Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

 

Date: October 28, 2010 

Subject: Apiculture Recommendation 

Chair: Daniel G. Giacomini 

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action X 

Guidance Statement 

Other 

 

Statement of the Recommendation (Including Recount of Vote): 

 

In the Fall of 2001 the NOSB issued a recommendation on Apiculture 

Standards. The proposed standards were send back to the NOSB Livestock 

Committee for further work and refining. In the interim, many new pressing 

issues resulted in apiculture languishing on the Livestock Committee’s work 

plan. In late 2008 an apiculture working group formed independently of the 

NOP and the NOSB, with two goals: 1) help the Livestock Committee rework 

the 2001 Apiculture Recommendation, and 2) bring apiculture back to the 

forefront. The NOSB has taken the 2001 NOSB Apiculture Recommendation, 

comment from the public, and the input of the apiculture working group to 

address the National Organic Program’s concerns with the previous apiculture 

recommendation. 

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

 

 The recommendation is a modification of the apiculture recommendation 

passed by the NOSB at the Fall 2001 meeting. 

 

NOSB Vote: 

Moved: Joe Dickson Second: Tina Ellor 

Yes: 14 No: 0 Abstain: 0 Absent: 0 Recusal: 0 
Organic Apiculture 

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National Organic Standards Board 

Livestock Committee 

Organic Apiculture Recommendation 

October 27, 2010 

Introduction

 

Honey, and its associated products are valued in the organic food industry. A key alternative 

to refined sugars and a respected contributor to managing allergies and abrasions, honey 

represents an iconic product, one that consumers assume is one of the purest and simplest 

ways to eat as close to nature’s intent. Since honeybees are animals, the Livestock Committee 

of the National Organic Standards Board takes responsibility for developing a recommendation 

for USDA standards to govern the production of organic honey and honey-related products, 

such as pollen, propolis, royal jelly, beeswax, and bee venom. Because the biology and 

behavior of honeybees is so markedly different from other types of organic livestock, and 

because they fly and forage a wide area, specific standards are required to ensure consistency 

between organic certifiers and to ensure that organic honey meets consumers' expectations for 

organic products. 

Honey is the end result of an intricate process of Nature, performed by honey bees, which also 

serves as a critical input in successful agriculture and food for other species of animals and 

birds. At least 30% of agriculture relies directly on pollination, a job that bees perform with 

pure enjoyment. As the bee retrieves the nectar it needs to eat, it also collects pollen. As it 

travels from flower to flower on a variety of different plants to satisfy its hunger, it carries the 

pollen with it, thereby ‘pollinating’ other plants and crops, a necessary jump-start to crop 

maturity. While not only a functional requirement for some crops, and definitely honey 

production, in the true spirit of organic, the honey bee promotes biodiversity. That these bees 

and their forage be managed organically has a significant impact. At the near bottom of the 

food chain, and responsible through forage for their own contribution to ‘drift,’ it is important to 

create reliable, rigorous standards that ensure the quality and organic integrity of the food 

supply. 

In the past decade, several issues have arisen to pose real threats to the health and survival of 

all honey bees. Tracheal mites, Varroa mites and Colony Collapse Disorder have all been 

identified as reasons for significant declines in healthy bee colonies, in fact colonies that are 

able to survive at all. 

The commercial organic honey industry is well in place, despite the lack of organic standards 

specific to organic apiculture. Refined standards, which provide much needed clarification on 

practices specific to honeybee product production, will ensure the continued success and 

growth of the U.S. organic honey market. While the many certified producers have honored all 

the requirements of the existing regulation, there has been some variation in certifier 

expectations and interpretation. Finally, the EU and Canada have detailed apiculture 

requirements as part of their organic standards. In order to facilitate effective trade with other 

countries, and to effectively compete in the international market, it is important that a U.S. 

organic apiculture standard be implemented. 
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Background 

As the original organic standards were being developed, an NOSB Apiculture Task Force was 

charged with development of organic apiculture standards. In September 2001, they issued a 

report and Draft Organic Apiculture Standards. The draft organic apiculture standard 

established allowed and prohibited production practices for organic apiculture operations 

based on the requirements of the Organic Foods Production Act (OFPA). It was consistent with 

the National Organic Program Final Rule, published December 21, 2000, and cross-references 

applicable sections of the rule. 

The OFPA-based livestock certification requirements include provisions for the origin of 

livestock, the feed ration, living conditions, health care management practices, and the record 

keeping arrangements necessary for identification and audit trail purposes. All livestock 

certification requirements were addressed in the draft organic apiculture standard. 

During the same time period as the release of this recommendation, the first Organic Rule was 

being prepared for implementation as of October 2002. The competition for priorities to 

address left organic apiculture on the list of items requiring attention in the future improvement 

and embellishment of the law. 

In the interim, certifiers have used the existing Livestock Standards as a baseline for certifying 

organic apiculture operations, 205.236 – 205.239, and the related sections of the National List, 

205.603 and 205.604. The fact that apiculture varies considerably from other livestock 

operations has lead to a great deal of variability in the requirements of certification. Growing 

pressure from the apiculture industry, the certifier community and the movement toward 

equivalency agreements spawned a renewed effort to develop apiculture specific organic 

standards. 

At the Fall 2009 NOSB Meeting, the Accredited Certifiers Association Apiculture Working 

Group presented a document which suggested updates to the 2001 NOSB Apiculture 

Recommendation. The Livestock Committee’s current recommendation incorporates many of 

the ACA Apiculture Working Group's recommendations, and also attempts to harmonize 

certain requirements - such as the forage zone, surveillance zone, and transition period - with 

EU and Canadian organic apiculture standards. 

Much has changed in the intervening years. The largest organic apiculture community, in the 

state of Hawaii, had long been free of the Varroa mite, one of the most dangerous bee pests. 

In recent years, the mites reached Hawaii, and its organic honey producers struggle for 

survival. The feral hives are nearly extinct and the commercial hives fight for another season 

without the same tools as their international organic competitors from Canada and the EU, 

whose standards allow the use of formic acid for mite control. 

Amendments to the National List 

The ACA Working Group discussed materials specific to beekeeping, and noted that some 

which are specific to beekeeping will be required to be petitioned for inclusion on the National 
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List. The following are materials the Working Group believes must be reviewed for appropriate 

status and petitioned for addition to the National List if necessary. 

Formic acid 

Thymol 

Carbon Dioxide 

The Group does not believe that oxytetracline or terramycin should be approved for use in 

organic beekeeping. Antibiotics are not permitted for any other type of livestock. Synthetic 

miticides are also not permitted. 

The Group also believes that organic formulations of feed supplements are now available, thus 

non-organic feed supplements do not need to be added to the National List. This includes 

vegetable shortening and confectionary sugar. These products are produced organically at this 

time. 

The Group also discussed materials used in the smokers. The Group agreed that synthetic 

materials in bee smokers are prohibited unless listed on the National List. The Group also 

recommends that tobacco be added to §205.604, Nonsynthetic substances prohibited for use 

in organic livestock production. 

The Group states that there are several materials that are not recognized by the EPA for use in 

bees including Folic acid, Lactic acid and Oxalic acid for mite control. If these materials do 

receive EPA registration, the Group recommends they be petitioned for inclusion on the 

National List. The group recommends that Folic acid and Lactic acid should have the following 

annotations: 

Folic Acid – for use as a pesticide to control varroa mites solely within honeybee hives, 

after last honey harvest; discontinue 30 days prior to addition of bee product harvest 

equipment. 

Lactic acid – after last honey harvest; discontinue 30 days prior to addition of bee product 

harvest equipment. The need must be documented and approved prior to use. 

The National Organic Standards Board will consider substances related to organic honey bee 

production for inclusion on the National List as they are petitioned. 

Recommendation 

The Livestock Committee recommends that the following apiculture standards be added to the 

organic regulations: 
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Organic Apiculture Standard 

§ 205.2 Terms Defined 

Apiary or bee yard. An area of a collection of hives or colonies of bees kept for their bee 

products.

Apiculture. The management and production of honey bees, queens and bee products. 

Bee products. Honey, wax, propolis, royal jelly, beeswax, pollenand bee venom or any other 

product from bees intended for human use or consumption. 

Colony. Queen bee with its attendant worker bees and drone bees used to produce bee 

products. 

Forage zone. Land or bodies of water, within a 1.8 mile (3 km) radius of the edge of the 

apiary/bee yard which provides bees with water, nectar, honeydew, pollen and propolis. 

Harvest Equipment. Equipment used to collect bee products for sale as organic, including 

honey supers, frames from which royal jelly will be harvested, and any other equipment in 

contact with organic bee products. 

Hive. Equipment used in the production of bee products to include hive boxes, bottom 

boards, covers, frames, comb. 

Nucleus colony or nuc. A smaller sized hive box with reduced numbers of bees and brood, 

usually containing a queen; used for expansion of the apiary operation. 

Replacement bees. Bees introduced into an existing organic apiary operation to replenish 

established colonies which have been lost to overwintering, predators or other catastrophic 

loss. 

Surveillance zone. Land area of a 2.2 mile radius (3.4 km) beyond the forage zone which may 

not contain high risk activities. 

§ 205.240 Apiculture practice standard. 

The application of this practice standard is to regulate the production of bee products, not to 

require the use of organic bees for organic crop pollination. 

(a) Origin of bees 

(1) Transition 

Bee products from an apiculture operation that are to be sold, labeled, or represented 

as organic must be from colonies and hives which have been under continuous organic 

management for no less than one year prior to the removal of the bee products from the 

hive. 

At the beginning of the one year transition, foundation wax (if used) must be replaced 

and all brood comb must be new and produced by bees under organic management. 

Foundation may be sourced from: 
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(i) Organic foundation 

(ii) Plastic foundation dipped in organic or conventional wax 

(iii) Organic or conventional wax 

Once an entire apiary has been converted to organic production, all plastic foundation 

must be dipped in organic wax. Queen bees are not required to undergo transition. 

(2) Replacement Bees 

The introduction of bees from organic sources or from non-organic sources (i.e. 

packaged bees), is permitted for replacement purposes Provided, That the bees from 

non-organic sources are limited to 25% of colonies present in the previous honey flow, 

are managed organically for at least 60 days , and harvest equipment is removed from 

the hive during the 60 days. 

(i) 25% count is based on the total number of colonies going into winter 

(3) Expansion of the apiculture operation may be done by 

(i) Purchase of organic hives and bees 

(ii) Splitting of existing organic colony to form nucleus colony 

(iii) Purchase of nonorganic bees, providing that they undergo a one year transition as 

per requirements in §205.240(a)(1). 

(b) A producer of organic apiculture products must develop an organic apiculture plan in 

accordance with the provisions in § 205.201. In addition, the organic apiculture plan must: 

(1) Contain a map of the apiary which shows the location of the hives, the forage zone, 

including the location of organic and wild land, and the surveillance zone, including the 

location of all non-organic areas and human housing; 

(2) Forage Zone: Provide a description of all crops grown, the quantity of organic and/or 

wild forage to be provided per colony, including the type or types of forage, approximate 

bloom period, forage density, competing species density, honeybee colony density, 

colony health, colony strength, topography, and climatic conditions; and any sources of 

potential contamination located within the 1.8 mile (3 km) forage zone. 

(3) Surveillance Zone: Provide a description of crops grown and high risk activities such as 

sanitary landfills, incinerators, sewage treatment facilities, power plants, golf courses, 

human housing, towns or cities, land to which prohibited materials are applied, and all 

other sources of potential contamination located in the surveillance zone of 2.2 miles 

(3.4 km) beyond the forage zone. Crops produced using excluded methods, deemed by 

the accredited certifying agent to be attractive to bees, are not permitted on land within 

the surveillance zone. 

(4) Describe the water sources available in the forage zone; 

(5) For split operations, list and describe the management practices used to prevent 

commingling and contamination, including measures to prevent commingling resulting 

from bee drift and robbing. 
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(c) A producer of organic apiculture products must maintain records in accordance with § 

205.103 and § 205.236(c). Split operations are required to identify hives that have been 

treated with materials not permitted under §205.603 or materials prohibited under 

§205.604. Records must include: 

(1) map of the forage zone, the surveillance zone, and the flowering times of the various 

plants in those zones for all bee yards 

(2) affidavits verifying the 3 year land management history for the certified forage zones 

(3) sources of foundation and whether foundation is organic 

(4) date of last use of prohibited substances 

(5) identification system for hives and bee yards 

(6) verification that all comb has been drawn out under organic management 

(7) the season these “clean” frames had been used for the production of organic honey 

(8) a system of tracking hives, queens introduced or raised, monitoring through the season 

(9) a list of inputs used and labels of inputs 

(10) records of feeding including materials and dates 

(11) source of any organic sugar, organic honey, organic pollen and/or organic pollen 

substitutes fed to colonies; certification documentation for materials fed 

(12) records of all health care interventions and products used 

(13) estimated yields of all bee products per hive 

(14) dates of harvest of bee products 

(15) sales records of bee products 

(16) packaging and labeling for bee products sold 

(d) The producer must maintain colonies on land that is managed in accordance with the 

provisions in § 205.202 through § 205.207. All apiaries and transportation activities must be 

included in the OSP and approved prior to movement. 

(e) The producer must provide bees with water and organic feed by: 

(1) managing the forage zone as certified organic (either as crops or wild harvest) under 

the provisions of 205.202 through 205.207 

(2) recognizing that bees from the operation may occasionally and minimally forage on nonorganic land in the surveillance zone. The Organic System Plan must demonstrate that 

sufficient organic forage is available within the forage zone throughout the year. Given that 

even in well-managed operations with sufficient forage in the forage zone, a small number 

of bees will travel out of the forage zone to forage, the OSP must also demonstrate the 

crops in surveillance zone offer minimal risk to organic integrity. 

(f) The producer of an organic apiculture operation may: 

(1) provide supplemental feed from organic honey, organic sugar syrup, and/or pollen 

substitutes and supplements that are allowed under 205.603, Except, That, the producer 

must not provide organic sugar syrup less than 15 days prior to placement of bee product 

collection equipment. 

(g) The producer of an organic apiculture operation must not: 
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(1) Maintain colonies during the forage season in an area where a significant risk of 

contamination by prohibited materials exists within a 1.8 mile (3 kilometers) radius of the 

apiary, as described in the operation's organic apiculture plan. 

(h) Approved hive construction materials include: 

(1) Hives must be made of non-synthetic materials, including wood and metal, not treated 

with prohibited substances. 

(2) Outside hive surfaces may be painted with non-lead based paints. 

(3) Plastic foundation may be used if dipped in organic beeswax 

(i) The producer must establish and maintain preventive health care practices, including: 

(1) Selection of bee stocks, hive densities, and colony locations appropriate to site-specific 

conditions and resistant to prevalent diseases and pests; 

(2) Maintenance of adequate supplies of honey and pollen in the hive, including leaving 

hives with reserves of honey and pollen sufficient for the colony to survive the dormancy 

period; 

(3) Use of foundation wax not contaminated with diseases or pests; 

(4) Destruction of equipment and bees contaminated with disease or pests; 

(5) Use of management methods or modified equipment to control pests and diseases; 

(6) Use of therapeutic applications of non-synthetic materials to control pests, parasites, 

and diseases, Provided, That such materials are not prohibited under § 205.604; and 

(7) Use of therapeutic applications of synthetic materials, Provided, That such materials are 

allowed under § 205.603. 

(j) The producer must not: 

(1) Accept the presence of pests, parasites, or disease without initiating efforts to restore 

the health of the colony; 

(2) Use synthetic materials not listed as allowed under § 205.603; 

(3) Use non-synthetic materials prohibited under § 205.604; 

(4) Use lumber treated with synthetic materials not listed as allowed under § 205.603 or 

non-synthetic materials prohibited under § 205.604 for hive construction materials; 

(5) Use synthetic materials or non-synthetic materials prohibited under § 205.604 in bee 

smokers; 

(6) Use synthetic bee repellants to remove bees from their honey; 

(7) Annually destroy bee colonies following honey flows; 

(8) Rotate hives between organic and non-organic management; or 

(9) Sell apiculture products as organic if they contain a residue of a prohibited material 

greater than 5 percent of the Environmental Protection Agency’s tolerance for the 

specific material, pursuant to § 205.671. 
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Committee Vote: 

Motion: Kevin Engelbert Second: Jeff Moyer 

Yes: 6 No: 0 Abstain: 0 Absent: 2