Seed Treatments

How does OMRI review seed treatments, and how should OMRI Listed® seed treatments be labeled?

By Tina Jensen Augustine

The National Organic Program (NOP) has established standards for the seeds and planting stock used in organic crop production at §205.204. These regulations state that:

• A producer must use organically grown seeds, except when an organically produced seed variety or equivalent is not commercially available. This exception does not apply to seeds used to grow edible sprouts.
• If organic seed is not commercially available, a producer may instead use untreated seeds.
• If an organic or untreated seed variety or equivalent is also not commercially available, then a producer may use non-organically produced seed that has been treated with a nonsynthetic substance, or a synthetic substance permitted on the National List.

When it comes to organic certification, seeds follow rules that are similar to crops. According to §205.105 of the NOP regulations, seeds and crops must both be produced and handled without the use of synthetic substances, except for those appearing on §205.601, and without the use of excluded methods (certain types of genetic engineering), sewage sludge or ionizing radiation. 

A variety of materials may be used as seed treatments for different purposes. Examples include:

• peracetic acid, hydrogen peroxide, or chlorine materials for sanitation and fungal disease control;
• natural clays for pelleting (for easier handling); and
• beneficial microorganisms to promote seedling growth.

Seed may be sold as treated or untreated (whether certified organic or uncertified), and seed treatments can be pre-applied to seeds, or sold as stand-alone products intended for use on seed.

OMRI reviews input materials that are seed treatments; however, we do not review or list treated seeds. This is because OMRI is not an organic certifier. In a very real sense, seeds are baby plants—a young version of the crop itself, subject to the oversight of a certifier—and not a material input for OMRI to review. It is therefore important for product labels and other marketing information (including bulk sales invoices) that OMRI reviews to clearly distinguish between seed treatments (to be applied to seed later) and treated seed.

When the label of a seed treatment product does not make a clear distinction between the seed treatment and seed, or refers directly to seed, farmers and certifiers may be confused as to the product’s identity, purpose and certification status. A farmer or certifier may believe that we have reviewed the seed as well as the seed treatment. For this reason, a seed treatment product whose label alludes to “treated seed,” “coated seed” or just “seed” in a way that suggests the seed is part of the product is considered out-of-scope for OMRI review. OMRI therefore encourages manufacturers and suppliers of seed treatments to make clear in their labeling and marketing materials that their product is for use on seed, and does not include or come already applied to seed. Similarly, seeds that have been treated with an OMRI Listed product may not display the OMRI seal on the seed tag or label, nor claim to contain OMRI Listed ingredients. OMRI considers these actions misleading and a breach of OMRI policy, as they suggest that OMRI has reviewed or even certified the seed. Seeds, again, are subject to organic certification by an Accredited Certifying Agent.   

This article was originally published in the spring 2024 edition of the OMRI Materials Review newsletter.