Formal Recommendation 

From: National Organic Standards Board (NOSB) 

To: the National Organic Program (NOP)

Date: 

Subject: 

Chair: 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: 

Guidance Statement: 

Other: 

Statement of Recommendation: (Motion # 1) 

 

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

 

Committee Vote:

 

Moved: 

SecondĞĚ: 

Yes:EŽ͗ďƐƚĂŝŶ͗ďƐĞŶƚ͗ZĞĐƵƐĞ͗ 

 

 

 3DJHUHYLVHGPD

April 11, 2013

Petition to add Sugar Beet Fiber to 205.606

Mac Stone

 Motion to classify Sugar Beet Fiber as agricultural 

Passed

According the technical report, lines 174-176, the petitioned sugar beet fiber is the unreacted and 

insoluble portion of the beet that remains after the sucrose has been extracted by basic hydrolysis. As 

such, it is chemically unchanged and is physically or mechanically processed and may be considered a 

non-synthetic agricultural ingredient. 

John Foster

Colehour Bondera

15 0 0 0 0

04/2013 1 of 10 NOSB Recommendation
Rationale Supporting Recommendation (including consistency with OFPA and NOP):

Statement of Recommendation: (Motion # 2)

Committee Vote:

 

Moved: 

SecondĞĚ: 

Yes:EŽ͗ďƐƚĂŝŶ͗ďƐĞŶƚ͗ZĞĐƵƐĞ͗ 

 

 

 

 

3DJHUHYLVHGPD

Failed

 Motion to list Sugar Beet Fiber as petitioned on 205.606 

 

Sugar Beet Fiber fails criteria categories 1, 2, and 3: Processing may have a negative impact on the 

environment; there is concern about the genetic purity of sugar beets as 90% of the worlds sugar beets 

are genetically modified; and sugar beet fiber is not essential and although the petition and TR state that 

they are not available in large enough quantities to supply the market, there are alternatives. 

Additionally, there were few or no comments from potential users of the substance indicating the need 

for this material, nor adding any substantive support for the listing of the substance. 

John Foster

Jean Richardson

0 15 0 0 0

04/2013 2 of 10 NOSB Recommendation
National Organic Standards Board

Handling Committee

Petitioned Material Proposal

Sugar beet fiber

December 18, 2012

Summary of Proposed Action:

Sugar beet fiber is the remaining vegetable matter following the sucrose extraction hydrolysis 

process for sugar beets. This fibrous sugar beet material is composed of hemicellulose, cellulose, 

and pectin and contains soluble fiber concentrations of 10%-20%. Sugar beet fiber has a large 

surface area and is able to bind a large volume of water within a product to maintain the product’s 

integrity (moisture) and lower the overall water activity which can lead to a longer shelf-life and 

minimize microbial concerns. Sugar beet fiber is often added to a food product to provide an 

increased source of soluble fiber within a food, and it is this function that has been brought forth in the 

petition for addition to §205.606. The addition of sugar beet fiber in this capacity is due to the fact 

that it has been found to facilitate better digestion/health in those that consume an adequate amount.

Sugar beet fiber processing may have a negative environmental impact due to the release of 

wastewater with high biologic oxygen demand (BOD) that can disturb natural ecosystems if not 

released/treated responsibly. Additionally, the technical review states that sugar beet fiber production 

often relies upon genetically engineered beets that are not allowed in organic production since 

genetic engineering is an excluded method. The extraction process to isolate the sugar from the beet 

fiber is reliant upon a non-chemical hydrolysis process. However, further sugar beet fiber processing 

can utilize additional materials to bleach and/or treat the fibers with formaldehyde to produce a 

uniform color and/or prevent microbial activity which can lead to spoilage and mycotoxin production. 

Production practices throughout the world for sugar beet production and processing may vary, in 

some cases, using a variety of organically prohibited materials (pesticides, herbicide, fumigants, 

fertilizers, preservatives, etc.). These practices, while not allowed for organic production, are 

consistent with other common crop practices for non-organic ingredients.

The subcommittee discussed concerns over GMOs and the concern over the genetic purity of 

sugar beets that may be used for sugar production and therefore would be the source material for the 

fiber in question—either currently or in the future. The subcommittee also had concerns and is

seeking comments from the industry regarding the reportedly unique solubility/insolubility ratio and 

phytic acid levels in the substance and the degree to which these offer specific benefits over other or 

organically available alternatives.

Evaluation Criteria 

(Applicability noted for each category; Documentation attached) Criteria Satisfied? (see 

“B” below)

1. Impact on Humans and Environment x Yes ☐ No ☐ N/A 

2. Essential & Availability Criteria x Yes ☐ No ☐ N/A

3. Compatibility & Consistency x Yes ☐ No ☐ N/A 

4. Commercial Supply is Fragile or Potentially Unavailable x Yes ☐ No ☐ N/A 

as Organic (only for § 205.606)

Substance Fails Criteria Category: [ ] Comments: 

Proposed Annotation (if any): 

04/2013 3 of 10 NOSB Recommendation
Basis for annotation: ☐ To meet criteria above ☐ Other regulatory criteria ☐ Citation 

Notes: 

Recommended Committee Action & Vote

Classification Motion: Motion to classify sugar beet fiber as agricultural

Motion by: John Foster Seconded by: Joe Dickson

Yes: 8 No: 0 Absent: 0 Abstain: 0 Recuse: 0

Listing Motion: Motion to list sugar beet fiber as petitioned on § 205.606

Motion by: John Foster Seconded by: Joe Dickson

Yes: 7 No: 0 Absent: 0 Abstain: 1 Recuse: 0

Crops ☐ Agricultural x Allowed1 ☐

Livestock ☐ Non-synthetic ☐ Prohibited2 ☐

Handling x Synthetic ☐ Rejected3 ☐

No restriction ☐ Commercial unavailable as 

organic

x Deferred4 ☐

1

Substance voted to be added as “allowed” on National List to § 205.606 without annotation. 

Approved by Committee Chair to Transmit to NOSB

John Foster, Committee Chair December 18, 2012.

04/2013 4 of 10 NOSB Recommendation
NOSB Evaluation Criteria for Substances Added To the National List

Category 1. Adverse impacts on humans or the environment? Substance: Sugar beet fiber

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Are there adverse effects on 

environment from manufacture, use, 

or disposal?

[§205.600 b.2]

X TR: wastewater can have high BOD 

and lead to water pollution; growing 

conventional beets is cited to use a 

large amount of harmful materials 

(herbicides, methyl bromide, 

pesticides); also TR states 

formaldehyde and sulfur dioxide may 

be used to bleach and preserve the 

fiber from microbes/toxin production

2. Is there environmental contamination 

during manufacture, use, misuse, or 

disposal? [§6518 m.3]

X TR: cites that environmental 

contamination can happen at 

processing plants; however, not all 

plants/production would lead to that 

pollution since it is practice dependent 

for different producers worldwide

3. Is the substance harmful to the 

environment and biodiversity?

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X

4. Does the substance contain List 1, 2 

or 3 inerts? [§6517 c (1)(B)(ii); 

205.601(m)2]

X

5. Is there potential for detrimental 

chemical interaction with other 

materials used?

[§6518 m.1]

X

6. Are there adverse biological and 

chemical interactions in agroecosystem? [§6518 m.5]

X THIS MATERIAL IS FOR 606

7. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518 m.5]

X

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products?

[§6518 m.2]

X

9. Is there undesirable persistence or 

concentration of the material or 

breakdown products in environment? 

[§6518 m.2]

X

10.Is there any harmful effect on human 

health? [§6517 c (1)(A)(i); 6517 

c(2)(A)i; §6518 m.4]

X

11.Is there an adverse effect on human 

health as defined by applicable 

X

04/2013 5 of 10 NOSB Recommendation
Federal regulations? [205.600 b.3]

12.Is the substance GRAS when used 

according to FDA’s good 

manufacturing practices? [§205.600 

b.5]

X

13.Does the substance contain residues 

of heavy metals or other 

contaminants in excess of FDA 

tolerances? [§205.600 b.5]

X

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 

(b) are N/A—not applicable.

04/2013 6 of 10 NOSB Recommendation
NOSB Evaluation Criteria for Substances Added To the National List

Category 2. Is the Substance Essential for Organic Production? Substance: Sugar beet 

fiber

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Is the substance formulated or 

manufactured by a chemical 

process? [6502 (21)]

X TR-some manufacturers may use 

some chemicals in bleaching or 

preventing microbial activity; this 

would be dependent on the producer 

and not all sugar beet fiber would 

have this problem

2. Is the substance formulated or 

manufactured by a process that 

chemically changes a substance 

extracted from naturally occurring 

plant, animal, or mineral, sources? 

[6502 (21)]

X See above

3. Is the substance created by naturally 

occurring biological processes? 

[6502 (21)]

X TR: product is extracted via a physical 

method using on water and heat

4. Is there a natural source of the 

substance? [§205.600 b.1]

X

5. Is there an organic substitute? 

[§205.600 b.1]

X TR, PETITION: there is not the 

quantity of organic to supply the 

industry

6. Is the substance essential for 

handling of organically produced 

agricultural products? [§205.600 b.6]

X TR, PETITION: it is not a requirement 

for food , but it is a product that can 

assist in processing and provide 

additional health benefits to 

consumers

7. Is there a wholly natural substitute 

product?

[§6517 c (1)(A)(ii)]

X

8. Is the substance used in handling, not 

synthetic, but not organically 

produced?

[§6517 c (1)(B)(iii)]

X

9. Is there any alternative substances? 

[§6518 m.6]

X TR, PETITION: other vegetable fibers 

can be used instead (oat, pea, etc.) 

however each has slightly different 

properties

10.Is there another practice that would 

make the substance unnecessary? 

[§6518 m.6]

X Using another vegetable fiber or not 

using a fiber at all.

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 

(b) are N/A—not applicable.

04/2013 7 of 10 NOSB Recommendation
NOSB Evaluation Criteria for Substances Added To the National List

Category 3. Is the substance compatible with organic production practices? Substance: 

Sugar beet fiber

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Is the substance compatible with 

organic handling? [§205.600 b.2]

X X Sugar beet may be grown with GMO 

sugar beets.

2. Is the substance consistent with 

organic farming and handling? [§6517 

c (1)(A)(iii); 6517 c (2)(A)(ii)]

X

3. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518 m.7]

X

4. Is the nutritional quality of the food 

maintained with the substance? 

[§205.600 b.3]

X TR: no mention or data was 

presented showing a decrease in the 

nutritional value due to addition.

5. Is the primary use as a preservative? 

[§205.600 b.4]

X TR: sugar beet fiber can bind water 

and thus act as a preservative

6. Is the primary use to recreate or 

improve flavors, colors, textures, or 

nutritive values lost in processing 

(except when required by law, e.g., 

vitamin D in milk)? [205.600 b.4]

X Can be used to improve texture but 

this is not the primary use.

7. Is the substance used in production, 

and does it contain an active 

synthetic ingredient in the following 

categories:

a. copper and sulfur compounds;

X

b. toxins derived from bacteria; X

c. pheromones, soaps, horticultural 

oils, fish emulsions, treated seed, 

vitamins and minerals?

X

d. livestock parasiticides and 

medicines?

X

e. production aids including netting, 

tree wraps and seals, insect traps, 

sticky barriers, row covers, and 

equipment cleaners?

X

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 

(b) are N/A—not applicable.

04/2013 8 of 10 NOSB Recommendation
NOSB Evaluation Criteria for Substances Added To the National List

Category 4. Is the commercial supply of an agricultural substance as organic, fragile or 

potentially unavailable? [§6610, 6518, 6519, 205.2, 205.105 (d), 205.600 (c) 205.2, 205.105 (d), 

205.600 (c)] Substance: Sugar beet fiber

Question Yes No N/A1 Documentation (TAP; petition; 

regulatory agency; other)

1. Is the comparative description 

provided as to why the non-organic 

form of the material /substance is 

necessary for use in organic 

handling? 

X Petition: there is not a currently 

certified source available in large 

quantity. TR states some suppliers 

internationally.

2. Does the current and historical 

industry information, research, or 

evidence provided explain how or 

why the material /substance cannot 

be obtained organically in the 

appropriate form to fulfill an essential 

function in a system of organic 

handling? 

X TR: does mention that production of 

the crop is challenged by weed pest 

pressure.

3. Does the current and historical 

industry information, research, or 

evidence provided explain how or 

why the material /substance cannot 

be obtained organically in the 

appropriate quality to fulfill an 

essential function in a system of 

organic handling? 

X

4. Does the current and historical 

industry information, research, or 

evidence provided explain how or 

why the material /substance cannot 

be obtained organically in the 

appropriate quantity to fulfill an 

essential function in a system of 

organic handling?

X Past suppliers stopped producing it 

due to lack of purchasing.

5. Does the industry information 

provided on material / substance 

non-availability as organic, include ( 

but not limited to) the following:

a. Regions of production (including 

factors such as climate and 

number of regions);

X

b. Number of suppliers and amount 

produced;

X TR: may be suppliers in the world, but 

none in the US

c. Current and historical supplies 

related to weather events such as 

X

NOSB Recommendation
hurricanes, floods, and droughts 

that may temporarily halt 

production or destroy crops or 

supplies; 

d. Trade-related issues such as 

evidence of hoarding, war, trade 

barriers, or civil unrest that may 

temporarily restrict supplies; or

X

e. Are there other issues which may 

present a challenge to a 

consistent supply?

X GMO contamination of organic 

crops/products?

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 

(b) are N /A—not applicable.

NOSB Recommendation