Don’t Roll Back the Rules: NOC Defends Organic Standards for Pet Food & Mushrooms
A Step Backwards for Organic Rulemaking
The National Organic Coalition (NOC) strongly opposes USDA’s May 12, 2025 proposal to rescind a final rule that would establish clear organic standards for pet food and mushrooms. These long-awaited standards were finalized in December 2024 after years of input from organic businesses and community members. On June 11, 2025, NOC submitted comments to USDA opposing the recession of this rule. 📄 Read our full public comment to USDA here.
This proposed rollback was made without consultation with the National Organic Standards Board (NOSB) or input from the organic community—undermining the transparent, collaborative process that is central to organic rulemaking.
Why These Standards Matter
For decades, organic farmers, certifiers, and businesses have urged USDA to resolve inconsistencies in how mushrooms and pet food are certified. Without clear standards, both sectors have struggled to grow and innovate.
Organic mushrooms: Certification practices vary widely between certifiers, especially regarding substrate and spawn.
Organic pet food: There has been no clear guidance on whether essential animal by-products and vitamins are permitted.
This lack of clarity has discouraged investment, hindered product development, and created confusion for consumers.
What the Final Rule Achieved
The Market Development Rule provided long-overdue regulatory clarity. It:
Required consistent certification practices for mushroom substrate and spawn
Allowed the use of essential nutrients and organic slaughter by-products in organic pet food
Strengthened consumer confidence and provided new income streams for organic producers
These standards were widely supported by producers and would have opened new markets while reinforcing the integrity of the organic label.
The Harm of Rolling It Back
Rescinding this rule will:
Shut down emerging opportunities for organic livestock and mushroom producers
Reduce access to organic pet food, a growing segment of the market
Undermine confidence in USDA’s commitment to stakeholder-informed organic rulemaking
The USDA has provided no new evidence to justify this reversal—only vague claims that it would reduce “paperwork burden.” In reality, it creates uncertainty and market disadvantage for organic producers trying to operate under consistent, transparent standards.
NOC's Call to Action
NOC urges USDA to reinstate the final rule and recommit to the integrity and growth of organic markets. Clear standards are vital for a fair playing field, producer success, and consumer trust.