Despite concerns that the spring 2026 National Organic Standards Board (NOSB) meeting could be cancelled, it took place in Omaha, Nebraska – albeit later in the year than is usual. (The fall 2025 meeting was delayed even longer and was held in January 2026.)
NOSB meetings are announced in the Federal Register, where federal agencies publish proposed and final changes to rules and regulations. When the meeting is announced, the public is invited to submit comments for consideration by the NOSB.
Ordinarily, the NOSB has about six weeks to read public comments before their meeting. However, the spring meeting was announced barely a month in advance and written comments were due very shortly before the NOSB met in person. While oral comments were taken as usual, these comments always represent a small portion of the public input each NOSB meeting. National Organic Program staff were tapped to gather and share the written public comments with the NOSB, although it’s unlikely the NOSB had time to truly consider public input from written comments submitted by the deadline.
[Read Cornucopia’s written comments here.]
[Read Cornucopia’s oral comments here.]
Missing NOSB Members
[NOTE: The National Organic Standards Board (NOSB) is a Federal Advisory Board made up of 15 public volunteers from across the organic community. Established by the Organic Foods Production Act (OFPA) and governed by the Federal Advisory Committee Act (FACA), the NOSB considers and makes recommendations on a wide range of issues involving the production, handling, and processing of organic products. The NOSB also has special responsibilities related to the National List of Allowed and Prohibited Substances. Typically, meetings with the full 15-member Board happen in spring and fall – every six months.]
The NOSB continues to be short five board members, meaning 10 people are currently doing the work of 15. While the Board can continue to operate with 10 members (the Organic Foods Production Act says that a majority of board members does constitute a quorum), this situation is far from ideal.
The NOSB is intended to represent the entire organic marketplace. The Board is currently lacking representation from individuals who own or operate an organic farming operation or employees of such individuals (two of four seats unfilled), individuals who represent public interest or consumer interest groups (two of three seats unfilled), and one certifying agent (this is the only certifier seat). The last call for nominations closed September 9, 2025. The final step in appointing NOSB members is political, meaning it is essentially out of the hands of National Organic Program staff. Appointments are cleared through political appointees at the USDA and the White House.
The process itself is not public, and Cornucopia has often submitted a Freedom of Information Act (FOIA) request to learn who is on the slate of nominees. We received this list in response to our FOIA request in April 2026.
[NOTE: FOIA requests in the organic food system are an important tool! It’s important to understand that this type of transparency is rarely available in the conventional food system.]
Although the number of NOSB members is concerning, the five new Board members added in January 2025 were engaged and eager to participate in the public process. This has not always been the case, and it appears that the NOSB onboarding process has improved over time.
You can view the list of current NOSB members to learn more about their backgrounds. The organic handler/processor seats are held by employees of Danone (Dannon in the US) and Taylor Farms. The two farmer-members currently on the board run community-scale farms, and Cornucopia is hopeful that their much-needed voices will inform NOSB discussions. Community-scale farmers experience some of the highest barriers to volunteering their time on the board – it is deeply time-consuming to be an NOSB member, and these farmers typically have no one to replace their work on-farm while they attend meetings, research issues, and learn about the substances they will review in the National List.
Rulemaking Report
Dr. Tucker updated the NOSB and the public about the status of the Market Development for Mushrooms and Pet Food. On May 12, 2025, the USDA proposed rescinding the recently finalized Market Development Rule for organic pet food and mushrooms—without industry input and without consultation with the NOSB. This rescission would undermine the transparency and collaborative process that the organic community relies on to develop clear, consistent standards. Many public commentors wrote in to express support for the rulemaking and objections to its demise.
Dr. Tucker noted that the NOP synthesized the public comments into a report for the administration and that there has been no action on the rule since (including no movement to rescind the rulemaking). This means the final rule that was published in December currently stands, and organic operations must comply with its requirements by March 22, 2027, pending further feedback from the administration. [To follow updates on this rulemaking, follow the AMS page.]
The NOP has also received approval to draft a proposed rule for inert substances and a sunset renewal notice.
NOTE: Each allowed substance in the National List of Allowed and Prohibited Substances is discussed by the NOSB every five years, and their vote advises the National Organic Program on whether to keep each individual substance on the list. The “Sunset Renewal Notice” is a routine rulemaking announced in the Federal Register for public comment, usually annually, to address to rolling sunset of substances listed on the National List.
NOP Enforcement Report
Dr. Tucker reported that enforcement efforts continue to ramp up. She said that the Strengthening Organic Enforcement (SOE) rulemaking gave the NOP tools to detect some organic fraud immediately – especially with respect to import fraud. In some cases, they have caught organic fraud before illegal products enter the market – a win for eaters and organic integrity.
Cornucopia notes that organic grain and soybean prices are climbing this summer, suggesting some headway is being made. However, high prices have historically inspired global fraudsters to become creative in eluding the law. We will keep an eye on this as it develops further.
The NOP needs resources to continue their enforcement work.
Common Organic Systems Plan (OSP)
An Organic System Plan (OSP) is the blueprint for organic certification for a farm or business. It is a comprehensive, living document that details every single practice, input, and procedure that the farm or business uses to protect the integrity of our organic food.
As it stands, each certifier collects this detailed information about every certified operation as required by regulations, but the forms themselves vary from certifier to certifier. Since the beginning of the organic program, many have requested some kind of standardized form.
At the NOSB meeting, Dr. Tucker announced that a Common OSP was nearing completion. [NOTE: As of the posting of this recap from Cornucopia, Common OSP templates are available in different formats on the AMS website.]
The NOP cannot legally mandate a Common OSP that all certifiers must follow, but Dr. Tucker did note that they hope more widespread adoption of the Common OSP would help detect concerns and inconsistencies in certification when entities switch certifiers. Unfortunately, particularly in the international market, when a bad actor knows they have been caught in fraud, they often surrender their organic certificate and then seek certification with another certifier. If using a Common OSP, inconsistencies would be easier to find and more quickly noticed.
A Common OSP, if widely used by certifiers, would standardize the data collected across certified operations, making it easier to identify fraud in the market as well. It would establish a shared baseline structure for documenting organic practices in alignment with USDA National Organic Program (NOP) regulations.
It would also make it possible for independent inspectors to work for any certifier using the Common OSP – right now, inspectors must be trained in the OSP documentation used at each individual certifier they contract with. With inspectors still in short supply, this is important.
The NOP is working with the American Certification Association (ACA) on a governance strategy that would keep templates up to date. The NOP also noted that they plan to tackle the issue of a Common Inspection Form next.
NOSB Discussions and Updates
Integrating Livestock and Agroforestry and Consistency in Organic Seed Use
During the public comment period, the NOSB received many comments from producers about how current food safety rules conflict with some of the best practices for livestock grazing. These rules lack common sense and are preventing some otherwise stellar producers from becoming certified organic.
Agroforestry is the intentional integration of trees and shrubs into crop and animal farming systems to create environmental, economic, and social benefits. There is a lack of clarity in food safety rules around what constitutes a “manure application.” Proponents of farms with integrated livestock argue that manure application was never meant to include natural deposits from grazing animals, but rather intentional application of concentrated manure. The current rule for organic producers also does not take into account the differences in crop type or how a crop is harvested.
Specifically, producers implementing agroforestry and silvopasture practices (livestock grazing among woody plants and/or trees) have limits in how they can harvest products from those trees, including long windows of times when livestock have to be removed from the forest.
For instance, allowing animals to graze in an orchard where fruit is picked off trees is unlikely to cause pathogen contamination in food.
Ultimately, agroforestry proponents asked that the rules be changed to provide more site-specific flexibility within the context of an operation-wide food safety plan. In general, comments from the NOSB seemed supportive of addressing this challenge in some form.
Sunset Reviews – Carrageenan
Carrageenan is once more up for Sunset Review! In 2016 the NOSB voted to remove and de-list carrageenan – a win for the NOSB process after the public campaigned for this exact result. Unfortunately, the NOP then declined to accept the NOSB’s recommendation and it was not removed from the National List.
Cornucopia has fought the allowance of carrageenan in organic food because of its clear danger to human health. Cornucopia’s public comments outline that the science on carrageenan is clear and concerning: it has known human health effects, especially for sensitive individuals. US-Americans are exposed to more carrageenan in their diets than was predicted by previous dietary research. Further, the studies showing carrageenan “safety” were largely conducted by the carrageenan industry with clear conflicts of interest.
The discussion from the Board during this meeting included a summary of the public comments and the new Technical Review which had been requested by the NOSB prior to their review. The new TR did acknowledge there were some health concerns from carrageenan, including unknown digestive fate, toxicology, impurities, metabolic effects, inflammation, and ulceration, especially in the gastrointestinal tract.
The NOSB will vote on whether to keep carrageenan on the National List in fall 2026 – stay tuned for future action alerts from Cornucopia on this topic!
