the Crops Committee concluded that Hydrogen 

chloride remains the only option for organic cotton farmers and should be relisted. 

In preparation for its 2009 Spring meeting, the NOSB received numerous comments from the public 

supporting the relisting of Hydrogen chloride and highlighting the importance of this product in the 

organic cotton industry. The Crops Committee found several patents for delinting equipment which 

had been submitted as recently as 2008 and appear to show promise; it is the hope of this Committee 

that appropriate mechanical solutions are developed in the near future.

III. Committee Recommendations

The Crops Committee recommends the continued listing of Hydrogen chloride as annotated in

§205.601(n). 

Moved: J. Moyer Second: K. Ellor

Committee Vote: Yes- 6 No- 0 Absent- 0 Abstain- 0 Recuse- 0
Respectfully submitted,

Tina Ellor Chair Crops Committee September 11, 2009