Late Breaking—Tell USDA To Ensure that Certified Organic Fungi and Pet Food Are Truly Organic

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USDA is proposing new regulations for organic certification of mushrooms and pet food. While the proposals are needed and long overdue, there are problems that need correcting: (i) re. mushrooms—more closely follow the 2001 recommendation of the National Organic Standards Board (NOSB), as well as current biological knowledge and the organic marketplace; and, (ii) re. pet food—conform to organic livestock standards, but do not allow the synthetic amino acid taurine for which there are natural sources.

>>Tell USDA to ensure that certified organic fungi and pet food are truly organic.

Mushrooms: Mushrooms are fungi, a separate biological kingdom from plants and animals. Whereas plants make their own energy through photosynthesis and over 95% of their bodies are comprised carbon, oxygen, and hydrogen gained from carbon dioxide and water (with less than 5% comprised of nutrients gleaned from soil), fungi are comprised entirely of digested substrate. In this sense, fungi are more similar to animals than plants. Obviously, they are a poor fit for the livestock standards, which require outdoor access and attention to animal welfare. But because of their unique biology and heterotrophic nature, they are a poor fit for the crop standards as well. Fungi deserve, and need, their own scope of certification which recognizes their unique biology and can foster consistency in their cultivation and certification.

Additionally, there are already some organic fungal products in the marketplace that are not mushrooms, such as drink powders made from lion's mane mycelium as well as the fruiting body and mycelium extract dietary supplements. Yeasts produced for direct consumption (such as nutritional yeast) are currently overseen as organic handling but would fit better under a separate fungi scope. Framing new production standards to include only mushrooms would unnecessarily exclude these products from certification (or leave them without consistent production standards) and make it harder for future innovative products to become certified. Conversely, framing new production standards to include all fungi would not only provide a better fit for current organic fungal products, but provide ample room for additional markets to develop.

In 2001, the NOSB recommended that organic mushrooms must be grown on organic substrate. Since fungi are composed of digested substrate, only mushrooms grown on organic substrate—manure derived from organic sources or untreated wood that is grown without prohibited substances—can validly claim the organic seal.

Pet Food: While Beyond Pesticides supports bringing organic pet food production into conformance with livestock standards, when incorporating meat into its products, it disagrees with the NOSB recommendation and USDA's proposal to allow the use of synthetic taurine for all pet food. The allowance of any synthetic material to be added to pet food must be based on a recommendation from the NOSB that, in accordance with the Organic Foods Production Act, specifies the species that will be consuming the food. While the science is clear that carnivorous pets, especially cats, require taurine, the question is whether there is a natural source. Since natural taurine is already being marketed commercially by a manufacturer, it is difficult to argue that it is not available in its natural form. As Nature's Logic® states on its website:

Since our foods are made from high levels of animal protein, all Nature's Logic diets naturally contain sufficient levels of the Omega-3 fatty acids, eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA). They also exceed AAFCO*'s protein amino acid requirements for arginine, histidine, isoleucine leucine, lysine, methionine-cystine, methionine, phenylalanine-tyrosine, phylalanine, taurine, threonine, tryptophan, and valine.

Therefore, Beyond Pesticides is urging USDA to reject the recommendation to add taurine to the National List for pet food. Note that synthetic taurine has been petitioned and rejected for allowance in baby formula.

>>Tell USDA to ensure that certified organic fungi and pet food are truly organic.

The target for this Action is the U.S. Department of Agriculture, with public comments via Regulations.gov.

Thank you for your active participation and engagement!

Proposed comment to the USDA:

USDA’s proposed regulations for organic certification of mushrooms and pet food are needed and long overdue, but there are problems that need correcting: (i) re. mushrooms—more closely follow the 2001 recommendation of the National Organic Standards Board (NOSB), as well as current biological knowledge and the organic marketplace; and, (ii) re. pet food—conform to organic livestock standards, but do not allow the synthetic amino acid taurine for which there are natural sources.

Mushrooms. Mushrooms are fungi, a separate biological kingdom from plants and animals. Whereas plants make their own energy through photosynthesis and over 95% of their bodies are comprised of carbon, oxygen, and hydrogen gained from carbon dioxide and water (with less than 5% comprised of nutrients gleaned from soil), fungi are comprised entirely of digested substrate. In this sense, fungi are more similar to animals than plants. Obviously, they are a poor fit for the livestock standards, which require outdoor access and attention to animal welfare. But because of their unique biology and heterotrophic nature, they are a poor fit for the crop standards. They require their own scope of standards, recognizing their unique biology, which fosters consistency in their cultivation and certification.

There are already organic fungal products in the marketplace that are not mushrooms, but made from mycelium, such as drink powders and dietary supplements. Yeasts produced for direct consumption (such as nutritional yeast) are currently overseen as organic handling, but would fit better under a separate fungi scope. New production standards including only mushrooms would unnecessarily exclude these products from certification (or leave them without consistent production standards) and make it harder for innovative products to become certified. Framing new production standards to include all fungi would not only provide a better fit for current organic fungal products, but provide ample room for additional markets to develop.

Please modify the proposed mushroom standard to: 1) give fungi—not mushrooms—a separate scope; 2) cover all fungi forms; and 3) require that certified organic fungi be grown on organic substrate.

Pet Food: The pet food rule attempts to bring pet food production and materials standards in line with organic standards. It also adds an allowed synthetic amino acid, taurine, to the National List of Allowed and Prohibited Substances. Some pet food manufacturers maintain that the amino acid is necessary to fulfill a macronutrient requirement for cats and dogs.

I support bringing organic pet food production into conformance with organic standards and incorporating meat into its products. However, I disagree with USDA’s proposal to allow the use of synthetic taurine for all pet food. The allowance of any synthetic material to be added to pet food must be based on a recommendation from the NOSB that, in accordance with the Organic Foods Production Act, specifies the species that will be consuming the food. While the science is clear that carnivorous pets, especially cats, require taurine, the question is whether there is a natural source. Since natural taurine is already being marketed commercially by at least one manufacturer—Nature’s Logic®—it is difficult to argue that the substance is not available in its natural form. The original recommendation to add taurine for pet food was made in 2008, and it should be revisited by the NOSB before adding it into the regulations.

I urge USDA to reject the recommendation to add taurine to the National List for pet food.

Thank you.