NOSB RECOMMENDED DECISION FORM

Form NOPLIST2. Full Board Transmittal to NOP 

 

For NOSB Meeting: May 2008 Substance: Tragacanth Gum 

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? 

Criteria category: N/A 

 

Comments: 

 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 include Tragacanth Gum, to section 205.606 - Nonorganically 

produced agricultural products allowed as ingredients in or on processed products labeled as “organic”, under section (j) 

Gums - water extracted only. 

Motion: Julie Weisman Second :Joe Smillie Yes: 14 No: 0 Abstain: 0 Absent: 1 

 

The petition for Tragacanth Gum was complete and showed the material met all evaluation criteria for consideration to be 

listed in 205.606 (j) gums - water extracted only - of the NOP regulations. (See attached) The material was recommended for 

listing by a vote of the Handling Committee, and subsequently by a vote of the NOSB at it’s May 2008 meeting. 

 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. ______ Describe why material was rejected: _____ _ 

___________________________________________________ __ 

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 

Allowed1X Prohibited2

Handling X 

No restriction X Deferred4 Rejected3

E. Approved by NOSB Chair to transmit to NOP 

 Rigoberto Delgado. July 9, 2008 .

Chair Date

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

 Return to NOSB Reason: ____________________________________________________________________ 

 

_____________________________________ 

 Date 

 _________________________ 
National Organic Standards Board 

Final Recommendation for 

Date: May 22, 2008 

I. List: 

National Organic Program Subpart G: The National List of Allowed and Prohibited Substances. 

§205.606 Nonorganically produced agricultural products allowed as ingredients in or on 

processed products labeled as “organic” or “made with organic (specified ingredients or food 

groups(s)).” List in section (j) Gums- water extracted only. 

II. Board Summary: Tragacanth gum, water-extracted is an exudite gum and is harvested and 

processed in a manner which is identical to other exudite gums already included on §205.606 

of the National List. The Board considered whether it is necessary to add another gum to the 

National List and was persuaded that although Tragacanth gum is derived by an identical 

process to gum Arabic, it has sufficiently different functionality to justify it’s inclusion on the 

National List. 

The Board also considered the reasons for this material being commercially unavailable in an 

organic form and the prospects for such availability in the future. 

 At present this tree is primarily cultivated in Iran and the current embargo which exists 

 on U.S. trade with this country had disrupted the supply of even the conventional 

 form of this material. Turkey has increased it’s production of conventional Tragacanth 

 gum and also is expanding it’s organic production. The petitioner is working closely 

 with their Turkish supplier and believes that a supply of this material in an organic 

 will be made available in the next several years. 

 The Board feels that this material meets evaluation criteria in all four categories 

 required for listing on section 205.606 of the National List. 

III. Board Recommendation 

Tragacanth Gum for inclusion on §205.606 of the National List in Section (j) Gums - 

water extracted only.

Moved: Julie Weisman Second: Joe Smillie 

Board vote: Yes-14 No- 0 Absent- 1 Abstain-0 Recuse-0
NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: ___May 2008_________________ Substance: ___Tragacanth Gum__________________

Committee: Crops  Livestock  Handling X Petition is for:___ Inclusion of Tragacanth on the National List § 

205.606 (b)____

_______________________________________________________ on the National List § 205.___________________________

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  No  N/A X

3. Compatibility & Consistency Yes  No  N/A X

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

B. Substance Fails Criteria Category: _________ Comments: ___________________________________________________ 

________________________________________________________________________________________________________ 

C. Proposed Annotation (if any): ___water extracted only ( current annotation for this section)._____________ 

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

D. Recommended Committee Action & Vote (State Actual Motion): ____ Recommend Tragacanth Gum for listing 

on § 205.606 (b) of the National List________________________________________________________________ 

________________________________________________________________________________________________________ 

Motion by: _Julie Weisman_ Seconded:__Steve DeMuri__ Yes: _6___ No: __0___ Absent: ___0____ Abstain: __0___ 

 

 

1) Substance voted to be added as “allowed” on National List to § 205. 606 (b) with Annotation (if any) Water-extracted 

only___( current annotation for this section )______________

________________________________________________________________________________________________________ 

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: 

__Julie Weisman______________________ ___March 27, 2008______________________ 

 Committee Chair Date

Decision Sheets 

December 2006 
NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Substance - __ Tragaganth Gum ____

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 

This is an agricultural product. 

2. Is there environmental 

contamination during manufacture, 

use, misuse, or disposal? [§6518 

m.3] 

X 

3. Is the substance harmful to the 

environment? 

[§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 is an agricultural product used as an ingredient in an 

organic processed food. It is no longer in the agro-ecosystem. 

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5] 

X This is an agricultural product used as an ingredient in an 

organic processed food. It is no longer in the agro-ecosystem. 

. 

8. Is there a toxic or other adverse 

action of the material or its 

breakdown products? [§6518 m.2] 

X This is an agricultural product used as an ingredient in an 

organic processed food. It is no longer in the agro-ecosystem. 

9. Is there undesirable persistence 

or concentration of the material or 

breakdown products in 

environment?[§6518 m.2] 

X This is an agricultural product used as an ingredient in an 

organic processed food. It is no longer in the agro-ecosystem. 

10. Is there any harmful effect on 

human health? [§6517 c (1)(A)(i) ; 

6517 c(2)(A)i; §6518 m.4] 

X Tragaganth Gum is considered GRAS by the FDA 

 (CFR 21 § 182.10 

11. Is there an adverse effect on 

human health as defined by 

applicable Federal regulations? 

[205.600 b.3] 

X 

12. Is the substance GRAS when 

used according to FDA’s good 

manufacturing practices? [§205.600 

b.5] 

X See # 10 above. 

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. 

Decision Sheets 

December 2006 
Category 2. Is the Substance Essential for Organic Production? Substance - ___ Tragaganth Gum ____

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 This is an agricultural product. 

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 This is an agricultural product. 

3. Is the substance created by 

naturally occurring biological 

processes? [6502 (21)] 

X 

Petition p.2 #5 states “ the gum naturally exudes during 

harvest season through openings in the plants bark as a means 

of protection.” 

4. Is there a natural source of the 

substance? [§205.600 b.1] X Petitioned substance is from a natural source. 

5. Is there an organic substitute? 

[§205.600 b.1] X 

Petition p.3 #11 describes that organic locust bean, arabic and 

guar gums are available but these do not hold up as well as 

petitioned material under certain temperatures and Ph levels. 

6. Is the substance essential for 

handling of organically produced 

agricultural products? [§205.600 

b.6] 

 

X 

 

7. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)] 

X Peitioned material is wholly natural. 

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 

10. Is there another practice that 

would make the substance 

unnecessary? [§6518 m.6] 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. 

Decision Sheets 

December 2006 
Category 3. Is the substance compatible with organic production practices? Substance - _ Tragaganth Gum 

Extract

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Is the substance compatible 

with organic handling? [§205.600 

b.2] 

X 

Attachment # 2 is an article describing the cultivation, harvest 

and processing of gum tragacanth as being identical to gum 

Arabic, which is already included on the National List § 

205.606. 

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 

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] 

XX 

 Used to create textures in processed products to meet 

consumer expectations of those types of products, not to 

restore texture lost during processing. 

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. 

Decision Sheets 

December 2006 
Decision Sheets 

December 2006 

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 -Tragaganth Gum

Question Yes No N/A Comments on Information Provided (sufficient, 

plausible, reasonable, thorough, complete, unknown) 

1. Is the comparative description provided as 

to why the non-organic form of the material 

/substance is necessary for use in organic 

handling? 

 

XX 

 Petition p. 3 #11 describes that other gums are available in organic 

form but these do not hold up as well as petitioned material under 

certain temperatures and Ph levels required for the production of 

the sauces and dressing made by the petitioner. 

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? 

XX 

See #1 above. 

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 

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); 

XX 

Petition p. 4 “Justification Statement” describes that” altough [gum 

tragacanth] is capable of being produced 

by organic methods it is not currently being cultivated under 

organic certification....Nearly all the gum tragacanth produced in 

the world comes from Iran and neighboring countries.” 

The petitioner states that the non-organic gum tragacanth they 

currently use comes from Turkey and that the amount of organic 

agriculture taking place in Turkey is increasing. The petitioner 

states that Turkey is capable of providing a supply of organic gum 

tragacanth and that they (the petitioner) are actively seeking such a 

supply. 

b. Number of suppliers and amount 

produced; 

XX Petition p. 4 “Justification Statement” names two suppliers of 

gums. One, TIC Gums choses not to sell Tragacanth gum at all, the 

other, Gumix International can only obtain Tragacanth gum in nonorganic form. 

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; 

XX Petitioner does not indicate that weather events are a factor 

affecting the supply of Tragacanth gum in organic form. 

d. Trade-related issues such as evidence of 

hoarding, war, trade barriers, or civil unrest 

that may temporarily restrict supplies; or 

XX 

Petition p. 4 “Justification Statement” describes that “the United 

States has trade embargoes in place with Iran and other Middle 

Eastern countries which limits.... the trade of non-organic gum 

tragaganth, let alone an organic form.” 

e. Are there other issues which may present 

a challenge to a consistent supply?