Organic Trade Association
Organic Trade Association
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OTA's National List Backgrounder


In order to call a product organic, the ingredients must come from an organic farm. In addition, any processing of those ingredients must meet the conditions in the national organic regulations. In general, the national organic regulations allow the use of natural materials and prohibit the use of synthetics in food production. There are a few exceptions, however.


What is the National List?

The National List of Allowed and Prohibited Substances is the list of exceptions to the general requirement that natural materials are allowed and synthetic materials are prohibited. In other words, the national list is a list of prohibited natural materials (such as arsenic), and allowed synthetics (such as pectin, baking soda, and Vitamin C). Even though a synthetic may be allowed for one purpose does not mean that it is allowed for every possible use, so manufacturers need to pay careful attention to the usage restrictions mentioned in the regulations.


Who defines the National List?

The National Organic Standards Board (NOSB), a group of fifteen volunteers appointed to advise the secretary of agriculture, is responsible for recommending to the Secretary of Agriculture which materials will be on the list. The Secretary of Agriculture makes the final determination. A Techni­cal Advisory Panel (TAP) gathers and evaluates the scientific data and makes recommendations to the board based on seven review criteria:

1) Effect on human health.

2) Effect on the farm ecosystem.

3) Toxicity and mode of action.

4) Availability of gentler alternatives.

5) Probability of environmental contamination during manufacture, use and disposal.

6) Potential for interactions with other materials used.

7) Overall compatibility with a system of sustainable agriculture.

In 1995, the NOSB completed a massive review of the materials in use by organic producers, and those recommendations became the base for the National List. The procedure is ongoing, as new materials are reviewed for inclusion or prohibition. Any business or person can petition for a materials review.

In addition to the list above the national organic standards require synthetic processing aids must meet the following:

1) It cannot be produced from a natural source and has no organic ingredients as substitutes

2) Its manufacture, use, and disposal do not have adverse effects on the environment and are done in a manner compatible with organic handling as described in section 6513 of the OFPA.

3) The nutritional quality of the food is maintained and the material itself or its breakdown products do not have adverse effects on human health as defined by applicable Federal regulations.

4) Its primary purpose is not as a preservative or used only to recreate/improve flavors, colors, textures, or nutritive value lost during processing except in the latter case as required by law.

5) It is Generally Recognized as Safe (GRAS) by FDA when used in accordance with Good Manufacturing Practices (GMP) and contains no residues of heavy metals or other contaminants in excess of FDA tolerances.

6) Its use is compatible with the principles of organic handling.

7) There is no other way to produce a similar product without its use and it is used in the minimum quantity required to achieve the process.

How Is The National List structured?
The National List is part of the national organic regulations available at, and is divided into six parts. (Examples used here are as illustrations only. See the regulations for complete details.):

1) Synthetic substances allowed for use in organic crop production (section 205.601). Some examples include: sticky traps and newspapers for mulch.

2) Nonsynthetic substances prohibited for use in organic crop production (section 205.602) Some examples include: arsenic, tobacco dust, and ash from burning manure.

3) Synthetic substances allowed for use in organic livestock production (section 205.603). Some examples include: aspirin, chlorine for disinfecting equipment and sanitizing facilities, glycerin.

4) Nonsynthetic substances prohibited for use in organic livestock production (section 205.604). Only one substance is listed as of Dec. 2004: strychnine.

5) Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as “organic” or “made with organic (specified ingredients or food group(s)).” (section 205.605).  This section of the regulations is further divided into “Nonsynthetics allowed” and “Synthetics allowed.” Some examples of nonsynthetics allowed include dairy cultures, potassium chloride, camauba wax, yeast. Some examples of synthetics allowed include ascorbic acid (Vitamin C), carbon dioxide, lecithin, tocopherols (Vitamin E).

6) Nonorganically produced agricultural products allowed as ingredients in or on processed products labeled as “organic” or “made with organic (specified ingredients or food group(s)).” (section 205.606) This sections lists materials which may be used if an organic version is not commercially available. The complete list includes: cornstarch (native), gums (water extracted only; arabic, guar, locust bean, carob bean), kelp for use only as a thickener and dietary supplement, unbleached lecithin, and high-methoxy pectin.


These lists contain the relatively few exceptions to the basic understanding within the organic industry that organically grown and handled foods are produced with solely natural materials. This may seem like an unusual structure. However, it avoids the problem of trying to list every natural material organic growers or processors might use and it might neglect to mention all of the local re­sources available in a given region.


Why are there exceptions?

Organic production systems encourage a healthy environment with as few inputs as possible. The NOSB recommends that cultural, biological and other management tools be sought to replace material inputs — whether synthetic or natural.


Congress, in passing the Organic Foods Production Act, recognized that it will take time for organic producers and handlers to achieve the long term goals expressed in the Act. The National List was meant to reflect realistic organic practices, and to take into account current obstacles to ideal organic production. Therefore, some synthetics are allowed if the review process shows that they are:

Not harmful to human health or the environment;

Necessary to production because of unavailability of natural products;

Consistent with organic ideals.

Likewise, the law provides for prohibition of natural materials that may be harmful to human health or the environment, and inconsistent with organic ideals.


Why are there non-organic ingredients in some organic food?

If you were to make organic cookies at home you would naturally use organic flour, sugar, oil, eggs, raisins, etc. But what about the baking powder and baking soda? Because they are non-agricultural products, neither of these ingredients meets the definition of organic. Processors of many kinds of organic foods face the same dilemma. In addi­tion, nutritional fortification is sometimes required by regulation or professional guidelines, but not available in natural form.


Thus the NOSB recommends that the National List include synthetic processing aids and natural products such as minerals that are not agricultural. For the finished food to be called “organic,” these ingredients may not comprise more than 5% of the total product, by weight. For the finished product to be called “made with organic (specified food or food group(s)),” these ingredients may not comprise more than 30% of the product total by weight. Products that are composed of wholly organic ingredients may be identified as 100% organic.


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