NOSB RECOMMENDED DECISION FORM

Form NOPLIST2. Full Board Transmittal to NOP

For NOSB Meeting: 

May 2009

Substance: Myrrh (Commiphora myrrha) essential oil

A. Evaluation Criteria (Applicability noted for each category; Documentation attached) Criteria Satisfied? (see B below) 

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

 

2. Essential & Availability Criteria Yes X No  N/A 

3. Compatibility & Consistency Yes X No  N/A 

4. Commercial Supply is Fragile or Potentially Unavailable as Organic (only for 606) Yes X No  N/A  

B. Substance fails 

criteria? 

MEETS criteria.

Comments: none

C. Proposed Annotation: NONE

___________________________________________________________ 

Basis for annotation: 

To meet criteria above: ____ Criteria: _______________

Other regulatory criteria: ____ Citation:_______________

D. Final Board Action & Vote (State Actual Motion): To add Myrrh (Commiphora myrrha) essential oil to the National List in 

section 205.606

Motion: Steve DeMuri Second: Julie Weisman Yes: 11 No: 2 Abstain: 1 Absent: 1

 

Provide a summary narrative here or attach a more complete narrative, and attach the original committee recommendation

that includes the evaluation criteria checklist:

All criteria for listing this substance were met. The petition made a case that organic forms of myrrh are not commercially available, and 

independent research by the Handling Committee confirmed that assertion. The primary uses for this oil are as ingredients in personal 

care products, but it is conceivable that it could be used in organic food products as well. There are references in the literature to its’ 

occasional use as an ingredient in beverages, and it has FDA approval for food use. The oil is extracted from the plant sap with steam. 

There are no synthetic solvents used in it’s manufacture. 

 

1—substance voted to be added as “allowed” on National List on National List to § 205.606 with Annotation (if any) No annotation 

__________________________________________________________________________________________________ _ 

2—substance to be added to “prohibited” paragraph of National List to § 205.______ Describe why a prohibited substance:

_____________________________________________________ ___________________________________

__ ____

 _

 

___ 

3—substance was rejected by vote for amending National List to § 205. 606. Describe why material was rejected: 

See summary narrative in Section D above and attached Committee Recommendation documentation. 

 

4-substance was recommended to be deferred § 205. ______ Describe why deferred; if any follow-up is needed. If follow-up needed, 

who conducts follow-up ________________________________ ____________________________________ 

Agricultural X Nonagricultural Crops

Synthetic Not synthetic X Livestock

Allowed1

X Prohibited2

Handling X

No restriction Deferred4 Rejected3

E. Approved by NOSB Chair to transmit to NOP

Jeff Moyer 

Chair Date

May 6, 2009 .

F. NOP Action: Include in FR to amend National List: 

 Return to NOSB Reason: ____________________________________________________________________ 

_____________________________________ _________________________ 

 Date 
NOSB COMMITTEE RECOMMENDATION

Form NOPLIST1. Committee Transmittal to NOSB

For NOSB Meeting: __May 2009_ Substance: _Myrrh essential oil (Commiphora myrrha)___

Committee: Crops  Livestock  Handling √ Petition is for:_The inclusion of myrrh essential oil (Commiphora 

myrrha) for use in perfume_ on the National List § 205.606

A. Evaluation Criteria (Applicability noted for each category; Documentation attached) Criteria Satisfied? (see B below) 

4. Impact on Humans and Environment Yes √ No  N/A 

 

5. Essential & Availability Criteria Yes √ No  N/A 

6. Compatibility & Consistency Yes √ No  N/A 

7. Commercial Supply is Fragile or Potentially Unavailable as Organic (only for 606) Yes √ No  N/A  

B. Substance Fails Criteria Category: _________ Comments: ___________________________________________________ 

________________________________________________________________________________________________________

C. Proposed Annotation (if any): _____________________________________________________________________________

________________________________________________________________________________________________________

 Basis for annotation: To meet criteria above: _______ Other regulatory criteria: _______ Citation:______________________

D. Recommended Committee Action & Vote (State Actual Motion): _To include myrrh essential oil (Commiphora myrrha) 

_for use in perfume on the National List §205.606_

Motion by: _G.Davis___ Seconded:__S. DeMuri

 

___ Yes: __4__ No: __0__ Absent: __2___ Abstain: __0__ 

 

1) Substance voted to be added as “allowed” on National List to § 205.606. with Annotation (if any) No annotation

________________________________________________________________________________________________________

2) Substance to be added as “prohibited” on National List to § 205. with Annotation (if any) _________________________

________________________________________________________________________________________________________

Describe why a prohibited substance:__________________________________________________________________________

________________________________________________________________________________________________________ 

 

3) Substance was rejected by vote for amending National List to § 205. _____ Describe why material was rejected:___________ 

________________________________________________________________________________________________________

4) Substance was recommended to be deferred because ___________________________________________________________

_____________________________________________________________________________ If follow-up needed, who will 

follow up ________________________________________________________________________________________________

Crops Agricultural X Allowed1 X

Livestock Non-Synthetic Prohibited2 

Handling X Synthetic Rejected3

No restriction Commercially UnAvailable as Organic1

 X Deferred4

E. Approved by Committee Chair to transmit to NOSB:

Steve DeMuri 

Committee Chair Date

March 16, 2009
NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Substance - _Myrrh essential oil_

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 Petition

2. Is there environmental 

contamination during 

manufacture, use, misuse, or 

disposal? [§6518 m.3]

X Petition

3. Is the substance harmful to the 

environment?

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

X Petition

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 

agro-ecosystem? [§6518 m.5]

X Not intended for crop use

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5]

X Not intended for crop use

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 Undiluted material may be irritant to the eyes

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3]

X FDA approved as a food flavor.(petition)

12. Is the substance GRAS when 

used according to FDA’s good 

manufacturing practices? 

[§205.600 b.5]

X Petition

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.
Category 2. Is the Substance Essential for Organic Production? Substance – Myrrh essential oil__

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 Essential oil produced by steam distillation of oleoresin 

material exuded as sap from the plant Commiphora 

myrrha.

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 Substance is extracted from natural plant source without 

chemical change.

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)]

X

4. Is there a natural source of 

the substance? [§205.600 b.1]

X Substance is natural.

5. Is there an organic 

substitute? [§205.600 b.1]

X Petitioner claims that no organically produced myrrh oil is 

available. HC member internet search produced no 

organic sources. 

6. Is the substance essential for 

handling of organically 

produced agricultural products? 

[§205.600 b.6]

X

 

Petitioner claims substance is a vital component of certain 

perfumes.

7. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)]

X Fragrance is specific to this plant material.

8. Is the substance used in 

handling, not synthetic, but not 

organically produced? 

[§6517 c (1)(B)(iii)]

X See question 10

9. Is there any alternative 

substances? [§6518 m.6]

 X

10. Is there another practice 

that would make the substance 

unnecessary? [§6518 m.6]

X Fair trade marketing efforts to work more directly with 

indigenous harvesters could potentially produce a certified 

organic (wild harvested) product. 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.
Category 3. Is the substance compatible with organic production practices? Substance -

Myrrh essential oil_

Question Yes No N/A1 Documentation

(TAP; petition; regulatory agency; other)

1. Is the substance compatible 

with organic handling? 

[§205.600 b.2]

X As long as the substance used as a component of 

organically certified perfumes is part of the 5% nonorganic portion and resultant perfume product is not 

designated with myrrh in the name. 

2. Is the substance consistent 

with organic farming and 

handling? [§6517 c (1)(A)(iii); 

6517 c (2)(A)(ii)]

X As a wild harvested material and extracted and/or diluted 

with natural solvents only.

3. Is the substance compatible 

with a system of sustainable 

agriculture? [§6518 m.7]

X X Limited information raises concern of potential overharvesting of the native shrubs from which myrrh is 

derived.

4. Is the nutritional quality of the 

food maintained with the 

substance? [§205.600 b.3]

X

5. Is the primary use as a 

preservative? [§205.600 b.4]

X

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

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.
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 - __Myrrh essential oil_________

Question Ye

s

No N/A Comments on Information Provided (sufficient, 

plausible, reasonable, thorough, complete, 

unknown)

1. Is the comparative description

provided

X

as to why the non-organic 

form of the material /substance is 

necessary for use in organic 

handling?

 Plausible

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

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

X

to fulfill an 

essential function in a system of 

organic handling?

Plausible

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 Plausible

b. Number of suppliers and amount 

produced;

X

c. Current and historical supplies 

related to weather events such as 

hurricanes, floods, and droughts 

that may temporarily halt production 

or destroy crops or supplies; 

X

d. Trade-related issues such as 

evidence of hoarding, war, trade 

barriers, or civil unrest that may 

temporarily restrict supplies; or

X Petitioner makes the case for the difficulty of 

establishing a certified organic supply due to the 

inherent civil unrest of the main regions of production 

such as Somalia, Yemen, etc.
e. Are there other issues which may 

present a challenge to a consistent 

supply?

X