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Earthworm super powers | NOP news | Let’s expand markets for minor ingredients

“Dreams don’t have deadlines.”  ~LL Cool J

President’s Message

For over 30 years, Wolf & Associates has been providing comments to the National Organic Standards Board. Our participation is one way we work to grow the organic sector with integrity. The underlying passion and thread of our efforts is to increase the acreage of organic production, which in turn improves soil carbon and plant, animal, human, and planetary health.

One way to facilitate growth of organic is to apply the commercial availability clause to the entire list of 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 of the National Organic Program rules.

The requirement to use an organic form of an ingredient when available provides a mechanism for innovation and drives an increase in organic acreage. This commercial availability rule currently applies to use of flavors, yeast, collagen gel, and indirectly for silicon dioxide. Advancements in organic processing demonstrate we can produce certified organic versions of more items on §205.605. Consider flavors—there are now two additional certified organic flavor bases—ethyl acetate and benzaldehyde—ready for market, a positive change driven by the commercial availability clause. This is just a beginning – imagine the impact if commercial availability was applied to all the other materials on the list.

This regulatory change would encourage the development of additional organic ingredients, providing new markets for organic crops for these new supply chains.

We have been making this comment to the NOSB for many years but it has not gotten traction. So, we now propose preparing a petition for this change and are seeking like-minded stakeholders. Please contact us if you’d like to participate. Together, we can use our voices to boost the market for minor organic ingredients, and spur additional organic agricultural production.

We’ll be making comments during the oral comment periods October 17 and 19, and attending the meeting if you’d like to discuss this, or any other organic sector matter.

Bill Wolf
Wolf & Associates

Regulatory Updates


NOP Speeds Up Investigations
The National Organic Program’s 2023 Organic Oversight and Enforcement report includes a summary of investigations and compliance actions, an update on the Organic Agricultural Product Imports Interagency Working Group, a look at organic import oversight, and. updates on the Transition to Organic Partnership Program and the Organic Human Capital Development Initiative. In fiscal year 2022, NOP received 554 complaints and inquiries. Educational information resolved 41% of them, and the most common outcomes for the other 59% were voluntary compliance or no violation found. Thanks to additional staff, training and new technology, NOP has reduced the time it takes to complete an investigation from 13 months in 2018 to less than 4 months in 2022. Shorter investigations mean swifter enforcement actions, better protecting the integrity of organic products.

NOP Wants More Discussion on Biodegradable Biobased Mulch Film
In a September 9 memo, the National Organic Program (NOP) asked the National Organic Standards (NOSB) Board to keep working on the topic of biodegradable biobased mulch film (BBMF) in organic crop production. Although biobased mulch film products are allowed in organic crop production, there are no known products that meet the current requirements for 100% biobased content or the NOSB’s 2021 recommendation for 80% biobased content. NOP has determined that it will not implement the Board’s 2021 recommendation, since the recommendation would not provide additional options to farmers.

Biodegradable Products Institute Wants To Allow Compostable Plastics in Organic Compost
In an effort to align the National Organic Program requirements with state composting programs, the Biodegradable Products Institute filed a petition to update the National Organic Program’s definition of composting and set a definition for composting feedstocks. The petition asserts that the current regulations were established before compostable plastic packaging and similar products were developed, and thus prevent them from being used in facilities generating compost for the organic market. Furthermore, they say, the current definition could hamper efforts to improve the circularity of packaging and increase food scrap collection.

NOSB Fall Meetings Will Be October 17, 19 and 24-26
The National Organic Standards Board Fall 2023 meeting will be held live online and in person from 10 a.m. to 5 p.m. Eastern time October 24-26 in Providence, Rhode Island. The meetings are free and open to the public, and registration is not required. Online public comments can observed on October 17 or 19 from noon-5 p.m. Eastern. Eastern on October 17 or 19. The meeting agenda includes reports from the USDA and the NOSB board discussions.

Inside the Beltway

House Rules Committee Quashes Amendment to Stop OLPS
The US House of Representatives Rules Committee found that an amendment to the House Agriculture Appropriations bill prohibiting the use of agriculture appropriation funds to write, prepare, or publish, implement, or enforce the proposed Organic Livestock and Poultry Standards rule was made out of order. As a result, the amendment will not advance to the House floor for a vote. A similar amendment in the Senate is still in play. The Organic Trade Association is gathering support to fight this attempt to undermine the USDA organic seal.

US Government Avoids Shutdown
Although Congress extended funding for some programs in a continuing resolution to keep the government operating until November 17, 2023, Farm Bill appropriations were not among them. Unless either an extension of the bill or a new Farm Bill is passed before the end of the year, older permanent laws will come back into force, potentially disrupting commodity markets.

FSIS To Test Cattle Slated for the “Raised Without Antibiotics” Market
USDA’s Food Safety and Inspection Service (FSIS), in partnership with USDA’s Agricultural Research Service (ARS), is starting a new exploratory sampling program to assess whether antibiotics residues are detected in cattle intended for the “raised without antibiotics” market. The program will help USDA assess if a new verification program is needed. Liver and kidney samples from eligible cattle will be tested for more than 180 veterinary drugs from major classes of antibiotics. If antibiotic residues are detected, establishments, who will be notified by letter, will need to take actions to prevent misbranded product in commerce.

Help USDA Prioritize the Most Useful Organic Market Data
As part of its Organic Data Initiative, USDA’s Agricultural Marketing Service Market News is asking members of the organic industry to complete a survey on the their data needs. Results of the survey will influence the data on the organic sector that will be available to the public in the future.

USDA Provided Organic Dairy Marketing Assistance;
Milk Loss Program Opens

United States Department of Agriculture’s Farm Service Agency made a second round of payments to organic dairy operations participating in the Organic Dairy Marketing Assistance Program. A total of $20 million dollars went to help dairy producers mitigate market volatility, higher input and transportation costs, unstable feed supplies and prices that have created unique hardships in the organic dairy industry. FSA has also opened applications for the Milk Loss Program, which will provide payments to dairy operations that were forced to remove milk from the commercial milk market due to the consequences of weather events that inhibited delivery or storage of milk during 2020, 2021, and 2022. Applications are due October 16.

International News

India’s Laboratories Ordered to Improve Organic Product Testing
In an effort to build trust with consumers amid concerns about adulterated organic products in the market, India’s Food Safety and Standards Authority (FSSAI) has directed all state-authorized laboratories to put infrastructure in place for testing organic products. The government of India intends to promote organic products domestically and to boost exports, and wants reliable testing to assure the authenticity of organic products.

The Survey Says…

From the “Bill Wolf Nailed It” File:
Earthworms Contribute Significantly To Global Food Supplies
A study published in Nature Communications estimated that earthworms add more the 140 million metric tons per year to the global food supply, or about 6.5% of global grain (corn, rice, wheat, barley) production and 2.3% of legume production. In the global South, earthworms contribute 10% of total grain production in Sub-Saharan Africa and 8% in Latin America and the Caribbean.

Organic Cropping Systems Do Less Damage To Environment
A meta-analysis of studies using life cycle assessment to compare conventional and organic cropping systems found that “despite lower yields, organic crop systems show better environmental performance compared to conventional ones for climate change, ozone depletion, ecotoxicity and use of resources (i.e. abiotic, mineral and metal resources).”

Comparison of organic and conventional cropping systems: A systematic review, published in Environmental Impact Assessment Review, also found that fertilization is the cultivation process most responsible for the impacts in conventional systems. Although the reduced impacts of organic cropping systems is systematically present across crop classes such as fruits and nuts, specific crops within those classes, such as apples, contain exceptions. In addition, the researchers point out that life cycle assessment does not adequately account for some aspects of farming, such as biodiversity and soil health.

Continuous Improvement Features in Global Trends Report
Mintel’s 2024 Global Food Trends Report identified five trends that will be important for brands next year and beyond:

  • Being Human—an appreciation of the human experience, such as personal connections and emotions
  • More Than Money—shared core values and value
  • Relationship Renaissance—renewed importance of interpersonal relationships and social connection
  • New Green Reality—a shift from “zero-sum” sustainability initiatives to continuous improvement and tangible solutions.
  • Positive Perspectives—honesty in communications and support for developing resilience

Within the “New Green Reality” trend, 60% of American consumers agree that many companies are ‘just pretending’ to be sustainable. Authenticity and measurable outcomes are some of the keys to reach consumers and encourage trust. In Canada, 37% of consumers feel farmers are trustworthy information sources, compared to 19% of consumers who feel well-known food brands are trustworthy information sources. In the US, 34% of consumers would choose a product based on familiarity rather than sustainability claims. More.

Entrepreneurial Farmers are Becoming the Norm
In research designed to clarify US farmers’ current attitudes and mindsets by looking at psychographics, Aimpoint Research’s Farmer of the Future 2.0 analysis found that the concentration of farmers in each of the market segments they identified is changing faster than predicted. Entrepreneurs and innovators—those farmers and ranchers that embrace change— are becoming the norm in the United States. These groups also skew younger.

Fairtrade Label Garners Trust
Research from Fairtrade America found that 86% of US shoppers say they recall an ethical or sustainability label on products while they shop. Recognition of the Fairtrade label is up 118% since 2019, with 61% of US consumers aware of it. Moreover, 72% of US consumers trust the Fairtrade label. Millennials are the most frequent purchasers, with 63% of those familiar with the label buying Fairtrade products regularly. The top three motivators shoppers used in choosing products were promises of reduced pesticides and chemicals, no child labor and improved living standards for farmers and workers.

Organic Industry News & Notices

What’s Hot At Natural Products Expo?
Food Business News identified several trends at Natural Products Expo East:

  • Flavors from around the world in condiments, snacks and beverages, especially flavors from the Middle East and Asia featuring tahini, sesame, ginger, turmeric and other spicy delights.
  • Upgraded products for babies and children, again with flavors form around the world and spotlighting convenience and less sugar.
  • Canned non-alcoholic “mocktails” with sophisticated flavors and coffee alternatives.

Natural Products Expo East Ends
After nearly 40 years, Natural Products Expo East had its final edition in Philadelphia last month. Informa Markets’ New Hope Network, the show’s creators, will launch a new platform—Newtopia Now—to encourage what they describe as “a more tailored and intentional approach to connection and product discovery.”  The event is slated for August 6-8, 2024, in Savannah, Georgia.

OMRI and IOIA Courses Support Professional Development
There’s still time to register for webinar trainings from the Organic Materials Review Institute and the International Organic Inspectors Association. Designed for new and returning inspectors, the courses will also be useful for any organic professionals interested in input materials. Course activities start well in advance of the sessions, so sign up soon.

  • November 15: 200 Level NOP Processing Input Materials
  • December 13: 100 Level NOP Crop Input Materials

Organic Community

Leadership Changes at the Ecological Farming Association
Andy Fisher, Executive Director of the Ecological Farming Association, is leaving the organization and Rebecca North will be transition to acting Executive Director. The organization hosts the EcoFarm conference, January 17-20 at the Asilomar State Beach and Conference Grounds in Monterey, California. Registration opens October 16.

Career Opportunity at Farm Aid
Farm Aid Seeks a Business and Marketing Director to serve on the leadership team.