Material Inputs

Most commonly referred to as “Inputs” or “Materials” - these are products used by operations in the production or handling of organic agricultural products. These include things like fertilizers, pesticides, livestock medical treatments, equipment cleaners/sanitizers, processing aids, etc. These types of products typically cannot be “certified” so instead they must be reviewed and approved for compliance. The organic regulations require that all materials must be disclosed to the organic certifier and approved for their specific use prior to use on an organic operation.

Input materials can be Allowed, Allowed with Restriction, or Prohibited. Restrictions, also known as annotations, are included in the regulations and may place requirements on the source or the use of an input material. Inputs are approved for specific uses, under specific criteria for each scope (Crops, Livestock, Processing/Handling). For example, an approved livestock medical treatment might not be allowed as a fertilizer, or even a livestock feed ingredient. One product may need to be reviewed under a few different criteria, sometimes even within one scope.

Several different parts of the regulation cover input materials, but the primary sections are 7 CFR 205.105 Allowed and prohibited substances, methods, and ingredients in organic production and handling and the National List at 7 CFR Part 205 Subpart G. The NOP itself does not review brand name materials, but the National List covers substances which are exceptions to the general rule that non-synthetics are generally allowed and synthetics are generally prohibited.

• Check to see if the input material is approved by a recognized Material Review Organization (MRO).
  • PCO accepts their reviews without the need for further review so long as the intended use is the same as the use it was approved under. For example, if an input is approved by an MRO as a crop fertilizer and the product will be used as a crop fertilizer, PCO will accept that review. However, if an input is approved by an MRO as a crop fertilizer yet a client would like to use the input as a livestock feed additive, PCO would need to conduct a review of the product for that intended use. Approved MROs are: information for suppliers. PCO does not provide any guarantee or endorsement for materials included on our lists.

• Organic Materials Review Institute (OMRI)
• Washington State Dept. of Ag. (WSDA)
• California Department of Food and Agriculture (CDFA)

• Check to see if the input material is approved by PCO.
  • PCO reviews material inputs, such as cleaners & sanitizers, livestock health care products, pest and disease control products, processing aids etc. for our clients and members to determine whether their use is in compliance with the requirements of the National Organic Program, and the National List of Allowed and Prohibited Materials, as listed at 21 CFR 205.
  • PCO publishes an annual Approved Materials List, which is provided to PCO’s certified clients and applicants as well as current ACA and Business Members every year, both electronically and in print.
  • PCO’s Approved Materials List contains several thousand approved brand name products, as well as applicable restrictions and contact information for suppliers. PCO does not provide any guarantee or endorsement for materials included on our lists.

1. Ensure you are a current PCO client, Business Member, or ACA Member.
2. Fill out the material review request form linked above. Include all required information and as much supporting documentation as possible!
   1. In order to complete our compliance reviews, we will likely request product labels, SDS, spec sheets, and other documentation required to document that your product meets the requirements as an allowed input. All ingredient information is kept strictly confidential and is for our compliance review purposes only. See details here.
3. PCO will send you an invoice for the cost of the material review (if applicable). Please note a 3% credit card processing fee will be issued for all payments made with a credit card. The entity requesting the review agrees to pay according to invoice payment terms.
4. PCO Material Team staff may reach out to the manufacturer or requester for more information if needed to verify compliance with the NOP regulations. Entities requesting reviews must provide the exact material manufacturer name, material name, and the intended use. A material reviewed for multiple intended uses will consist of 1 billable review service per intended use.
   1. Four attempts of contact will be made to obtain review information from the material manufacturer. If the manufacturer does not respond to PCO’s requests or chooses not to participate, the material will receive a Prohibited due to Insufficient Information Status. The requestor will still be responsible for the associate review fees. These review outcomes will not be listed in PCO’s Approved Materials List.
   2. Additional fees will be incurred if a re-review is required due to a formulation change or the submission of information after a Prohibited due to Insufficient Information status has been assigned.
5. Upon successful completion of a review, PCO will assign the status of Allowed, Allowed with Restrictions, Prohibited, or See Notes with respective information.
6. Once PCO has reviewed a material and determined whether or not it is in compliance, the entity requesting the review will be notified and the material may be added to our published list of Approved Materials.
7. The Material Reports, Material Lists, or other Resources of PCO may not be posted on the internet or other publicly accessible communication method.

National List– The NOP itself does not review brand name materials, but the National List of Allowed and Prohibited Substances lists substances which are exceptions to the general rule that non-synthetics are generally allowed and synthetics are generally prohibited. Particular sections of the National List that you should be aware of include: §205.601 Synthetic Substances allowed in organic CROP production §205.602 Non-synthetic substances prohibited for use in organic CROP production §205.603 Synthetic substances allowed for use in organic LIVESTOCK production §205.604 Non-synthetic substances prohibited for use in organic LIVESTOCK production §205.605 Non-agricultural (non-organic) substances allowed as ingredients in or on processed products labeled as “organic” or “made with organic (specified ingredients or food group(s))” §205.606 Non-organically produced agricultural products allowed as ingredients in or on processed products labeled as “organic”