what we mean:
up for congruity in organic labeling
due: February 19
Readers who support changes to AAPFCO label claims
for “organic” fertilizers, or who
have first-hand experience with confusing and/or
misleading claims, are invited to contact the
AAPFCO Labeling Committee, Dr. Maryam Khosravifard,
Chair, Agricultural Commodities & Regulatory
Services, 1220 N Street, Room A-472, CA Department
of Food & Agriculture, Sacramento, California
Readers should also contact their own state fertilizer
control officials. A directory can be downloaded
January 27, 2005: A farmer in the Northeast
applied a product named “Organo” to his hayfields.
The farmer had been assured by a salesperson that the product
was an “organic” fertilizer, but later found out
that the product was primarily dried sewage sludge. Those
hayfields lost certification for three years.
A product “EKO Organic Compost”, which has been
marketed as derived from municipal biosolids, is sold in Hawaii.
The product has caused problems for new organic growers who
are not aware of the product’s ingredients.
Farmers in the Midwest have run into problems using Milorganite®,
which advertises itself as an “organic nitrogen fertilizer.”
Milorganite is made from Milwaukee sewage sludge – perfectly
legal and useable as advertised—but prohibited for use
in organic production.
Other producers have had problems with potting soil and peat
moss products that are routinely identified as “organic”
yet contain prohibited synthetic fertilizers and wetting agents.
Could the same things happen today, now that the National
Organic Program (NOP) regulation has been fully implemented?
The short answer is “yes.” Because the USDA does
not control the labeling of fertilizers, NOP regulations do
States control labeling choice
Fertilizer label claims are regulated by state fertilizer
control officials, who belong to the Association of American
Plant Food Control Officials (AAPFCO).
Under AAPFCO’s existing definitions the word “organic”
has more to do with organic chemistry (presence of carbon)
than with organic agriculture. AAPFCO allows use of the word
“organic” on fertilizers that may contain urea,
sewage sludge (biosolids) and other substances prohibited
under NOP regulations. AAPFCO currently allows the terms “organic
fertilizer,” “natural organic fertilizer,”
“natural fertilizer,” and “organic base
The Organic Trade Association (OTA), in a November 30, 2004
letter from Katherine DiMatteo, requested that AAPFCO amend
its fertilizer labeling categories so that the word “organic”
only appears on products that are allowed under the NOP for
use in organic production.
Specifically OTA proposed that the term “organic”
when used on a fertilizer product, means: “that the
claim of the product, compound, mixture of compounds, or constituent
to be organic has been allowed or allowed with restriction
by the United States Department of Agriculture's National
Organic Program as specified in 7 CFR Part 205.”
The NOP has specific requirements for product inputs that
are allowed on certified organic farms. The rules permit natural
materials and a specific list of synthetic materials as long
as they meet a strict set of criteria. For example, while
most composts are okay products, including composts, containing
sewage sludge/biosolids are prohibited.
Certified organic farmers who inadvertently apply products
labeled as AAPFCO-approved “organic” that contain
materials prohibited for use in organic production may lose
their organic certification for three years, with ensuing
loss of income.
The use of “organic” fertilizers containing prohibited
ingredients can also have negative impacts on small farmers,
who are exempt from certification, but still must follow the
NOP regulation in order to sell their products as organic.
Small farmers, whose acreage is small enough to exempt them
from certification, are especially vulnerable to misleading
or confusing fertilizer labels. These farmers must follow
NOP regulations if they are to sell their products as organic
but because they do not go through a formal certification
process they are not required to list their implements on
an Organic System Plan nor are their operations reviewed by
a certifying agent where a second pair of eyes may catch the
Consumers and backyard gardeners, who have a common understanding
of “organic food” are also susceptible to deception.
Often they are not aware of the idiosyncrasies of the system
and understandably, believe that fertilizer products labeled
“organic” are suitable for organic gardening or
Although many “organic” fertilizers comply with
NOP regulations, many do not. Certifiers, farmers, and inspectors
cannot trust AAPFCO-regulated labeling as it exists, and must
re-verify all products used.
Adjustment of fertilizer terms would help reduce the confusion
caused by multiple definitions of the word “organic.”
By adopting the uniform definitions being considered by AAPFCO,
fertilizer manufacturers would be able to designate products
that are suitable for organic production, and buyers would
be able to clearly determine which products are suitable for
use under organic certification. In addition, consistent use
of the word “organic” would aid farmers seeking
products that will not compromise their organic certification
status or violate their status as exempt operations.
Board asks USDA to follow-up
The National Organic Standards Board (NOSB) in October 2004
endorsed changes to AAPFCO labeling claims to ensure that
the word “organic,” when used on fertilizer labels,
is consistent with NOP requirements. The NOSB has asked the
USDA staff to examine the issue and communicate to AAPFCO
USDA’s support for consistent use of the word “organic”
on fertilizer labels.
AAPFCO’s Labeling Committee will consider the changes
proposed by OTA at their mid-year meeting, scheduled February
19-24, at the Sheraton Four Points in Phoenix, Arizona. If
the changes are supported by the Labeling Committee, new labels
could be expected in 12 to 18 months.
Jim Riddle serves as chair of the USDA’s National
Organic Standards Board and organic policy advisor for NewFarm.org.
He was the founding chair of the Independent Organic Inspectors