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Guidance

Substances Used in Post-Harvest Handling of Organic Products 

Links and References Updated March 20, 2024 

1. Purpose and Scope

This guidance provides information to all USDA-accredited certifying agents (certifiers) and

certified and exempt organic operations about substances that may be used in post-harvest

handling of organic products. More specifically, this guidance clarifies: 1) what substances may 

be used for post-harvest handling; 2) the difference between “post-harvest handling of raw 

agricultural commodities” and “further processing”; and 3) the regulatory requirements for 

facility pest management. This guidance also defines post-harvest substances and post-harvest 

handling (see Section 3). 

See Appendix A for examples of post-harvest substances affected by this guidance, and

Appendix B for questions and answers about using this guidance. 

2. Background

The Organic Foods Production Act of 1990 (OFPA) requires substances used in organic 

production and handling to be itemized on the National List of Allowed and Prohibited 

Substances (National List) by specific use or application (See 7 U.S.C. 6517). The National List, 

a subpart of the USDA organic regulations, is divided into the following sections: 

• 7 CFR 205.601 lists substances for use in crop production;

• 7 CFR 205.603 lists substances for use in livestock production; and

• 7 CFR 205.605 – 205.606 list substances for use in or on processed products.

Post-harvest handling includes actions such as washing, cleaning, sorting, packing, cooling, 

storing of raw agricultural products, and facility pest management. These actions can be 

performed on farms or in handling facilities. The National List does not contain a separate 

section dedicated to substances for use in the post–harvest handling of raw agricultural products 

(post-harvest substances). Nevertheless, post-harvest substances may be found in both sections

205.601 and 205.605. For example, some post-harvest handling substances, such as lignin 

sulfonate and sodium silicate (used as floating agents), are included in § 205.601; and others, 

such as ethylene (for tropical fruit ripening) and chlorine and peracetic acid (used as 

antimicrobials), are included in § 205.605. 

Because substances allowed for use in post-harvest handling appear in different sections of the 

National List, or are nonsynthetic and are therefore not included on the crops section of the 

National List, confusion among organic stakeholders exists around: 1) the point at which crop 
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production for unprocessed commodities ends and processing starts; and 2) the post-harvest 

substances allowed for use. 

Since post-harvest handling of raw agricultural products is an action that can take place either on a 

farm or in a handling facility, this guidance clarifies that nonsynthetic substances allowed for use in 

crop production may be used post-harvest on raw agricultural commodities either on a farm or in a 

handling facility, provided that there is no limitation in § 205.602 of the National List that prevents 

or restricts their use. Similarly, substances allowed for use in handling in § 205.605 of the National 

List, with no specific use restrictions that prevent post-harvest use, may be used in post-harvest 

handling of raw agricultural products either on a farm or in a handling facility. Synthetic substances 

that are included in § 205.601 for use in crop production must be specifically annotated to permit 

post-harvest use in order to be used in the handling of processed products. 

3. Policy and Procedure

3.1 A substance may be used in post-harvest handling if it falls in one of the following 

categories1: 

• Synthetic substances that are listed in § 205.601 of the National List specifically for

post-harvest use may be used for handling raw agricultural commodities, either on

farms or in handling facilities. (E.g., lignin sulfonate or sodium silicate.)

• Substances listed in § 205.605 of the National List may be used for post-harvest

handling of raw agricultural commodities either on farms or in handling facilities,

provided that there is no restriction limiting their use. (E.g., carbon dioxide, nitrogen

gas, and ozone.)

• Natural (nonsynthetic) substances allowed for use in crop production that are not

restricted or prohibited in § 205.602 of the National List may be used for post-harvest

handling of raw agricultural commodities, either on farms or in handling facilities.

3.2 All inert ingredients used in post-harvest pest control substances on raw agricultural 

commodities must be either nonsynthetic and not prohibited in § 205.602 of the National 

List, or allowed by § 205.601(m) of the National List. 

3.3 Facility pest management.

The USDA organic regulations also provide for the use of certain substances in facility 

pest management, under certain circumstances, even though they are not on the National 

List. Section 205.271 describes an order of preference for facility pest management 

practices. Producers or handlers must first apply management practices to prevent or 

control pests as described in § 205.271(a) and (b), including the use of lures and 

repellents containing nonsynthetic or synthetic substances that are consistent with the 

1 The use of any substance must comply with the U.S. Environmental Protection Agency (EPA) or U.S. Food and 

Drug Administration (FDA) requirements, as applicable. 
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National List. If these practices are not adequate, then a nonsynthetic or synthetic 

substance “consistent with the National List” may be applied (See § 205.271(c)). The 

phrase “consistent with the National List” does not specify which section of the National 

List should be referenced in making this determination. For instance, materials such as 

pheromones, sticky traps, boric acid, and Vitamin D3 are listed in § 205.601 of the 

National List for use in crop production, therefore, these substances would be “consistent 

with the National List” for facility pest control purposes. If none of the practices listed in 

§ 205.271 are effective, the handler may use substances that are not on the National List,

provided that there is no contact with organic products or ingredients, the certifier and

handler agree on the use of the substance, and its use complies with § 205.271(d).

Handlers include producers who handle crops or livestock of their own production.

3.3.1 7 CFR 205.271(c) allows producers and handlers to use nonsynthetic or synthetic 

substances “consistent with the National List” in facility pest management. This 

means that nonsynthetic substances and synthetic substances listed in §§ 205.601, 

205.603 or 205.605 of the National List may be used for facility pest management 

in accordance with any restrictions, provided they are not included at §§ 205.602 

or 205.604 of the National List as prohibited nonsynthetic substances. 

3.3.2 Any EPA registered pesticide substance used in a facility pest application must be 

labeled for that use. 

3.3.3 All inert ingredients in facility pest management products permitted under 

§ 205.271(c) must be either nonsynthetic, included in § 205.601(m), included in

§ 205.603(e) of the National List, or included in § 205.605 of the National List.

3.3.4 Producers and handlers must demonstrate compliance with § 205.271 in their 

Organic System Plans. 

3.3.5 Producers and handlers may use substances that are not on the National List for 

facility pest management, provided that there is no contact with organic products 

or ingredients, they are used in accordance with § 205.271(d), and the certifier 

agrees on the use and method of application of the substance. 

4. References

Organic Foods Productions Act of 1990, as amended 

7 U.S.C. 6517 National List 

USDA Organic Regulations (7 CFR Part 205)

7 CFR 205.2 Terms Defined 

Handle. To sell, process, or package agricultural products, including but not limited to trading, 

facilitating sale or trade on behalf of a seller or oneself, importing to the United States, exporting 
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for sale in the United States, combining, aggregating, culling, conditioning, treating, packing, 

containerizing, repackaging, labeling, storing, receiving, or loading. 

Handler. Any person that handles agricultural products, except final retailers of agricultural 

products that do not process agricultural products. 

Handling operation. Any operation that handles agricultural products, except final retailers of 

agricultural products that do not process agricultural products.

Inert ingredient. Any substance (or group of substances with similar chemical structures if 

designated by the Environmental Protection Agency) other than an active ingredient which is 

intentionally included in any pesticide product (40 CFR 152.3(m)). 

Processing. Cooking, baking, curing, heating, drying, mixing, grinding, churning, separating, 

extracting, slaughtering, cutting, fermenting, distilling, eviscerating, preserving, dehydrating, 

freezing, chilling, or otherwise manufacturing and includes the packaging, canning, jarring, or 

otherwise enclosing food in a container. 

7 CFR 205.271 Facility pest management practice standard. 

7 CFR 205.601-605 of the National List of Allowed and Prohibited Substances. 

Other Definitions (adapted from FDA Guidance for Industry: Antimicrobial Food Additives, 

July 1999): 

Facility. A structure or site where production, handling, processing, packaging or storage of 

organic products occurs. A facility could include packing lines, wash lines, storage units, coolers, 

freezing plants, feed mills, milk houses, production structures such as housing for livestock, 

greenhouses and mushroom buildings. 

Post-harvest substances. Substances used in the post-harvest handling of raw agricultural 

commodities which are not further processed, either on farm or in handling facilities. This 

includes substances used for flotation, washing, sanitizing, cooling, storing, and for facility pest 

management. 

Post-harvest handling. Post-harvest handling is the act of handling raw agricultural commodities 

without further processing. Post-harvest handling activities preserve the essential form of the 

product. Examples of these activities include, but are not limited to: flotation, washing, 

sanitizing, cooling, packing, separation from foreign objects or plant parts (e.g., cleaning grain), 

removal of stems leaves or husks, and storage and pest control practices... “Further processing” 

includes actions that change the essential form of the product such as chopping, peeling, cutting, 

waxing, coating, drying, or combining with other ingredients. 

Raw agricultural commodity. Any food in its raw or natural state, including all fruits that are

washed, colored, or otherwise treated in their unpeeled natural form prior to marketing (Federal 
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Food, Drug, and Cosmetic Act, 21 U.S.C. 321(r)). Substances used for coloring or coating must 

be permitted as per § 205.605 or § 205.606 of the National List.

Other Laws and Regulations 

Federal Food, Drug, and Cosmetic Act, 21 U.S.C. 301 et seq. 
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Appendix A

Examples of Post-Harvest Handling Substances Affected by this Guidance

1. Diatomaceous earth is a natural substance used in crop and livestock pest management. It

is also listed for handling use in 7 CFR 205.605(a) for use as a filter aid only. It is

commonly used as a pest control substance in storage bins for grain, and is regulated by

EPA as a pesticide.

• Allowed as a nonsynthetic substance permitted in crop production.

• Allowed for post-harvest handling on raw agricultural products, including storage

bins for grain since there are no restrictions in 7 CFR 205.602.

• Inert ingredients must either be compliant with 7 CFR 205.601(m), nonsynthetic,

or approved synthetics in 7 CFR 205.605.2

• Must be used in accordance with label directions.

2. Pyrethrum, Bacillus thuringiensis, or other botanical or biological pesticides.

• Allowed as nonsynthetic substances for use in crop or livestock production,

provided that the EPA label permits its use.

• Allowed for post-harvest use on raw agricultural products provided that the label

permits its use.

• Inert ingredients must either be compliant with 7 CFR 205.601(m), nonsynthetic,

or approved synthetics in 7 CFR 205.605.

3. Copper sulfate, narrow range oils, elemental sulfur, insecticidal soaps.

• Allowed in 7 CFR 205.601 as synthetic substances permitted for insect or disease

control of crops.

• Not allowed for post-harvest use in direct contact with organic products, since

these synthetic substances are not on the National List for post-harvest use.

• Could be used in compliance with 7 CFR 205.271(c) for handling facility pest

management.

4. Clove oil, for sprout inhibition of potatoes, is considered a pesticide that is exempt from

EPA registration requirements.

• Allowed as a nonsynthetic substance permitted in crop production.

• Allowed for post-harvest handling since there are no restrictions in 7 CFR

205.602.

• Inert ingredients must either be compliant with 7 CFR 205.601(m), nonsynthetic,

or approved synthetics in 7 CFR 205.605.

2 They must also meet all EPA requirements. Minimal Risk Pesticides exempt from EPA registration must use inerts permitted as per 

http://www.epa.gov/inerts/section25b_inerts.pdf.
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• Allowed in direct contact with unprocessed organic potatoes, provided that the

label permits this use.

5. Ethylene gas.

• Allowed as a synthetic substance in 7 CFR 205.605(b) for post-harvest use as a

ripening agent for tropical fruit and for degreening of citrus. EPA regulates this

use as a pesticide; therefore, inert ingredients must be compliant with 7 CFR

205.601(m).

• Not allowed for other post-harvest uses since the listing in 7 CFR 205.605 is

limited to specific uses.

6. Sodium silicate.

• Allowed as a synthetic substance in 7 CFR 205.601 as post-harvest floating agent.

This substances may be used in packing houses on farms, or in separate handling

operations.

7. Ethanol and isopropyl alcohol.

• Allowed for crop production as synthetic substances in 7 CFR 205.601(a) as

algicides, sanitizers and disinfectants for crop production.

• Not allowed in direct contact with food products for post-harvest use, since they

are synthetic and not listed for that use. (Note.—Organic ethanol is permitted for

handling use).

• Could be used in compliance with 7 CFR 205.271(c) for facility pest

management.

8. Boric Acid

• Allowed for crop production as a synthetic substance in 7 CFR 205.601(e)(3) as

insecticides, structural pest control, no direct contact with organic food or crops.

• Not allowed in direct contact with food products for post-harvest use, since they

are synthetic and not listed for that use.

• Could be used in compliance with 7 CFR 205.271(c) for facility pest

management, provided there is no direct contact with organic products, as per the

restriction at 205.601(e)(3).

9. Mouse bait stations that are baited with warfarin (an anticoagulant rodent poison)

• Prohibited for use in crop production, since it is a synthetic substance, not

included in 7 CFR 205.601.

• Not allowed in direct contact with food products for post-harvest use, since they

are synthetic and not listed for that use.

• Could be used in compliance with 7 CFR 205.271(d) for facility pest

management, provided there is no contact with organic products or ingredients,

and the certifier approves the intended use and plan for application. The handler

must demonstrate that preventive management practices, physical controls, and
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use of substances on the National List are not effective, as per 7 CFR 205.271(ac).
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Appendix B

Questions and Answers 

Substances Used in Post-Harvest Handling of Organic Products

1. Can I use this substance for post-harvest handling of raw agricultural commodities?

2. Can I use this substance for facility pest control? 3,4

3 All pesticides must have an EPA registration or exemption from registration for use in facility pest control. 4 Pursuant to 7 CFR 205.271(a)-(b), management practices must be demonstrated before the substance may be used.

 The substance is listed in 7 CFR 205.601 (crops), with an annotation for postharvest use:

 YES

 The substance is listed in 7 CFR 205.605 (handling), without restrictive

annotations that prevent this use:

 YES

 The substance is nonsynthetic, and is not prohibited or restricted in 7 CFR 205.602

or 205.604:

 YES

 The substance is synthetic, and is listed in 7 CFR 205.601 for crop use, without

annotation for post-harvest use:

X NO

 The substance is listed in 7 CFR 205.601, 205.603, or 205.605 without any

restrictions preventing use:

 YES

 The substance is nonsynthetic, and is not listed in 7 CFR 205.602 or 205.604:

 YES

 The substance is synthetic, not on the National List:

• May be used by handlers (including producers who handle crops or livestock of

their own production) when the substance is not in contact with organic products

or ingredients, and with the certifier’s approval, pursuant to 7 CFR 205.271(d).