FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: _____6-3-06___________________

Subject: Sunset Review - 205.601 Synthetic substances allowed for use in organic crop 

production 

Chair: Kevin O’Rell 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: _XXXXXX_ 

Guidance Statement: ________ 

Other: ________ 

Statement of the Recommendation (including Recount of Vote):

See attached Recommendation for Renewal of Aquatic Plant Extracts as Synthetic substances 

allowed for use in organic crop production on 205.601, category use (j) as plant or soil 

amendments. 

NOSB Vote: 

Moved: Gerald Davis Second: Nancy Ostiguy 

Yes – 12 

No – 0 

Abstain – 0 

Absent – 2 

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

NOSB Sunset Material Vote 

Response by the NOP:
NOSB- Crops Committee 

Aquatic Plant Extracts - Sunset Recommendation 

Final NOSB Recommendation 4/20/2006

I. List: 205.601 Synthetic substances allowed for use in organic crop production 

II. Category Use 

(j): As plant or soil amendments. 

III. Committee Summary: In the decision making process on whether to continue the 

inclusion of aquatic plant extracts (alkali extraction) on the List, several questions have 

been raised that require a response. These include: What are the manufacturing processes? 

What do the extractants and stabilizers do to the product? Are there non-synthetic aquatic 

plant products available? 

Seaweed (kelp) extracts can be produced from live, fresh plants using potassium hydroxide 

or sodium hydroxide (alkali’s). Potassium hydroxide is the more preferred material due to 

concerns about the possible negative effects of sodium on the intended crops. The raw plant 

parts are ‘digested’ in the presence of the alkali to break open the cell walls of the plants. 

Some manufacturers use pressure in this part of the process, some do not. It is claimed that 

the high pressure environment allows the extraction of the cell contents of the kelp with 

less alkali, without the reduced yield of vital plant compounds that occurs by raising the 

temperature of the process. After extraction, the insoluble fraction of the mixture is filtered 

out and the liquid is either stabilized with an acid (such as phosphoric) or is dried to form a 

soluble powder (without acid stabilization). Liquid formulations would be overtaken with 

bacterial growth if the pH were not lowered to around 3.5. Natural acids such as citric are 

not able to accomplish this in the high pH (10) alkali type extracts. 

The alkali extraction process does produce some chemical reactions in the raw material, 

although the complexity of the chemical mixtures found naturally in the plant material 

would make it almost impossible to quantify all the chemical changes. Clearly, the 

extraction and stabilization of liquid kelp extracts (alkali process) does change the amount 

of potassium and phosphorus in the finished product vs. the raw plant. One manufacturer 

(Acadian) commented that their process does not use any more of the alkali than necessary 

to produce the proper consistency of extract and no more phosphoric acid than necessary 

to lower the pH of the extract to an exact point. They contend that, at the recommended use 

rates for their material, considerably less than 1% of a typical crop’s nutritional needs 

would be supplied. To go much beyond their use rates in order to obtain a fertilizer benefit 

from the material would be cost prohibitive to the grower and possibly detrimental to the 

crop due to the natural amount of sodium found in kelp/seaweed. Their comments are in 

response to concerns that fortification with synthetic nutrients might be occurring rather 

than simply extraction and stabilization of the product. 

Some non-alkali extracted aquatic plant products have become available in recent years. 

These usually involve mechanical/physical disruption or pulverization of the seaweed. The 

liquid extracts are separated from the solids and stabilized with natural acids (citric, acetic). 

As described by the manufacturers, these materials would be considered non-synthetic. The 

component of plant growth substances in these products is said to be somewhat different than 
the alkali extracted products. Some might be less available for beneficial activity to crop 

foliage due to less than complete extraction as compared to the alkali extracts. Some may 

be more available for beneficial crop activity due to the lack of chemical change in some 

of the less (alkali) stabile plant compounds inherent to the seaweed. One apparent 

difference in the activity between the alkali and natural extracts can be learned from 

reading the application instructions of each type. The natural extracts discourage 

applications at or after bloom on many crops due to the tendency of these products 

to promote more vegetative growth at the expense of bloom. The alkali extracts, on the 

other hand, are well known for their beneficial effects on bloom. 

The aquatic plant extracts used in organic crop production are completely unique in some 

of their beneficial attributes for crops. There are no substitute products that provide the 

same benefits to growers. They are somewhat unique even when comparing the 

benefits of alkali extracts and the non-alkali extracts. 

IV. Committee Recommendation: 

Recommendations based upon comments received- 205.601(j) 

The Crops Committee recommends the renewal of the following: 

 (1) Aquatic plant extracts (other than hydrolyzed)- Extraction process is limited to 

the use of potassium hydroxide or sodium hydroxide; solvent used is limited to that 

amount necessary for extraction. 

Moved: Jeff Moyer Second: Kevin Engelbert 

Committee vote: 3-0 2 absent (Delgado, Ostiguy) 

NOSB vote: 

Moved: Gerald Davis Second: Nancy Ostiguy 

Yes – 12 

No – 0 

Abstain – 0 

Absent – 2