How to File a Petition

The National List of Allowed and Prohibited Substances identifies synthetic substances that may be used and the nonsynthetic (natural) substances that may not be used in organic crop and livestock production. It also lists the non-organic substances that may be used in or on processed organic products. Any individual or organization may submit a petition to add, remove, or amend the listing of a substance.

Role of the NOSB

The National Organic Standards Board (NOSB), a Federal Advisory Committee, reviews petitions based on specific criteria in the Organic Foods Production Act of 1990. Depending on the proposed use of the substance, the petition will be reviewed by an NOSB sub-committee: crops, livestock, or handling.

Role of the NOP

The National Organic Program (NOP) accepts petitions, solicits public comments, and manages all communication with petitioners.

Petition Process

The petition process is summarized below:

  • E-mail submission. Petitions may be submitted as a single PDF file via e-mail.

  • Mail submission. Petitions may be sent electronically (i.e. CD) or hard copy via mail:
    National List Manager
    USDA/AMS/NOP, Standards Division
    1400 Independence Ave. SW
    Room 2648-So., Ag Stop 0268
    Washington, DC 20250-0268
    Note: Electronic submission (by disk or email) is preferred to facilitate posting of petitions on the NOP website.

  • NOP determines if substance is eligible for petition. If the substance is eligible for petition and the petition meets the guidelines referenced above, it is forwarded to the appropriate NOSB sub-committee (crops, livestock, or handling). If the petition is insufficient or if additional information is needed, NOP contacts the petitioner to request additional information. Eligible petitions are posted on the NOP website for public viewing, with the exception of Confidential Business Information.

  • NOSB sub-committee determines if additional information is needed. If the sub-committee finds the petition insufficient, NOP will contact the petitioner to obtain additional information. If the petition is deemed sufficient, the sub-committee may request a technical report. These reports are done by a third-party contractor and posted on the NOP website. 

  • NOSB sub-committee reviews petition and publishes a proposal with request for public comments. While reviewing substances, the NOSB uses these criteria (pdf). The NOSB sub-committee’s proposal outlines their reasoning and proposed response to the petition. The proposal will include background information, discussion, and the sub-committee’s votes to: (1) Classify the substance (2) Crops and livestock: synthetic or non-synthetic (3) Handling: agricultural or non-agricultural (4) Add, remove, or amend the listing of the petitioned substance.

  • NOP publishes the public meeting agenda and solicits public comments on NOSB’s behalf.

  • NOSB analyzes comments & votes on petition. The NOSB sub-committee makes necessary edits based on written and in-person public comments and presents the amended proposal to the full NOSB. The full NOSB discusses and votes on the petition in a public forum.

  • NOSB submits final recommendation to NOP. After the meeting, the NOSB finalizes its recommendation to reflect the final vote and submits it to the NOP.

  • NOP reviews recommendation and initiates rulemaking, if appropriate. The NOP reviews all NOSB recommendations and publishes its response on the NOP website. The NOP may decide not to add a recommended substance to the National List, but may not add a substance without the NOSB’s recommendation. Learn about the rulemaking process >

*If the substance you wish to petition is an inert ingredient for use in a pesticide formulation, please also review this memo.


Please contact the National List Manager

202-720-3252 |