An Exchange on Organic Fiber Standards

Dear Editor:

There are several statements in the article "Organics: Report from the Lone Star State" published in the July-August 2003 issue of Cooperative Grocer that are erroneous or need clarification.

First, the author claims that only members of the Organic Trade Association (OTA) can obtain information or comment on the organic fiber processing standards being developed by OTA's Fiber Council. This statement is not true. Throughout the lengthy development of these standards OTA has publicized and posted various drafts of this document on OTA's public web site (www.ota.com). In fact, the final draft that has emerged from this public process is currently posted at www.ota.com/standards/newstandards.html, along with a link for submitting comments (www.ota.com/standards/aos/rcform.html). Thus, it is available for everyone and anyone to read and comment on. OTA encourages anyone interested to read over the document, and submit any comments in time for the August 4, 2003, submission deadline.

Secondly, the author voices outrage that the final proposal would allow fiber products to be marketed as organic without any oversight for 18 months after an industry member signs a statement of conformity. An 18-month compliance period is not unreasonable. For example, in publishing the December 2000 final rule governing production and handling standards for organic food products, USDA's National Organic Program (NOP) set an 18-month implementation period, thus allowing organic food producers and processors 18 months to comply to the national standards. In fact, due to an administrative snafu, the actual implementation occurred on October 21, 2002-20 months after the final rule was published.

Thirdly, the author claims that in order for any product to legally be labeled organic on the front panel, it must contain at least 95% organic ingredients, excluding salt and water. In fact, under NOP, the 95% rule is for use of the USDA Organic seal on food products. Food products containing at least 70% organic ingredients can use the term "made with organic ingredients" on the front panel. The NOP rule does not yet cover the organic label for nonfood products, although it does cover organic ingredients that may be contained in nonfood products. It is for that very reason that the Organic Trade Association is working diligently to clarify industry guidelines governing nonfood organic products, for future submission and consideration by USDA's National Organic Program. OTA believes in an open, democratic process and is striving to develop organic standards for other sectors beyond foods. Doing so takes careful deliberation and time. Your readers are welcome to be part of the process.

-Katherine DiMatteo

Executive Director, Organic Trade Association

In response:

Dear Katherine,

Thank you for the clarifications. I do still have concerns about the OTA Fiber Standards and am happy for the opportunity to discuss this. It is an issue that needs everyone's attention. Various drafts of the fiber standards have been posted on the OTA site. However the draft that was seen in Texas had changed by the time the session was held. The draft that was voted on by Quality Advisory Council (immediately after the session) had changed yet again. Attendees of that session were confused and frustrated by their inability to view the actual draft language. There was little time given to questions and answers and lack of explanation of many issues.

I did not mean to disregard the "made with" label. However for a product to be labeled as "organic ______" the product MUST be 95% organic. According to the NOP:

"Organic Products labeled or represented as "organic" must contain, by weight (excluding water and salt), at least 95% organically produced raw or processed agricultural product."

This was the type of label I was referring to in my article.

The Preamble of the National Organic Rule tells us that organic fiber products may only be labeled as "made with":

"Nonedible Fibers Products in the NOP. Some commenters asked the NOP to clarify the certification status of fibers such as cotton and flax. The final rule allows for certification of organically produced fibers such as cotton and flax. However, the processing of these fibers is not covered by the final rule. Therefore, goods that utilize organic fibers in their manufacture may only be labeled as a "made with..." product; e.g., a cotton shirt labeled "made with organic cotton."

Many people do not agree with OTA's opinion that an 18-month compliance period is reasonable for allowing fiber products to be marketed as organic. It is true that the NOP took a very long time to be implemented, but it is also true that before implementation so-called "organic" products entered the stream of commerce yet did not come close to meeting NOP standards. Once this happens it is very difficult to assure consumers of the organic integrity of products. Without oversight there is easy fraud.

As a member of the Organic Trade Association, I applaud the OTA work in attempting to clarify industry guidelines governing organic nonfood products, and I appreciate their recent request for public comment regarding this issue. It seems clear, however, that there is work to be done in increasing consumer awareness of the process as well as understanding of the NOP's position on "organic" non-food products. This author is guilty of standing up for high quality, consistent organic standards. Sometimes that means I have concerns over moving product too quickly into the "organic" market without a system of control. It was most impressive to see so many retailers, who are not required to be certified under the regulation, voluntarily get their certification. I hope that the cotton industry will mirror their level of commitment to consumers.

-Cissy Bowman