NOC Comments to National Organic Standards Board

The National Organic Coalition has submitted extensive testimony to the National Organic Standards Board (NOSB) calling for stronger enforcement of the organic standards and clarity in several areas where the lack of consistency is causing to harm to producers who are following the letter and intent of the organic law and regulations. NOC is asking that:

  • Dairy producers be provided with a level playing field. This means more consistent enforcement of the pasture rule and finalizing a 2015 proposed regulation to provide clarity on how conventional dairy animals are transitioned into organic (‘Origin of Livestock’).

  • USDA reinstate the Organic Livestock and Poultry Practices rule to provide true outdoor access for poultry and to implement NOSB recommendations on animal welfare in organic.

  • NOSB support a moratorium on the certification of new hydroponic and container operations – there are no standards in place for these systems, which creates a situation that is open to abuse.

Import Fraud

On organic import fraud, NOC is urging that the USDA National Organic Program, NOSB, accredited certifiers, and organic stakeholders move forward swiftly to:

  • Issue a new regulation to eliminate exclusions from certification for uncertified entities, as required by the 2018 Farm Bill.

  • Strengthen reporting of organic acreage in the Organic Integrity Database and improve the user interface. Significant gaps in data collection greatly impede the ability to deter fraud. In addition, researchers and organic stakeholders need access to meaningful organic acreage data that can be segregated.

  • Strengthen the NOP accreditation system in response to findings from the 2018 Peer Review audit and make the peer review audit report publicly available.

NOC also commented on 10 NOSB proposals and Discussion Documents, as well as 7 petitions and 33 materials that are up for sunset review.** NOC opposes or has serious concerns about petitions to add oxalic acid, sliver dihydrogen citrate, pullulan, collagen gel, AITC, ammonium glycinate, and calcium acetate to the National List.

You can read our full comments to the NOSB here.

NOC’s staff team will also be delivering oral testimony to the Board in Seattle on April 24.

** The National Organic Standards Board (NOSB) must review every substance on the National List of Allowed and Prohibited Substances every five years to confirm that it continues to meet all required criteria. This review is called “sunset review.” More information is available here:

Abby Youngblood