A New Allowed Organic Crop Material: Paper-Based Planting Aids

A New Allowed Organic Crop Material: Paper-Based Planting Aids

by Mark Geistlinger, Customer Service Team Lead

Are you a vegetable farmer who uses paper-based planting system on your MOSA-certified organic farm? If so, you may have already learned that the National Organic Program (NOP) added a new material last December to the National List of synthetic substances allowed for use in organic crop production: "paper-based crop planting aids." The Organic Program also added a very specific definition of this material to the "Terms Defined" section of the National Organic Standards. Does this mean that paper-based media systems, such as the two commercial inputs used by some MOSA clients—the Paper Pot System from Small Farm Works and the Ellepots from Ellepot—are now permanently allowed for use? No, but the new additions to the Standards do create the necessary regulatory framework for these inputs to be reviewed by MOSA and other agencies.

MOSA and some other organic certifiers have allowed paper-based media systems for years based on the inclusion of "recycled paper" as an allowed synthetic material on the National List for use as mulch or a compost ingredient. About five years ago, other certification agencies informed the National Organic Program that they disagreed with this understanding, for two reasons: paper was not included on the National List for the actual use (planting media) of paper pot systems, and the paper pot inputs may contain non-paper ingredients (resin, adhesive, etc.) not included on the National List of allowed synthetic materials. The Organic Program agreed with this assessment and initially directed certifiers to not allow paper-based media systems. Advocates of paper pots immediately made a formal petition to have this material added to the National List, so the Organic Program agreed to allow continued use of paper planting media while the formal process for decision-making proceeded. That process—which included deliberations at several National Organic Standards Board (NOSB) meetings, hundreds of public comments, and a unanimous recommendation from the NOSB for National List inclusion—resulted in last December's revised Organic Standards that now recognize a place for paper-based media in organic production.

So what's next for MOSA's review of brand name paper planting systems? The very specific definitions now included in the National Organic Standards will serve as the review criteria MOSA and other agencies will use to determine if particular commercially-available paper pot inputs are acceptable for organic use. We have informed the manufacturers of these systems that we will continue to allow their use this year but we must receive verification documents addressing the new requirements. Alternatively, we will accept approval by either of the two accredited material review agencies, the Organic Materials Review Institute (OMRI) or the Washington State Department of Agriculture (WSDA). Once we have completed the review of a paper pot input we will communicate the result directly with clients who have that input on their Input Inventories.

Paper pot planting media's winding road through organic regulations perfectly showcases the deliberate, inclusive nature of rule-making within the USA's Organic Standards. Certification agencies were allowed to make their own material review decisions, until certifiers disagreed in their interpretations. The careful, thorough process that the NOP and NOSB then followed encouraged participation from all interested persons and a full consideration of the acceptability of paper as an organic media material. The resulting Standards change took time but resulted in a stronger rule that certification agencies can now consistently follow.