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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. 

Deadline: July 3, 2018

Feedback needed on Proposed National GMO Food Disclosure Standard

The U.S. Department of Agriculture (USDA) is inviting stakeholder input on the establishment of a GMO labeling standard (National Bioengineered Food Disclosure Standard). The deadline for comments is July 3, 2018

The Organic Trade Association is in the process of analyzing the proposed rule with plans to submit comments specific to the provisions that safeguard organic as the gold standard for transparency and non-GMO status. Our analysis includes cross-referencing OTA's comments that were submitted to USDA on July 17, 2017 in response to the 30 questions the agency asked to help inform this proposed rule. To read background on the topic as well as view the full text of the law and corresponding USDA policy, visit USDA’s GMO Disclosure & Labeling web page. Please note that due to the congressionally mandated timeline for this rule-making (July 29, 2018), the comment period will not be extended, so it is important that anyone interested in filing comments do so in a timely manner. Please send feedback on the proposal to Gwendolyn Wyard no later than June 19, 2018.

Comments may be submitted directly to USDA through the Federal eRulemaking portal beginning Friday, May 4th. 

Deadline: June, 29, 2018

Feedback needed on changes to the National List 

USDA’s Agricultural Marketing Service published a proposed rule in the April 27 Federal Register to amend the National List of Allowed and Prohibited Substances (National List) concerning organic livestock production. Based on public input and the National Organic Standards Board’s (NOSB) November 2017 recommendations, the proposed rule would allow elemental sulfur in organic livestock production for use as a topical pesticide treatment to repel mites, fleas and ticks from livestock and their living spaces. It also would reclassify potassium acid tartrate from a non-agricultural substance to an agricultural substance. Potassium acid tartrate currently is listed as a non-organic ingredient allowed in organic products. Reclassifying potassium acid tartrate as an agricultural substance would require handlers to use the organic form when it is commercially available. If not commercially available, handlers would be allowed to use the non-organic form. The 60-day public comment period closes June 29. Please send feedback on the proposals to Gwendolyn Wyard no later than June 15. Access the proposed rule for more information on how to submit comments.


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