06
Oct
Beyond Pesticides Urges the Public To Comment on Critical Issues on Organic Integrity
(Beyond Pesticides, October 7, 2025) [Comments are due by 11:59 pm ET on October 8, 2025.] As the public comment period for the upcoming National Organic Standards Board (NOSB) meeting closes on October 8 at 11:59pm, under consideration is an issue that goes to the heart of organic integrity—contamination-free compost. In response to a petition from the Biodegradable Products Institute (BPI), a certifier of packaging and products for commercial composting, the NOSB’s Crops Subcommittee (CS) voted to keep synthetic compostable materials out of compost permitted in certified organic production. According to comments submitted by Beyond Pesticides, compost from plant and animal materials is of fundamental importance to organic practices. Composting is one way that organic growers meet the requirement in law to “foster soil fertility, primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring.” The integrity of organic production has always been tied to the integrity of compost.
Beyond Pesticides provides the public with comments on all the issues before the NOSB, which can be accessed here: Keeping Organic Strong and the Fall 2025 issues page. (The organization urges members of the public to copy and paste from the issues below or Fall 2025 issues page. Submissions can be made at Regulations.gov. Note: Regulations.gov has disabled the one-click option. Comments are due by 11:59 pm ET on October 8, 2025.)
Contaminants in broadly defined “compost feedstocks” cannot be predicted, but history suggests that more persistent toxic pollutants will be found. Under the Organic Foods
Production Act (OFPA), the NOSB controls allowed synthetic materials in organic production. Research continues to raise alarms about the hazards associated with the use of plastic, including the microplastic particles that are distributed in alarming amounts throughout the environment and taken up by organisms, including humans. Only synthetic materials that are specifically added to the National List through the prescribed process should be allowed in compost destined to be an input into organic production, according to the Crops Subcommittee and Beyond Pesticides, which urges that BPI be denied.
Beyond Pesticides has taken the following positions on key issues, and urges the public to comment:
Keep synthetic “compostables” out of organic compost
Please support the proposal of the Crops Subcommittee (CS) to keep synthetic compostable materials out of organic compost. Compost from plant and animal materials is of fundamental importance to organic practices. Composting is one way that organic growers meet the requirement in law to “foster soil fertility, primarily through the management of the organic content of the soil through proper tillage, crop rotation, and manuring.” The integrity of organic production must be maintained by preserving the integrity of compost. Contaminants in broadly defined “compost feedstocks” cannot be predicted, but history suggests that more persistent toxic pollutants will be found. The NOSB must maintain control over synthetic materials allowed in organic production, as required by the Organic Foods Production Act (OFPA). Research continues to raise alarms about the hazards associated with the use of plastic, including the microplastic particles that are distributed in alarming amounts throughout the environment and taken up by organisms, including humans. Only synthetic materials that are specifically added to the National List through the prescribed process should be allowed in compost destined to be an input into organic production. The NOSB should reopen the workplan item on contaminated inputs that is currently on hold.
Eliminate nonorganic ingredients in processed organic foods as a part of NOSB’s sunset review. Materials listed in §205.606 in the organic regulations are nonorganic agricultural ingredients that may comprise 5% of organic-labeled processed foods. The intent of the law is to allow restricted nonorganic ingredients (fully disclosed and limited) only when their organic form is not available. However, materials should not remain on §205.606 if they can be supplied organically, and we can now grow virtually anything organically. The Handling Subcommittee (HS) needs to ask the question of potential suppliers, “Could you supply the need if the organic form is required?” Materials on §205.606 up for sunset review this year made from agricultural products that can be supplied organically should be taken off the National List of allowed materials.
When the HS examines the health effects of materials on §606, it must include the effects of chemical residues, impacts on the environment, and worker exposure. It is absurd to judge whether may be allowed by looking at health and environmental effects of the pure substance in isolation from the effects of its production, use, and residues.
Allow the use of pear ester in organic production only as a component of traps. Pear ester is a chemical synthesized to be structurally and functionally identical to a volatile substance emitted by mature and ripening pears and other fruits. It is attractive to codling moths and is used in various ways to control them. As a component of traps, it is consistent with organic practices and can be helpful to organic fruit growers. Microencapsulated pear ester distributes microplastics in the environment and is incompatible with organic practices.
Keep synthetic hormones out of organic milk production
Oxytocin is available as a synthetic hormone and currently allowed in organic dairy. A vague annotation has resulted in some producers using it inappropriately for milk letdown. Oxytocin is a hormone and, even if rarely used, it leaves organic dairy farmers open to valid criticism that they can still use hormones. For this reason, the two largest organic milk buyers in the U.S. did not support it remaining on the National List of Allowed and Prohibited Substances. Alternative treatments are available. The NOSB should allow oxytocin to sunset or be removed from the National List. If it remains on the National List, the NOSB should adopt the recommended annotation, “use in post parturition therapeutic applications within 3 days after birth. It may not be administered to increase an animal’s milk production or for milk letdown.”
Eliminate the blanket allowance of “inert ingredients.”
Despite repeated recommendations from the NOSB, the National Organic Program at USDA has not moved to evaluate individual “inert” ingredients, which may be more toxic than active ingredients allowed in organic production and make up the largest part of pesticide products. The NOSB should delist them unless individually reviewed under the National List review standards.
Ensure that online organic consumers have full information
The law requires that organic products are labeled with the organic seal, ingredients, and identification of the certifier. This labeling is not always visible to online consumers. The NOP must require full labels to be provided in online sales platforms.
Beyond Pesticides provides the public with comments on all the issues before the NOSB, which can be accessed here: Keeping Organic Strong and the Fall 2025 issues page. (The organization urges members of the public to copy and paste from the issues below or Fall 2025 issues page. Submissions can be made at Regulations.gov. Note: Regulations.gov has disabled the one-click option. Comments are due by 11:59 pm ET on October 8, 2025.)
The Fall National Organic Standards Board (NOSB) meeting is scheduled for November 4 – 6, 2025. The public meeting of the NOSB is preceded by an opportunity for public comments in writing and via online webinars on October 28 and 30, 2025, from 12 pm to 5 pm ET.
