Injectable Vitamins

What are the NOP standards for injectable vitamins? Does OMRI allow them?

By Amber Lippert

Vitamins are given to livestock orally, in feed, or as an injection. Some injectable vitamins are registered as drugs, while most non-injectable vitamins are used as additives in formulated feeds or diluted and offered free choice. The intended purpose of a vitamin product, such as whether it is meant to be fed daily or only in times of stress, makes a difference when it comes to the organic standards. Vitamins available on the market are generally made using synthetic processes or materials. Injectable vitamins are typically formulated with synthetic inerts (known as excipients when used in medications).

The National Organic Program (NOP) regulations at §205.603(d) permit the use of synthetic vitamins for enrichment or fortification of feed when FDA approved. The regulations make no reference to formulated injectable vitamins. 

A petition to add injectable vitamins to the National List for use in livestock feed was submitted to the NOP in 2009. The National Organic Standards Board (NOSB) recommended allowing injectable trace minerals, vitamins and electrolytes as nutritive supplements, formulated injectable supplements of trace minerals, or as vitamins or electrolytes, with excipients per 205.603 in accordance with FDA, and restricted to use by or on the order of a licensed veterinarian.

The recommendation is awaiting NOP rulemaking action. While OMRI does not typically follow recommendations until they are finalized, we recognize that organic certifiers allow the use of injectable vitamins as either nutritional supplements or as medications. 

OMRI offers a general “Vitamin” category for listing vitamin products for livestock. Recognizing that this is a grey area, OMRI does not have a formal policy on these substances and no applications have been received for such a product. 

A potential review of an injectable vitamin would begin by reviewing the intended use (health care vs feed) of the product as described on the marketing materials. Registered animal drugs are reviewed as livestock health care products by OMRI. Products intended as feed supplements are reviewed as feed products.