Clarkson Soy Products LLC, now known as Clarkson Specialty Lecithin, developed a proprietary water-based method for processing organic soybeans into organic soy lecithin. Unfortunately, the company was not able to leverage this innovation immediately in new sales. Why? Bleached lecithin was considered a synthetic material and unbleached lecithin was considered an allowed non-organic ingredient on the National List, so customers were not required to use organic lecithin.
In anticipation of petitioning the National Organic Program, Clarkson enlisted the services of Wolf DiMatteo Associates for regulatory strategic advice. In response, we developed a comprehensive strategy for prevailing before the National Organic Standards Board (NOSB), including:
- Submission of an effective petition
- Strategy to solicit affirmative public comments
- Identification of experts to present at the NOSB meeting
- Preparation of comments for Clarkson’s public testimony
With our support, Clarkson successfully petitioned the NOSB in 2008 to remove non-organic unbleached and bleached lecithin from the National List. In May of 2009, the NOSB overwhelmingly supported the petition. The National Organic Program (NOP) has since completed the multi-step process of implementing the NOSB recommendation. Meanwhile, market opportunities for Clarkson have grown substantially.