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The U.S. Department of Agriculture (USDA) administers the National Organic Program (NOP), which includes standards for “organic” food in the United States. The use of synthetic substances generally is prohibited in organic foods, with the exception of specific materials that have been evaluated and added to a national list of allowed and prohibited substances (“National List”). The National List also specifies nonsynthetic substances that may not be used in organic production. Although the National List identifies substances that may or may not be used in organic production, it does not address the use of substances in post-harvest handling of organic products.
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NOP recently issued a final guidance document to address this issue. Titled “Substances Used in Post-Harvest Handling of Organic Products (NOP 5023),” the guidance clarifies USDA’s organic regulations with respect to substances used in post-harvest handling activities, such as washing, cleaning, sorting, packing, cooling, and storing of raw agricultural products, and facility pest management. According to the guidance, substances that may be used in post-harvest handling include:
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substances allowed for use in handling in the National List (where there are no restrictions specified that would prevent such use);
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nonsynthetic substances allowed for use in crop production (where there are no restrictions in the National List that would prevent such use); and
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synthetic substances in the National List (where they are specifically annotated to permit post-harvest use).
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The guidance document provides greater clarity for accredited certifying agents and organic operations and helps resolve the confusion that previously existed in this area.
