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The following organic policy issues are open for public comment. Organic Trade Association members should lean on our regulatory staff for assistance in submitting comments, providing feedback to OTA for inclusion in our final comments, and with any issue-specific questions or concerns. 

Submit comments to USDA on calculating organic percentages

Comment Deadline: April 7, 2017

In response to a request by OTA, the National Organic Program (NOP) has extended the comment deadline from February 6, 2017 to April 7, 2017 on its draft guidance on Calculating the Percentage of Organic Ingredients in Multi-Ingredient Products. Although USDA organic regulations establish labeling categories for organic products based on the percentage of organic ingredients in the product, certifying agents have interpreted the requirements for calculating the percent of organic ingredients differently. The draft guidance clarifies the standards for calculating organic percentages for finished products, including products that contain multi-ingredients. The draft guidance is designed to help businesses and certifiers implement the USDA organic standards consistently.

Written comments can be submitted electronically through and should be identified with the document number AMS-NOP-16-0085.

Submit Comments 

Submit comments to USDA on a national organic check-off program

Comment Deadline: April 19, 2017

Note: USDA extended the Organic Check-off public comment period by 30 days from March 20 to April 19, 2017. Read OTA's statement on the extention. 

The U.S. Department of Agriculture is seeking public comments to a proposal for a nationwide research and promotion check-off program for the organic industry. This action is a significant step that will advance the growing organic sector and have important and long-lasting benefits for organic farmers, businesses and consumers alike. The organic industry proposal estimates the organic check-off, referred to as GRO Organic (Generic Research and Promotion Order for Organic), could raise over $30 million a year to spend on research to make farmers successful, technical services to accelerate the adoption of organic practices, and consumer education and promotion of the organic brand. Learn more.

Your voice can make a difference. Anyone can submit comments to USDA electronically using the Federal Register or by visiting GROorganic. Comments may also be sent by mail or fax.

  • GROorganic: Organic Check-off supporters can submit a supportive comment with one-click on
  • USDA Federal Register: Search for AMS-SC-16-0112 and then follow the instructions for submitting comments
  • Mail: Heather Pichelman, Division Director, Promotion and Economics Division, Specialty Crops Program, AMS, USDA, 1400 Independence Avenue, SW., Room 1406-S, Stop 0244, Washington, D.C. 20250-0244
  • Fax: submit comments to (202) 205-2800

Please contact OTA ( or 202.403.8520) with questions, or if you are interested in speaking with a member of the GRO Organic Core Committee. 

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Submit comments to NOP on a proposal to revise the National List

Comment Deadline: April 19, 2017

USDA's National Organic Program (NOP) has extended the comment deadline by 30 days on a proposed rule that would address several recommendations the National Organic Standards Board (NOSB) made to NOP pertaining to the 2017 Sunset Review of inputs allowed in organic farming and processing. View the 2017 Sunset Proposed Rule.

Consistent with the NOSB recommendations that were made to NOP in 2015, the proposed rule would remove ELEVEN inputs from the National List for allowed use in organic production and handling. Upon removal, the prohibitions would take effect on the sunset date of June 27, 2017. The comment period now closes on April 19, 2017.

Comments may be submitted to using docket number AMS-NOP-16-0052.

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Submit comments to FDA on the use of the term "Healthy" on food labels

Comment Deadline Extended to April, 26 2017

The Food and Drug Administration (FDA) has announced the opportunity to comment on the use of the term “healthy” in the labeling of human food products. This action in part comes from a citizen petition asking that FDA update its nutrient content claim regulations to be consistent with current federal dietary guidance. In particular, the petitioners request that FDA amend the regulation defining the nutrient content claim “healthy” with respect to total fat intake and amend the regulation to emphasize whole foods and dietary patterns rather than specific nutrients. FDA is inviting public comment on the term “healthy,” generally, and as a nutrient content claim in the context of food labeling and on specific questions contained in its comment request document. Learn more.

Written comments can be submitted electronically through and should be identified with the document number FDA-2016-D-2335-0731.

Submit Comments

Vice President of Regulatory and Technical Affairs  
(503) 798-3294
Farm Policy Director
(360) 388-6422