NOC Comments on Proposed Rule - Mushrooms & Pet Food
The National Organic Coalition is a consensus organization of 14 diverse members, representing different parts of the organic community. As such, all comments submitted by NOC are developed and accepted by all our members.
NOC has submitted substantial feedback to the USDA National Organic Program (NOP) in response to the proposed rule on Organic Market Development. In particular, NOC would like to see the NOP take a different approach regarding the certification of mushrooms.
While NOC supports many of the provisions outlined within the new mushroom rules, we disagree with several aspects around the commercial availability exceptions and the location of mushrooms within the crops practice standard. Due to their unique feeding habits, mushrooms are similar to livestock in that they must be fed organic feedstocks. Due to their unique properties, they should not be forced into either the crops or animal scopes.
Mushrooms, and the mycelia from which they grow, are unique. They are classified in the separate Kingdom of Fungi and are fundamentally different from the plant and animal kingdoms already addressed in the organic regulations under crops and livestock. Fungi should be in their own scope because the practices that would make them organic are distinct from the practices that make plants, livestock, or handling organic.
NOC furthermore suggests that AMS is taking too narrow of an approach in writing a standard only for mushrooms, when in fact this standard could cover the complete Fungi Kingdom. The direct human consumption of fungi, beyond mushrooms, is increasing and is likely to increase in the future.