The National Organic Program (NOP) is a USDA program. USDA determines all matters of policy concerning the eligibility of inert ingredients for use in the NOP. EPA’s role is to assist USDA by assuring that USDA’s policies are implemented with regard to organic claims made by registered pesticide products.

• USDA policy regarding inert ingredients and List 4 is summarized in the following USDA document: Instructions to Certifiers for Use of EPA List 4 Inert Ingredients
• If an applicant has questions with regard to the policy outlined in the above link, or wishes to petition USDA for the addition of another Inert Ingredient, EPA refers the applicant to USDA's NOP office. Find USDA program and contact for the National Organic Program
• Applicants who intend to make organic claims for pesticides with postharvest uses should be aware that USDA considers those uses to be subject to their Organic Processing standards, not their Organic Production standards. Accordingly, any inert ingredient intended for postharvest use must be explicitly allowed per the Organic Processing standards, which can be found in 7 CFR Parts 205.605 -205.606. Applicants also should be aware that List 4 is not applicable to postharvest uses and the Organic Processing standards.

USDA requires that any applicants seeking organic designation must assure that their inert ingredients can be found on this posted List 4, dated August 2004. No other inert ingredients (i.e., reassessed inert ingredients) will be considered for organic designation at this time. (Ingredients approved by 7 CFR part 205 excepted.)

For food uses, NOP applicants should cross-check their inert ingredients against the electronic Code of Federal Regulations (e-CFR) (40 CFR Part 180) to assure that their proposed uses remain covered by an appropriate tolerance exemption. View the e-CFR.  (Select Title 40, Volume 23 (parts 150-189), and then part 180. The majority of inert ingredient tolerance exemptions are found in 180.910 – 160.)

NOP applicants are responsible for providing sufficient information on their inert ingredients for EPA to make an NOP determination. Simply noting an ingredient as List 4 is often not sufficient. The NOP has many additional requirements for ingredients, which are intended to assure organic character of the formulation. EPA suggests applicants submit Manufacturing Process data for their product and technical data sheets and MSDS for their inert ingredients.

NOP applicants using proprietary blends in their formulations should check with their suppliers to assure that all the constituent ingredients in their blend can be found on this posted List 4, dated August 2004. The owner of the propriety blend must submit to EPA a complete description of the blend’s composition (trade name, chemical names, CAS Reg. Numbers, and amount of each component, the total of which must equal 100%).

EPA’s National Organic Program Contact Information:

Chris Pfeifer
Organic Labeling Liaison
Biopesticides and Pollution Prevention Division, EPA
(703) 308-0031
Email: pfeifer.chris@epa.gov

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