Listing Allowed & Prohibited Inputs
This section includes:
Cross references:
USDA NOP: § 205.600 Evaluation criteria for allowed and prohibited substances, methods, and ingredients.
NZFSA Technical Rules for Organic Production:
Section 9, Inputs used in Organic Production
The following criteria will be utilised in the evaluation of substances or ingredients for the organic production and handling sections of the National List ((i.e. NZFSA Technical Rules for Organic Production, Tables 1-6):
(a) Synthetic and non-synthetic substances considered for inclusion on or deletion from the National List (i.e. NZFSA Technical Rules for Organic Production, Tables 1-6) of allowed and prohibited substances will be evaluated using the criteria specified in Section 9 of the NZFSA Technical Rules.
(b) In addition to point (a) above, any synthetic substance used as a processing aid or adjuvant will be evaluated against the following criteria:
- The substance cannot be produced from a natural source and there are no organic substitutes;
- The substance's manufacture, use, and disposal do not have adverse effects on the environment and are done in a manner compatible with organic handling;
- The nutritional quality of the food is maintained when the substance is used, and the substance, itself, or its breakdown products do not have an adverse effect on human health as defined by applicable New Zealand regulations;
- The substance's primary use is not as a preservative or to recreate or improve flavours, colours, textures, or nutritive value lost during processing, except where the replacement of nutrients is required by law;
- The substance is listed as generally recognised as safe (GRAS) by the NZFSA when used in accordance with NZFSA's good manufacturing practices (GMP) and contains no residues of heavy metals or other contaminants in excess of tolerances set by NZFSA; and
- The substance is essential for the handling of organically produced agricultural products.
(c) Nonsynthetics used in organic processing will be evaluated using the criteria specified in Section 9 of the NZFSA Technical Rules.
6.1 Crop Inputs
Synthetic substances allowed for use in organic crop production for the US.
The following substances in this section are allowed for use on organic crop products for export to the USA only. They are prohibited for use on organic crop products for export to the EU, unless specifically listed in tables or Sections as per cross references below.
Cross references:
USDA NOP; 205.601 Synthetic substances allowed for use in organic crop production
In accordance with the restrictions specified in this section, the following synthetic substances may be used in organic crop production: Provided, that use of the substances do not contribute to contamination of crops, soil, or water. Substances allowed by this section, except disinfectants and sanitizers in paragraph (a) and those substances in paragraph (c), (j), (k), and (l) of this section, may only be used when the provisions set forth in 205.206 9a) and through (d) prove insufficient to prevent or control the target pest:
(a) As algicide, disinfectants, and sanitizer, including irrigation system cleaning systems
Cross references:
NZFSA Technical Rules for Organic Production:
- Table 5 Cleaning Aids and Disinfectants Section 4.1
- Alcohols
- Ethanol
- Isopropanol
- Chlorine materials - Except, That, residual chlorine levels in the water shall not exceed the maxium residual disinfectant limit under the Safe Drinking Water Act
- Calcium hypochlorite
- Chlorine dioxide
- Ozone gas - for use as an irrigation system cleaner only
- Peracetic acid - for use in disinfecting equipment, seed, and asexually propagated planting material
Soap-based algicide/demossers
(b) as herbicides, weed barriers, as applicable
Cross references:
NZFSA Technical Rules for Organic Production:
- Table 2 Pesticides
- Section 5.6
- Herbicides, soap-based - for use in farmstead maintenance (roadways, ditches, right of ways, building perimeters) and ornamental crops.
- Mulches
- Newspaper of other recycled paper, with out glossy or coloured inks
- Plastic mulch and covers (petroleum-based other than polyvinyl chloride (PVC))
(c) As compost feedstock
Cross references:
NZFSA Technical Rules for Organic Production:
Table 1 Fertiliser and soil Conditioners
- Section 4.1
Newspapers or other recycled paper, with out glossy or coloured inks
(d) As animal repellents
Cross references:
NZFSA Technical Rules for Organic Production:
- Table 2 Pesticides
- Section 5.6
Soaps, ammonium- for use as a large animal repellent only, no contact with soil or edible portion of crop.
(e) As insecticides (including acaricides or mite control)
NZFSA Technical Rules for Organic Production:
- Table 2 Pesticides
- Section 5.6
- Ammonium carbonate – for use as bait in insect traps only, no direct contact with crop or soil.
- Boric acid-structural pest control, no direct contact with organic food or crops
- Elemental sulphur
- Soaps, insecticidal
- Ferric phosphate – for use as a molluscicide to bait slugs and snails
(f) As rodenticides
Cross references:
NZFSA Technical Rules for Organic Production:
- Table 2 Pesticides
- Section 5.7
- Sulfur dioxide-underground rodent control only (smoke bombs)
- Vitamin D3
(g) As plant disease control
Cross references:
NZFSA Technical Rules for Organic Production:
- Table 2 Pesticides
- Section 5.7
- Coppers, fixed-copper hydroxide, copper oxide, copper oxychloride, includes products exempted from EPA tolerance, provided, that copper-based materials must be used in a manner that minimizes accumulation in the soil and shall not be used as herbicides
- Copper sulphate- substances must be used in a manner that minimizes accumulation of copper in the soil
- Hydrated lime
- Hydrogen peroxide
- Peracetic acid-for use to control fire blight bacteria
- Potassium bicarbonate
- Streptomycin, for fire blight control in apples and pears only
- Tetacycline (oxytetracycline calcium complex), for fire blight control only.
Clarification on the use of conventional grafting waxes containing petroleum jelly and prohibited fungicides.
With regards to the use of grafting wax containing petroleum jelly and prohibited fungicides, according to NZFSA the plants treated with a prohibited substance will lose organic status. These plants will have to undergo a 12 month conversion period before products taken can be exported to the US (- rule 205.204 (a) of the US NOS), and a 36 month conversion period before products taken can be exported to the EU (-section 5.1 of the NZFSA Tech Rules). The trees as well as the land would loose organic status if grafting wax is used. There is however the opportunity to explore the use of only petroleum jelly (without fungicides) to assist grafting
(j) As plant or soil amendments
NZFSA Technical Rules for Organic Production:
- Table 1 Fertilisers and soil Conditioners
- Section 5.3
- Aquatic plant extracts (other than hydrolyzed) – Extraction process is limited to the use of potassium hydroxide or sodium hydroxide: solvent amount used is limited to that amount necessary for extraction
- Calcium chloride- only for use as a brine sourced foliar spray to treat a physiological disorder associated with calcium uptake
- Humic acids- naturally occurring deposits, water and alkali extracts only
- Lignin sulfonate- chelating agent, dust suppressant, floatation agent
- Magnesium sulphate – allowed with a documented soil deficiency
Micronutrients – not to be used as a defoliant, herbicide, or desiccant. Those made from nitrates or chlorides are not allowed. Soil deficiency must be documented by testing
- Soluble boron products
Sulfates, carbonates, oxides, or silicates of zinc, copper, iron, manganese, molybdenum, selenium, and cobalt
- Liquid fish products – can be pH adjusted with sulphuric acid or phosphoric acid. The amount of acid used shall not exceed the minimum needed to lower the pH to 3.5
- Sodium nitrate - Use must be restricted to 20% of the crops total nitrogen requirement
- Vitamins, B1, C and E
(k) As plant growth regulators
Cross references:
NZFSA Technical Rules for Organic Production:
- Table 1 Pesticides
- Section 5.3
- Ethylene gas-for regulation of pineapple flowering
- As floating agent in postharvest handling
Cross references:
NZFSA Technical Rules for Organic Production:
- Not covered
- Lignin sulfonate
- Sodium silicate- for tree fruit and fiber processing
As synthetic inert ingredients as classified by the Environment Protection Agency (EPA), for the use with non-synthetic substances or synthetic substances listed in this section and used as an active pesticide ingredient in accordance with any limitations on the use of such substances
Cross references:
NZFSA Technical Rules for Organic Production:
- Not covered
- EPA List 4-inerts of Minimal Concern
- EPA List 3- Inerts of unknown toxicity- for use in passive pheromone dispensers
Both are limited to synthetic inert ingredients as classified y NZFSA-ACVM.ERMA, for use with non-synthetic substances or synthetic substances listed in this section and used as an active pesticide ingredient in accordance with any limitations on the use of such substances.
6.2 Livestock Inputs
Cross references:
Synthetic substances allowed for use in organic livestock production
The following substances in this section are allowed for use on livestock products for export to the USA only. They are prohibited for use on livestock products for export to the EU, unless specifically listed in tables or Sections as per cross references below
Cross references:
USDA NOP: 205.603 Synthetic substances allowed for use in organic livestock production
In accordance with restrictions specified in this section the following synthetic substances may be used in organic livestock production:
(a) As disinfectants, sanitisers, and medical treatments as applicable
Cross references:
NZFSA Technical Rules for Organic Production:
- Table 5 Cleaning Aids and Disinfectants
- Section 6.5.5 – 6.5.10
1.Alcohols
(i) Ethanol – disinfectant and sanitiser only, prohibited as a feed additive
(ii) Isopropanol – disinfectant only
2.Aspirin – approved for health care use to reduce inflammation
3. Chlorine materials – disinfecting and sanitising facilities and equipment. Residual chlorine levels in the water shall not exceed the maximum residual disinfectant limit under the Drinking Water Standards for New Zealand 2000.
(i) Calcium hypochlorite
(ii) Chlorine dioxide
(iii) Sodium hypochlorite
4. Chlorohexidine – Allowed for surgical procedures conducted by a veterinarian. Allowed for use as a teat dip when alternative germicidal agents and/or physical barriers have lost their effectiveness.
5. Electrolytes – without antibiotics
6. Glucose
7. Glycerin – Allowed as a livestock teat dip, must be produced through the hydrolysis of fats or oils.
8. Iodine
9. Hydrogen peroxide
10. Magnesium sulfate
11. Oxytocin – use in postparturition therapeutic applications
12. Parasiticides
Ivermectin – prohibited in slaughter stock, allowed in emergency treatment for dairy and breeder stock when organic system plan-approved preventive management does not prevent infestation. Milk or milk products from treated animal cannot be labelled as provided for in this standard for 90 days following treatment. In breeder stock, treatment cannot occur during the last third of gestation if the progeny will be sold as organic and must not be used during the lactation period of breeding stock.
12. Phosphoric acid – allowed as an equipment cleaner, Provided, that, no direct contact with organically managed livestock or land occurs.
13. Biologics
Vaccines
(b) As topical treatment, external parasiticide or local anaesthetic as applicable.
Iodine
Lidocaine – as a local anaesthetic. Use requires a withdrawal period of 90 days after administering to livestock intended for slaughter and 7 days after administering to dairy animals.
Lime, hydrated – (bordeaux mixes), not permitted to cauterise physical alterations or deodorise animal wastes.
Mineral oil – for topical use and as a lubricant.
Procaine – as a local anaesthetic, use requires a withdrawal period of 90 days after administering to livestock intended for slaughter and 7 days after administering to dairy animals.
Copper sulphate
(c) As feed supplements
Cross references:
NZFSA Technical Rules for Organic Production:
- Table 3, section 4 Feed additives
Milk replacers – without antibiotics, as emergency use only, no nonmilk products or products from BST treated animals.
(d) As feed additives
Cross references:
NZFSA Technical Rules for Organic Production: Table 3, section 4 Feed additives
DL – Methionine, DL-Methionine-hydroxy analog, and DL-Methionine-hydroxy analog calcium- for use only in poultry production until October 1, 2008.
2. Trace minerals, used for enrichment or fortification when FDA approved, including:
3. Vitamins, used for enrichment or fortification when FDA approved
(e) As synthetic inert ingredients as classified by NZFSA-ACVM/ERMA, for use with non-synthetic substances or a synthetic substance listed in this section and used as an active pesticide ingredient in accordance with any limitations on the use of such substances.
Cross references:
NZFSA Technical Rules for Organic Production:
- Table 3, part 2.2
Fish-based feeds
Fish and fish products are not considered to be from organic sources and on that basis are prohibited as animal feeds by US.
Interpretative note
On 3/1/02, the US National Organic Programme posted an answer to a “Frequently Asked Question” which indicates that fish products can be used for livestock feed
Q: Is the feed that is fed to organic livestock and poultry “vegetarian” feed?
A: Not necessarily. Although as stated in the National Organic Standards subpart C, section 205.237(b)(5), “The producer of an organic operation must not feed mammalian or poultry slaughter by-products to mammals or poultry.” there is no restriction against organic livestock feed containing appropriate fish products.)
6.3 Processing Inputs
Non-agricultural (non-organic) substances allowed as ingredients in or on processed products labelled as organic”or “made with organic (specified ingredients or food group(s)”.
The following substances in this section are allowed for use in organic products for export to the USA only. They are prohibited for use in organic products for export to the EU, unless specifically listed in tables or Sections as per cross references below.
Cross references:
USDA NOP: 6.3.1 Non-agricultural (non-organic) substances allowed as ingredients in or on processed products labelled as organic”or “made with organic (specified ingredients or food group(s)”.
The following non-agricultural substances may be used as ingredients in or on processed products labelled as organic”or “made with organic (specified ingredients or food group(s) only in accordance with any restrictions specified in this section.
Non-synthetics allowed:
- Animal enzymes – (rennet- animal derived: Catalase- bovine liver: Animal lipase: Pancreatin: Pepsin: and Trypsin)
- Calcium sulphate- mined only
- Glucono delta-lactone-production by oxidation of D-glucose with bromine water is prohibited
Cross references:
NZFSA Technical Rules for Organic Production:
- Table 4, Ingredients, Processing Aids
Summary of differences:
The following processing inputs are allowed by NZ, as prescribed in Table 4, NZFSA Technical Rules for Organic Production, but prohibited by US:
- Agar, argon, calcium sulphate, carrageenan, casein, ethanol solvent, karaga gum, hazelnut shells, isinglass, rice meal, sodium tartrate, sulphuric acid, talc, tannic acid, tragacanth gum, and vegetable oils. All of Table 4 Part C
- Volatile solvents
Cross references:
USDA NOP: Section 205.270 c2
US specifically prohibits synthetic volatile solvents in products labelled ‘organic’ and ‘100% organic’. NZ does not specifically prohibit synthetic volatile solvents, but none are approved on the list of allowed processing inputs.
