This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy. 

Revised June 20 2013

National Organic Standards Board

Livestock Subcommittee

Petitioned Material Proposal

Vitamins in aquatic animal production

June 17 2013

Reviewed January 21, 2014 - Minor formatting revisions only

Summary of Proposed Action:

Synthetic vitamins are proposed to be added to the National List at 205.611 for use in 

production of aquatic animals. Synthetic vitamins are presently approved at 205.603(d) (3) for 

use in organic, soil based, livestock production as “Vitamins for enrichment or fortification when 

FDA approved.” Vitamins are listed in the OFPA at 6517 (c) (1) (B)(i).

Vitamins are essential for production of animals, and although feed consisting of fish meal, or 

ingredients such as soy, corn, or vegetable oils could be used to supply vitamins. Currently, 

synthetic vitamin forms provide a more readily available and consistent source of vitamins to 

ensure good health for organic livestock. In the case of nutrient requirements for fish and 

shrimp, the National Research Council (NRC) defines essential vitamin compounds as 

“required”, and it is this group of 15 synthetic vitamins which are proposed for addition to the 

National List: Vitamin A; B1 (Thiamine); B2 (Riboflavin); B3 (Niacin); B5 (Pantothenic Acid); B6 

(Pyridoxine); B7 (Biotin); B8 Choline; B9 (Folic Acid); B12 (Cobalamin); Inositol; Vitamin C; 

Vitamin D3; Vitamin E Tocopherols; and Vitamin K.

Manufacture of vitamins can be by chemical processes, fermentation or extraction depending on 

the specific vitamin. Fermentation can be synthetic or non-synthetic. Typically chemical 

processes are used to achieve consistent and balanced feed pre-mixes. While large spills 

during manufacture may result in algal blooms, the typical feeding of vitamins for fish production 

is not considered to pose environmental harm. Vitamins should not be considered persistent in 

marine environments. Adverse effects due to persistence are more likely to be seen in closed 

systems.

In considering alternative sources for the 15 vitamins petitioned, Vitamin E can be extracted 

from vegetable oils and a diet comprised of forage and fish oils is the most natural means of 

providing vitamins to carnivorous and omnivorous fish. However, the aquaculture industry is 

working to mitigate use of and possible depletion of wild fish if it continues to be used in large 

amounts as a feed source in aquaculture. Extraction from natural sources is widely considered 

inefficient and low yielding.

In reviewing whether vitamins are compatible with organic agriculture the subcommittee took 

into consideration the Organic Food Production Act (OFPA) which limits the use of synthetics to 

various categories, one of which is “pheromones, soaps, horticultural oils, fish emulsions, 

treated seed, vitamins, and minerals.

It should be noted that at the time of drafting this proposal there are no federal standards 

promulgated for aquatic plant or animal production and this proposal is based on NOSB 

Recommendations of Standards voted in 2007, 2008, and 2009.

Evaluation Criteria (see attached checklist for criteria in each category)

Criteria Satisfied? 

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 
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy. 

Revised June 20 2013

Substance Fails Criteria Category: [ ] Comments: N/A

Subcommittee Action & Vote, 

Classification Motion: Motion to classify vitamins, as petitioned, as synthetic: Vitamin A, 

CAS #127-47-9; B1 (Thiamine), CAS # 59-43-8; B2 (Riboflavin), CAS # 83-88-5; B3 

(Niacin), CAS # 59 67-6; B5 (Pantothenic Acid), CAS #137-08-6; B6 (Pyridoxine), CAS # 

58-56-0; B7 (Biotin), CAS # 58-85-5; B8 (Inositol), CAS # 87-89-8; B9 (Folic Acid), CAS # 

59-30-3; B12, (Cobalamin), CAS # 68-19-9; Choline, CAS # 67-48-1; Vitamin C, CAS # 50-

81-7; Vitamin D, CAS # 67-97-0; Vitamin E, Tocopherols CAS # 59-02-9; and Vitamin K, 

CAS # 130-37-0.

Motion by: C. Reuben Walker 

Seconded by: Jean Richardson

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

Listing Motion: Motion to list vitamins as listed above at §205.611 of the National List 

Motion by: C. Reuben Walker 

Seconded by: Jean Richardson

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

 Proposed Annotation: None

Minority Opinion: see end of document

Approved by Tracy Favre, Subcommittee Chair, to transmit to NOSB January 21, 2014

NOSB Evaluation Criteria for Substances Added To the National List: Livestock

Category 1. Adverse impacts on humans or the environment? Vitamins (aquatic animals) 

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is there a probability of environmental 

contamination during use or misuse? 

[§6518(m)(3)]

X Vitamin pre-mixes are incorporated into 

feed at a rate of approximately 0.5%-

1.5% (Petition page 3) and releases are 

assumed to pose no risk (TR 982-983).

Large amounts of vitamins released into 

open waters may result in promotion of 

algal blooms and red-tides (TR 986-987) 

and perhaps eutrophication (TR 1075-

1079).

It is unlikely that vitamins use or misuse 

will result in environmental impairment 

due to their short half lives in aquatic 

systems. (TR 972-973 and 807-829).

Overall, accidental release of small 

amounts of vitamins into the environment 
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy. 

Revised June 20 2013

is not assumed to pose any significant 

risk (TR 982-983).

2. Is there a probability of environmental 

contamination during, manufacture or 

disposal? [§6518(m)(3)]

X See 1 above.

Industrial production of synthetic vitamins 

includes use of reagents and 

fermentation waste which can have 

negative environmental impacts, but no 

specific examples of such contamination 

are cited in TR (TR 945-987).

3. Are there any adverse impacts on 

biodiversity? (§205.200)

X See 1 above.

4. Does the substance contain inerts 

classified by EPA as ‘inerts of 

toxicological concern’? [§6517 

(c)(1)(B)(ii)]

X No (TR 541-548).

5. Is there potential for detrimental chemical 

interaction with other materials used in 

organic farming systems?

[§6518(m)(1)]

X Overall vitamins should not be 

considered persistent in marine 

environments as these compounds 

readily decompose in oxic (oxygen rich) 

environments (TR 827-829).

No direct interactions of vitamins and 

other aquatic animal feed additives have 

been identified (TR 991).

6. Is there a toxic or other adverse action of 

the material or its breakdown products?

[§6518(m)(2)]

X See 5 above and 7 below.

7. Is there persistence or concentration of 

the material or breakdown products in 

the environment? [§6518(m)(2)]

X See 5 above.

The potential for toxicity is generally 

dependent on the vitamin’s solubility 

properties. Water soluble vitamins 

(thiamine, riboflavin, pyridoxine, 

pantothenic acid, niacin, biotin, folic acid, 

choline, inositol, and ascorbic acid) are 

rapidly depleted and these vitamins do 

not bioaccumulate in animal fatty tissue. 

Lipid-soluble vitamins A, D, E, and K 

bioaccumulate in fatty tissue (TR 847-

876). Literature on bioaccumulation or 

persistence of vitamins in aquatic 

environments is limited. In general lipid 

soluble vitamins are more likely to 

bioaccumulate in fatty tissues (TR 830-

836). 

Adverse effects due to persistence will be 

more severe in closed systems (TR 805-

806).
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy. 

Revised June 20 2013

8. Would the use of the substance be 

harmful to human health or the 

environment? [§6517 (c)(1)(A)(i); §6517 

(c)(2)(A)(i); §6518(m)(4)]

X See 1, 5, and 7 above.

Limited information is available regarding 

potential for environmental or human 

health toxicity at the small levels used 

(TR 1045-1050).

9. Are there adverse biological and 

chemical interactions in the agroecosystem? [§6518(m)(5)]

X It is unlikely that vitamins used in aquatic 

animal feed would enter a terrestrial agroecosystem (TR 1027-1028).

No studies have been found indicating 

toxic effects of vitamins in soil dwelling 

organisms (TR 1030-1033).

Vitamin D3 is used in a rodenticide 

(TR1071-1072). Overloading aquatic 

ecosystems with nutrients could 

potentially reduce BOD but this would 

negatively impact fish production and 

thus with good management can be 

avoided (TR1075-1079).

10. Are there detrimental physiological 

effects on soil organisms, crops, or 

livestock? [§6518(m)(5)]

X See 1, 7, and 9 above.

No studies have been found indicating 

toxic effects of vitamins on soil-dwelling 

organisms (TR 1033).

Category 2. Is the Substance Essential for Organic Production? Vitamins (aquatic animals) 

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is the substance agricultural? [§6502(1)] X

2. Is the substance formulated or 

manufactured by a chemical process? 

[§6502(21)]

X X There are 15 Vitamins petitioned and the 

production methods vary. Some can be 

produced by fermentation or extraction 

from natural sources, but are typically 

commercially produced by chemical 

processes (TR 553-554).

Fermentation can be considered 

synthetic or non-synthetic (TR 785-786).

3. 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 X See 1 above.

Of the 15 synthetic vitamins petitioned 

Vitamins A, D, E, and K are lipid (TR 852-

853). 

Vitamin E, tocopherols is typically 

extracted from natural materials, i.e. 

vegetable oils (TR 779).
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy. 

Revised June 20 2013

Extraction from natural sources in widely 

considered inefficient and low yielding 

(TR 574-773).

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

X See 1 above.

5. Is there a natural source of the 

substance? [§ 205.600(b)(1)]

X X See 1 and 3 above and 9 below.

6. Is there an organic substitute? 

[§205.600(b)(1)]

X X Vegetable oil for Vitamin E, but not for the 

others petitioned.

7. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

X X For some of the vitamins vegetable oils or 

fish oils can be used.

8. Are there any alternative substances? 

[§6518(m)(6)]

X X See 1 and 8 above and 9 below.

9. Are there other practices that would 

make the substance unnecessary? 

[§6518(m)(6)]

X When possible a diet comprised of forage 

fish is the most natural means of 

incorporating proteins and vitamins into 

diets of carnivorous and omnivorous fish 

(TR 1247-1249) but the fish industry is 

working to mitigate demand for wild fish 

as fish feed (TR 1277-1285).

Category 3. Is the substance compatible with organic production practices? Vitamins (aquatic 

animals)

Question Yes No N/A Comments/Documentation (TAP; 

petition; regulatory agency; other)

1. Is the substance consistent with organic 

farming and handling? 

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

X Vitamins are presently on the National 

List at 205.603(d) (3).

Vitamins are listed in the OFPA at 6517 

(c) (1)(B)(i)

2. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518(m)(7)]

X See 1 above. 

3. If used in livestock feed or pet food, Is 

the nutritional quality of the food 

maintained with the substance? 

[§205.600(b)(3)]

X Vitamins enrich and fortify feed.

4. If used in livestock feed or pet food, Is 

the primary use as a preservative? 

[§205.600(b)(4)]

X

5. If used in livestock feed or pet food, Is 

the primary use to recreate or improve 

flavors, colors, textures, or nutritive value 

lost in processing (except when required 

by law)? [§205.600(b)(4)]

X
This is a proposal by a Subcommittee of the National Organic Standards Board (NOSB). Proposals are posted for public comment and 

then may be voted upon by the full Board. They are not final Board recommendations or NOP policy. 

Revised June 20 2013

6. Is the substance used in production, and 

does it contain an active synthetic 

ingredient in the following categories: 

[§6517(c)(1)(B)(i);

copper and sulfur compounds

X X Thiamine and biotin and vitamin K are 

sulfur containing. The other vitamins 

listed do not contain sulfur (TR 537-539).

toxins derived from bacteria X

pheromones, soaps, horticultural oils, 

fish emulsions, treated seed, vitamins 

and minerals

X

livestock parasiticides and medicines X

production aids including netting, tree 

wraps and seals, insect traps, sticky 

barriers, row covers, and equipment 

cleansers

X