Paper Pots and Organic Certification, Fall 2019 Update
The fall 2019 National Organic Standards Board is approaching! This Spring, we thought this was going to be THE big meeting where a vote would occur on paper pots based on the petition we submitted in the Spring of 2018. We were poised to rally small scale farmers in support of the amazing paper chain pot system. Alas, the NOSB decided to postpone a vote while they gather additional input—including yours—and spend more time considering allowable ingredients in paper.
The “Discussion Document” on paper pots for the fall 2019 NOSB meeting is available on-line here (see pages 103-109). It contains proposed language to annotate the NOP rule in regard to paper. Input on the proposed language from the organic community is desired by the NOSB.
We encourage everyone to participate in this process so that the NOSB hears from lots of folks. See below for how to make your voice heard.
The issue became more complex than we originally assumed because the NOSB needs to write a rule that will not just cover potential ingredients in PAPER POTS but all manner of existing and potential PAPER-BASED PRODUCTION AIDS such as paper mulch, paper seed tape, paper collars to protect seedlings from cut worms, paper cloches, etc. The issues are complex and we know everyone has limited time to spend reading, so we are going to attempt to boil it down to the following key points.
ADHESIVES. Many people assume that the major hang-up on the paper pot issue is adhesives (glue). While this is important, the NOSB subcommittee reviewing our petition concluded quite a while ago that the existing allowance for paper in the NOP rule allows for non-toxic adhesives that are typically used in paper. The adhesives used in paper chain pots are exactly that: they are commonly used in paper and are non-toxic and inert (non-reactive). This conclusion is why the NOSB acted last year to successfully ask the NOP to revoked the ban on paper pots that was to have taken effect in 2019.
Main Point: Although it has not yet been officially voted on by the entire NOSB, it appears the adhesives used in paper chain pots will be acceptable for use on organic farms. The NOSB welcomes input on this issue.
VIRGIN PAPER. The existing allowance for paper in the NOP rules limits paper used in organic production to “newsprint or other recycled paper.” Our petition requests that this be broadened to include virgin paper. Our main argument is that the ingredients in paper products made with virgin paper are actually knowable whereas waste stream recycled paper products are composed of an unknown panoply of materials.
Main Point: The NOSB committee reviewing the paper issue appears to be in support of allowing virgin paper and seeks input from the organic community.
SYNTHETIC FIBERS. We identified this as the key issue early in the process and this is, indeed, the main sticking point in the conversation about paper-based production aids on organic farms. Our petition specifically mentions hemp fiber as a replacement for synthetic fiber in paper chain pots. The manufacturer of paper chain pots, Nitten, has been working diligently on a new line of paper chain pots using hemp fiber for organic production. However, because the committee is looking at the issue of paper in general, not just paper pots, they want to make sure that their rule-making covers a range of paper products, including paper mulch. Commercial paper mulch products are likely to need to be made stronger by using various fibers and strengthening agents. Paper pots also need to be durable enough to be effective. So, while Nitten is committed to bring a paper pot to the marketplace WITHOUT synthetic fibers, the NOSB has heard from other paper pot and paper product manufacturers that they desire to market paper products with synthetic fibers to organic farmers. As a result, the current proposed rule language (see NOSB discussion document) includes an allowance for “synthetic” fibers that use bio-based ingredients in paper pots in small amounts, 15% or less. The vinylon fiber used currently in paper chain pots meets the proposed “less than 15%” requirement but may not meet the definition of “bio-based” (which is not entirely clear since ‘synthetic’ and ‘bio-based’ seem contradictory).
Main Point: The discussion document brought forward by committee to the NOSB and the organic community seeks input on allowing small amounts of “synthetic, bio-based” fibers in paper products.
BIODEGRADABILITY. Due in large part to the issue of synthetic fibers (see above), the committee reviewing paper pots has included proposed rule language that requires paper pots and other paper-based production aids to meet a biodegradability standard of 90% decomposition within 2 years.
Main Point: The NOSB discussion document seeks input from producers who use paper pots and other paper-based production aids on how quickly paper pots and other paper materials break down in soil over time.
To provide input to the NOSB on these issues, following these links:
Written comments. Submit feedback on the NOSB Subcommittees’ proposals via Regulations.gov. (Docket # AMS-NOP-19-0038). The deadline to submit written comments is 11:59 p.m. Eastern Time October 3, 2019.
Oral comments. Oral comment registration is now open. The Board will hear oral comments during the following times:
October 15 & 17, 2019, from 1:00 - 4:00 p.m. Eastern (3-minute comment slot)
Wednesday, October 23 and Thursday, October 24, 2019 (3-minute comment slot)
If you have questions or comments for us, please contact us.