what we mean:
Speak 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,
Readers should also contact their own state fertilizer
control officials. A directory can be downloaded at
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
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 not apply.
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 fertilizer.”
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
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 error.
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 farming.
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
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 Association