Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

 

Date: October 28, 2010 

Subject: Sunset Review of Sulfur Dioxide as listed on §205.605(b), 

Nonagricultural (nonorganic) substances allowed as ingredients 

in or on processed products labeled as “organic” or “made with 

organic (specified ingredients or food group(s)).” 

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): 

 

Sulfur dioxide is listed on 205.605(b) with the annotation “for use only in wine 

labeled ‘made with organic grapes,’ provided that total sulfite concentration 

does not exceed 100 ppm.” This substance was scheduled to sunset off the 

National List in 2012, was reviewed by the NOSB, and a motion was made for 

the re-listing of this substance at the October 2010 meeting. 

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

 

The Handling Committee’s recommendation covering this material is attached. 

There were no public written or verbal comments opposing the committee’s 

recommendation, and the material was recommended for relisting by the full 

NOSB as shown below. 

 

NOSB Vote: 

Moved: Joe Dickson Second: Steve DeMuri 

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

 
National Organic Standards Board 

Handling Committee 

Sunset Recommendation – 2012 

Sulfur Dioxide 

September 7, 2010 

List: 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in 

or on processed products labeled as “organic” or “made with organic (specified 

ingredients or food group(s)).” 

(b) Synthetics allowed 

Sulfur dioxide—for use only in wine labeled “made with organic grapes,” 

Provided that total sulfite concentration does not exceed 100 ppm. 

Committee Summary 

Sulfur dioxide is an preservative used for preventing the oxidization of wine. It has been 

used for centuries as part of the traditional winemaking process. Sulfur dioxide is 

produced naturally by the burning of elemental sulfur. The original technical review, and 

the NOSB which reviewed the original petition found that the traditional use of sulfur 

dioxide in wine would be permissible only in wines labeled “made with organic grapes,” 

and not in wines labeled “organic.” 

Review of the original recommendation, historical documents, and public comments 

does not reveal unacceptable risks to the environment, human, or animal health as a 

result of the use or manufacture of this material. There is no new information 

contradicting the original recommendation which was the basis for the previous NOSB 

decision to list this material. 

The committee is aware that that a petition has been submitted to alter the annotation 

for sulfur dioxide. This petition is currently in the NOP process and will not be voted on 

at the October 2010 NOSB meeting. We intend to review the petition in due course. 

Committee Recommendation(s)

The handling committee recommends the renewal of the following substances in this 

use category as published in the final rule: 

Sulfur dioxide—for use only in wine labeled “made with organic grapes,” Provided 

that total sulfite concentration does not exceed 100 ppm. 

Committee Vote 

Motion: Joe Dickson Second: Steve DeMuri 

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