United States Department of Agriculture 1400 Independence Avenue SW. Notice 11-6

Agricultural Marketing Service Room 2646-South Building

National Organic Program Washington, DC 20250

Notice 11-6 Petitions for Inert Ingredients Rev01 03 20 24 Authorized Distribution: Public

Page 1 of 2 

To:

From:

Subject:

Date:

National Organic Program 

Notice to National List Petitioners

National List Petitioners

Melissa R. Bailey, Ph.D., Director, Standards Division

Petitions for Inert Ingredients under the National Organic Program

February 3, 2011 

Links and contact information updated March 20, 2024. 

The National Organic Program (NOP) regulations, 7 CFR Part 205, allow use of synthetic inert 

ingredients in pesticide formulations which appear on the Environmental Protection Agency 

(EPA) List 4 – Inerts of Minimal Concern, and, for passive pheromone dispensers, EPA List 3 – 

Inerts of Unknown Toxicity. The use of inert ingredients that do not appear on EPA List 3 or 4 

must be individually petitioned to the National Organic Standards Board (NOSB) using the 

National List petition guidelines. Petitioned substances must be recommended by the NOSB and 

added to the National List through notice and comment rulemaking before use in organic 

agriculture. Additional guidance on the review of inert ingredients is available in the NOP 

Program Handbook on the NOP website: 

https://www.ams.usda.gov/rules-regulations/organic/handbook. 

The National Organic Standards Board (NOSB) is a 15-member advisory board, authorized 

under the Organic Foods Production Act (7 U.S.C. 6518), that assists in the development of 

standards for substances to be used in organic production and handling. At the NOSB meeting in 

Woodland, California on April 26-29, 2010, the NOSB requested that the NOP enter into a 

Memorandum of Understanding (MOU) with the Environmental Protection Agency (EPA). The 

MOU is intended to serve as a platform for developing an implementation strategy to review 

inert ingredients previously classified by the EPA as List 3 and List 4. 

At the NOSB meeting in Madison, Wisconsin on October 25-28, 2010, the NOSB suggested a 

moratorium on review of inert materials in the petition process. This guidance was offered with 

the understanding that, since 2003, no individual petitions for inert ingredients have been 

recommended for listing by the NOSB. At this meeting, the NOSB acknowledged that the 

current petition process may not be appropriately suited to review individual inert ingredients.

The NOSB meeting transcripts are available on the NOP website:

https://www.ams.usda.gov/rules-regulations/organic/nosb. 
United States Department of Agriculture 1400 Independence Avenue SW. Notice 11-6

Agricultural Marketing Service Room 2646-South Building

National Organic Program Washington, DC 20250

Notice 11-6 Petitions for Inert Ingredients Rev01 03 20 24 Authorized Distribution: Public

Page 2 of 2 

Petitions to add inert ingredients to the National List may continue to be submitted to the NOP to 

be reviewed by the NOSB; however, the NOSB Crops Committee has expressed their preference 

to defer review of individual inert ingredients pending the outcome of the EPA/NOP MOU. 

Please note that, since 2003, no individual petitions for inert ingredients have been recommended 

for listing on the National List of Allowed and Prohibited Substances by the NOSB. 

Those who have petitions for inert ingredients currently under review by the NOSB have the 

option to withdraw their petitions or to continue in the review process under the current review 

criteria. Petitions for inert ingredients that are withdrawn may be resubmitted, without bias, 

pending the outcome of the NOP/EPA process. 

If you have any questions regarding this notice, please contact NOP.guidance@usda.gov.