Organic Fish

Summer 2006

Organic Fish?

by Eric Sideman, Ph.D.
Copyright 2006

The word organic has become a household word during the 20 years I have worked for MOFGA. When I first took this job, I had to explain to friends and family what organic meant. Now they make a point of showing me the organic items in their refrigerators.

Purchasing organic products brings good feelings to consumers because of their satisfaction in helping family farms, protecting the environment and living up to their own self-image. Hence, the word organic now has great value in the marketplace, and businesses of all kinds want to profit from it.

Those of us who grew up with organic and know its heritage need to protect its meaning and keep it from becoming too vague, like many marketing terms, such as ‘natural’ or ‘green,’ used to make consumers feel good about buying products. Organic farming began with taking care of the soil and is based on management and practices that produce healthful food. If stretched too much, the term will lose all value.

Certification of organic food has changed, too. The Organic Foods Production Act of 1990 (OFPA) is now the statutory foundation for certifying organic agricultural commodities, and it represents quite well what historically has been called organic. The USDA National Organic Program (NOP) has done a commendable job of developing regulations that enforce the OFPA for producing vegetables and livestock. Both OFPA and the NOP standards clearly say that production practices make an item organic–but the Final Rule does not address many items that marketers want to label as organic. One of these is aquatic animals.

In 2000, an Aquatic Animal Task Force began to determine how such production could meet OFPA guidelines. (I served on that Task Force and at that time was a member of the National Organic Standards Board, or NOSB.) In June 2001, the Task Force presented its final report to the NOP and the NOSB.

In 2001, the Task Force concluded that operations that capture wild aquatic animals do not reflect the degree of producer management, continuous oversight and discretionary decision-making that characterize organic systems. Accordingly, the Task Force recommended that the NOSB and NOP not develop organic standards for wild caught fish. On the other hand, the 2001 Task Force recommended that aquaculture systems, which raise aquatic species in captivity, could operate in compliance with the OFPA, if and when specific standards are developed to regulate such production systems.

A new Aquaculture Working Group, created in 2005, presented its Interim Final Report to the NOSB in April 2006. The standards do a fair job of reflecting what organic is, but they stray on a few points. We need to let the NOSB know we are watching and want strict regulation of farming practices to determine what is and what is not organic. Furthermore, some issues discussed in the regulation of aquaculture will have repercussions on wild fishing, which is also seeking organic certification.

I want to stress that the NOP Final Rule is a practice-based regulation, as organic standards were historically in the organic community before the NOP and should continue to be. The use of the organic label on aquatic products should be based on practices implemented by the producer while producing a product, and qualities of the site where production occurs. The OFPA mandates this.

Regulations that describe practices used to produce organic aquatic livestock should meet the mandates in OFPA rather than trying to reinterpret or rewrite OFPA to meet present conventional production practices. The new Aquaculture Working Group has done a good job of recognizing this in its Interim Final Report.

Let’s look at the Aquaculture Working Group Interim Report‘s proposed standards (also posted at

I. Applicability

The first Aquatic Animal Task Force noted that by including “fish used for food” in the definition of livestock, the OFPA requires that any fish used for food that is to be labeled organic must be raised in accordance with NOP standards. Therefore, any producer labeling a fish as organically produced must comply with all applicable requirements and restrictions for livestock production in the OFPA, and the NOSB is responsible for advising the Secretary on standards for producing and handling fish. To clarify the meaning of the term “fish,” the NOP developed the term “aquatic animals” to refer to finfish, shellfish and other aquatic invertebrates used for food, either propagated in a selected, controlled environment (aquaculture) or taken from free ranging marine or fresh water populations (wild capture). So, agreement is widespread that the USDA has the authority to say what is or is not organic fish.

II. Designation of Site

 OFPA clearly mandates that the area in which organic products are produced have defined boundaries. This is important, and the Interim Final Report could state this more clearly. It is important because, for the producer take responsibility for the feed the livestock eat, the living conditions of the animals, the health care provided for the animals and the environmental impact of the production system, that producer must know where the animals are. The producer could not assess the impact of the surrounding environment on the organic status of the livestock, nor the impact of the production system on the surrounding environment, if the production site were not defined.

I suggest that the Interim Final Report be modified so that it mandates that the

Organic Plan for an operation of an aquaculture facility clearly designate the area of operation.

 III. Environmental Impact

The OFPA mandates that an organic production system not be destructive to the environment. The Interim Final Report recognizes this and addresses environmental contamination in a number of sections. However, it often uses the word “minimize” concerning environmental impact; e.g., “minimize the release of nutrients and wastes into the environment.” I hope that all systems, not only organic, minimize such releases and that organic aquaculture systems would be held to the same higher standard as any other organic livestock system regulated by the NOP. For example, instead of “minimize,” the NOP standard says, “The producer of an organic livestock operation must manage manure in a manner that does not contribute to contamination of crops, soil, or water by plant nutrients, heavy metals, or pathogenic organisms and optimizes recycling of nutrients.”

The Interim Final Report requires a nutrient management plan for every organic aquaculture facility. This is very good. Nutrient management has the greatest environmental consequence of the practices involved with aquaculture. The source of nutrients entering the system (feed) and the end point of nutrients leaving the system (uneaten feed, manure, etc.) potentially could have great negative environmental impact. The Report includes practical options for managing nutrients. I stress that practices that recycle nutrients within the system and surrounding environment are key to avoiding impact, both in production and feed procurement sites. National Organic Standards should require documenting nutrient recycling in the Organic Farm Plan.

IV. Origin of Livestock

The Interim Final Report recognizes that organically produced aquatic animals must be raised in a discrete population, similar to a herd of cattle or flock of poultry, that is brought under continuous organic management beginning very early in the animal’s life. It permits collecting slaughter stock from the wild, but only with regulations on age.

In addition, the Report discusses the environmental impact of collecting stock from natural populations, but I do not think the environment is protected enough here. The Report is not as strong as the present Rule for other wildharvested goods and OFPA. The Interim Final Report talks about collecting broodstock from the natural environment and says “that natural populations and the collected individuals are protected and that biodiversity in the ecosystem is supported.” However, I hope that any organic aquatic animal regulations are at least as strong as the NOP Final Rule that says, “A wild crop must be harvested in a manner that ensures that such harvesting or gathering will not be destructive to the environment and will sustain the growth and production of the wild crop.” The phrase “not be destructive” presently in the National Organic Program Rule is much clearer than “biodiversity in the ecosystem is supported,” which the Report suggests.

V. Livestock Feed


The OFPA mandates that producers provide organically produced animals with organically produced feed. I am comfortable with the potential for this to occur in aquaculture systems in designated areas where producers are responsible for what feed they use and for feed that moves into or grows in the area. This is similar to terrestrial livestock that graze in designated areas under producers‘ management.

I also accept the exception in the NOP Final Rule that nonsynthetic substances, and synthetic substances included on the National List, may be fed as feed supplements and feed additives to balance a feed. But clarification is needed as to what is a feed and what is a feed supplement or additive. The OFPA is very clear that feed must be organic, so I strongly believe that the basic feed groups of protein, fat and carbohydrate must come from organic feed. The OFPA does not provide for “natural” sources of feed. So, as I read the OFPA, natural ingredients used as supplements must be limited to balancing specific nutritional needs, but supplements may not be used to provide livestock with a significant portion of protein, fat or carbohydrate, unless they are organic products.

The Interim Final Report is very fuzzy on this issue. It suggests that fishmeal made from wild fish may be permitted as a major component of feed for fish aquaculture. I do not believe that fish meal made from wild fish can be called organic, for two reasons. First, many people are under the misconception that fish meal is a waste product of fish processing and that recycling this waste is good. But only a small amount of fish meal actually comes from waste. Most comes from overfishing natural populations of wild fish, such as herring and anchovy, for the purpose of making fish meal. A huge amount is harvested. Environmental Defense in Murky Waters reports that 27% of the world’s wild fisheries production is now converted to fish meal for animal feeds. Although the poultry and hog industry make feeds that are only a few percent fish meal if any, the aquaculture feed for fish, such as salmon and trout, is 20-70% fish meal. Natural populations of wild fish are very threatened by this practice; it would be a travisty to call an aquaculture product organic when the feed comes from overfishing, with its environmental distruction and ramifications in the food web.

Furthermore, the first Aquaculture Task Force concluded that operations that capture wild aquatic animals do not reflect the degree of producer management, continuous oversight and discretionary decision-making that are characteristic of organic systems, so I don’t think that wild fish or the fishmeal made from them should be called organic. Since the OFPA clearly states that organic livestock must eat organic food, fish from aquaculture based on fishmeal should not be called organic.

What should the fish be eating? This is an interesting question. They could eat fish meal from the waste of processing organic fish. Salmon actually eat salmon in nature, so in captivity they might eat a meal made from waste of organic salmon processing. They could eat organic crop products, although they would then need methionine supplements. Perhaps certain species that cannot be grown without fish meal just cannot be organic.


Fishmeal could be used in limited amounts as a natural supplement to balance amino acids, but the use of wild fishmeal and oil should be limited.

VII. Livestock Living Conditions

I believe that managed aquatic animals should be called organic only if they are raised within a secure, defined production system that accommodates the animals’ health and natural behavior and minimizes the risk of escape. The Report does a good job addressing the regulation that producers must maintain healthy water conditions with respect to temperature, oxygen concentration, pH and toxins, including ammonia and carbon dioxide. The importance of protecting the natural gene pool from escaped livestock species cannot be overemphasized.

Rather than “minimize” environmental impact, as the Report is now written, I believe that the regulation must require that producers maintain production systems, whether self-contained or located in open water, in a manner that does not contaminate water or soil with nutrients, heavy metals or pathogenic organisms. Producers should prioritize recycling of residual nutrients produced by the operation. Production systems located in open water must be sited and managed to avoid the potential for contact with prohibited substances, including environmental pollution.

Organic fish? Maybe, but only if its cultural practices reflect the principles of organic production. Let’s work hard to protect the meaning and value of the word we made popular. The Aquaculture Working Group just submitted its report, from which the NOSB will develop standards. People’s comment to the NOSB about the report will be considered as the NOSB develops recommended standards ([email protected]). After the NOSB submits recommendations, the NOP will use those to develop a Rule change that will be published in the Federal Register; this will provide another opportunity for comment.

 Eric is MOFGA’s director of technical services. You can address your questions about farm and garden crops and practices to him at [email protected] or 568-4142.



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