NOSB Wants to Approve Paper Pots but Cannot Find Suitable Rule-Making Language

The Fall 2020 National Organic Standards Board has come and gone and while it appears that some progress was made, the Board voted to send the issue of paper pots back to subcommittee. Based on the discussion, it appears that there is near universal desire to eventually approve paper based planting aids for use on organic farms (including paper pots)…but the exact wording of a proposed rule has, once again, proven elusive. The rub is that the committee needs to write a rule that is general enough to permit things like paper pots, while not opening the door to things the committee does not want to see used on organic farms such as “paper” products that contain too many synthetics or “undesirable” or hazardous synthetics. The subcommittee in charge of this issue attempted to create categories of ingredients and assign acceptable percentages of those types of ingredients but the full NOSB was not satisfied with this approach. There was also concern about the proposed rule allowing 100% virgin paper products with some members of the NOSB requesting that the rule be written to demand or encourage the use of post-consumer recycled paper content. A final concern is how to ensure that paper-based planting aids meet any final rule in terms of verification of ingredients.

Regarding the issue of virgin versus post-consumer paper content, the challenge here is that the cellulose fibers that impart strength and integrity to paper pots are vital and waste-stream recycled papers are not acceptable replacements in the manufacture of functional paper pots, especially paper chain pots. Also, based on the NOSB’s own technical reviews of paper and recycled paper, recycled paper is a waste-stream product so it is, essentially, ‘more synthetic’ and more likely to contain various synthetics including inks, dye, toners, coatings, etc. than virgin paper sources. Also, while recycling materials is a very good thing in general, collecting, hauling, processing, and reformulating paper into recycled paper products is a very energy and chemical intensive process. It is an open question whether there would be a net environmental gain from making paper pots from recycled paper. Paper pot manufacturers in Japan and Denmark have informed the NOSB that they cannot make functional paper pots from recycled paper.

It has been about two-and-a-half years since Small Farm Works submitted our petition to ask the NOSB and NOP to allow paper pots on certified organic farms. It was frustrating to see the NOSB (in the words of one NOSB member) “kick the can down the road” at last week’s meeting but we also recognize the complexity of the issues and respect the NOSB for their careful, deliberative process which, in the final analysis, does help protect the integrity of organic farming. We look forward to the Spring meeting and, hopefully, a vote! In the meantime, we will continue to help the NOSB by answering questions and providing input into the rule-making process. We will also continue to work with our paper pot partners in Japan to offer environmentally responsible paper pot products to help small farms be profitable and enjoyable!