Case Studies

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 & 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.