United States Department of Agriculture 1400 Independence Avenue SW. Policy Memo 13-2

Agricultural Marketing Service Room 2648-South Building Page 1 of 2

National Organic Program Washington, DC 20250

PM 13-2 Humic Acid Extraction Rev03 03 20 24 Authorized Distribution: Public 

Policy Memorandum

To: Stakeholders and Interested Parties

From: Miles V. McEvoy, Deputy Administrator

Subject: Humic Acid Extraction

Date: Approved on December 16, 2013

Links Updated March 20, 2024

This memorandum clarifies which materials are allowed for humic acid extraction under the 

USDA organic regulations.

Humic acids are allowed for use in organic crop production under the following allowance on the 

National List of Allowed and Prohibited Substances (National List) at 7 CFR 205.601:

§ 205.601 Synthetic substances allowed for use in organic crop production.

...

(j) As plant or soil amendments.

...

(3) Humic acids—naturally occurring deposits, water and alkali extracts only.

Issue:

The National Organic Program (NOP) has received requests to clarify which materials are 

allowed for alkali extraction of humic acid. The National Organic Standards Board (NOSB) has 

previously reviewed this substance. The technical reports reviewed by the NOSB described 

several alkali substances, including potassium hydroxide, sodium hydroxide, and ammonia.

The NOP is aware that some certifying agents and material evaluation programs have approved 

the use of ammonium hydroxide (the aqueous form of ammonia) and other alkali materials, 

including natural materials, for extraction. The use of certain extractants, such as ammonium 

hydroxide and potassium hydroxide, however, are potential issues of concern due to the risk for

fortification of humic acid products with prohibited synthetic fertilizers. In particular, 

ammonium hydroxide is used in conventional farming as a nitrogen fertilizer and is not permitted 

as a fertilizer under the USDA organic regulations.

Policy:

The annotation for humic acid at 7 CFR 205.601(j)(3) does not specify which alkali materials are 

allowed for extraction of humic acids. There is therefore no restriction regarding which alkali 
United States Department of Agriculture 1400 Independence Avenue SW. Policy Memo 13-2

Agricultural Marketing Service Room 2648-South Building Page 2 of 2

National Organic Program Washington, DC 20250

PM 13-2 Humic Acid Extraction Rev03 03 20 24 Authorized Distribution: Public 

materials may be used for extraction. Allowed extractants for humic acid include, but are not 

limited to:

• Potassium hydroxide;

• Sodium hydroxide;

• Ammonium hydroxide (aqueous ammonia); and

• Nonsynthetic (natural) substances.

However, extraction of humic acid with more than the necessary amount of synthetic alkali

material (i.e., for the purpose of inflating the nutrient analysis of the product) does not comply

with the annotation for humic acid at 7 CFR 205.601(j)(3) and is prohibited in organic crop 

production. 

Certifying agents and material evaluation programs must review humic acid products for 

indications that the product may be fortified, such as product label claims that indicate low 

concentrations of humic acid relative to the nutrient claims on the label. Humic acid products

that are fortified with ammonium hydroxide or potassium hydroxide are not allowed in organic 

crop production.

References:

The Organic Foods Production Act of 1990, as amended

7 U.S.C. 6508 Prohibited crop production practices and materials

USDA Organic Regulations (7 CFR PART 205)

7 CFR 205.2 Terms defined.

Fertilizer. A single or blended substance containing one or more recognized plant 

nutrient(s) which is used primarily for its plant nutrient content and which is designed for 

use or claimed to have value in promoting plant growth.

7 CFR 205.203 Soil fertility and crop nutrient management practice standard.

7 CFR 205.601 Synthetic substances allowed for use in organic crop production.

NOSB Technical Reports

Technical Evaluation Report for Humic Acids, January 27, 2006

Technical Advisory Panel Report for Humic Acid Derivatives, September 1996