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Additions to the National List of Allowed and Prohibited Substances

by Guest Blogger |

On June 25, 2021, the National Organic Program (NOP) issued a final rule to add three substances to the National List of Allowed and Prohibited Substances (National List): oxalic acid dihydrate, pullulan, and collagen gel. The final rule is effective July 26, 2021, and can be found in the Federal Register.

Oxalic acid dihydrate is added to §205.603 as an allowed synthetic for use as a pesticide in organic apiculture (beekeeping) to control varroa mites. Oxalic acid is a naturally occurring substance, but its addition to §205.603 allows for the use of oxalic acid dihydrate that has been synthesized via chemical processes.

Pullulan and collagen gel are added to §205.605 nonagricultural (non-organic) substances. Pullulan is added to §205.605(a) for use only in tablets and capsules for dietary supplements labeled as being “made with organic” ingredients. Collagen gel is added to §205.605(b) for use as a casing in processed products labeled “organic” or “made with organic” ingredients. Non-organic collagen gel may be used only when organic collagen gel is not commercially available.

If you would like to integrate oxalic acid dihydrate, pullulan, or collagen gel into your organic production, submit a request to For pullulan and collagen gel, provide CCOF with updated H2.0B Product Formulation, H2.7 Commercial Availability, and Nonorganic Processing Material Affidavit forms as applicable.