Is Biodegradable Mulch Allowed in Certified Organic?

What the National List actually says

The rules for organic crop production in the United States are set by the USDA National Organic Program (NOP) and codified in the National List of allowed and prohibited substances. Biodegradable biobased mulch film appears there explicitly: it was added to 7 CFR §205.601(b)(2)(iii), effective October 30, 2014, as a synthetic substance allowed for use in organic crop production.^[1]

The listing comes with conditions. To count as biodegradable biobased mulch film, a product must meet a recognized compostability standard — ASTM D6400, ASTM D6868, EN 13432, EN 14995, or ISO 17088 — demonstrate at least 90% biodegradation in soil within two years, and be biobased, with biobased content measured by ASTM D6866.^[1] On paper, that reads like a green light for organic growers. In practice, one requirement closes the door.

Why it's “allowed but not usable”

When the NOP clarified the listing, it confirmed that all of the polymer feedstocks used to make the film must be biobased — there is no allowance for petroleum-derived resin content. That is the catch. As the Organic Materials Review Institute (OMRI) reported back in 2015, the biodegradable mulch films on the market contain petrochemical feedstocks and are typically less than 50% biobased — nowhere near the 100% the rule demands.^[1]

Nothing has changed that arithmetic since. The USDA’s own words are blunt: although biobased mulch film is technically allowed as a synthetic in organic crop production, “there are no known products that meet the current requirements for 100% biobased content,” which makes it “allowed, but not actually useable.”^[1] This is the nuance most explainers get wrong in both directions — it is neither freely usable nor flatly banned.

The one mulch that does qualify: recycled paper

There is a plastic-free mulch organic growers can use today. The same National List section that covers biodegradable film also allows “newspaper or other recycled paper, without glossy or colored inks” as a mulch — listed at 7 CFR §205.601(b)(2)(i).^[1] Paper mulch breaks down in the field and sidesteps the biobased-content problem entirely, which is why it remains the practical organic-compatible choice while biodegradable plastic films wait for the chemistry to catch up to the rule.

Where the rules are heading

The standard could still move. In 2021 the National Organic Standards Board (NOSB) recommended lowering the biobased-content requirement from 100% to 80% — a threshold today’s products could plausibly reach. But in a September 2023 memo, the NOP declined to implement that recommendation, reasoning that even an 80% bar would not give growers additional usable options, and asked the Board to keep working on the topic.^[1]

The takeaway for planning purposes: as of mid-2026 the status is unchanged — 100% biobased, no qualifying products — and it is an active, dated regulatory question rather than a settled one. If you rely on this for certification decisions, confirm the current National List language before you buy.

What this means for your farm

If you farm certified organic, biodegradable plastic mulch — including būmigro — cannot go on your certified-organic acres under today’s rules, and you should not represent it as organic-approved. What it offers is a different, real benefit: it is independently certified compostable (a separate standard from organic), and it is designed to be tilled into the soil instead of pulled and landfilled. See our compostability certifications for what that actually proves.

For conventional and transitioning operations not bound by the organic rule, the calculation is the cost and labor of removal versus the roll price — which is exactly what the biodegradable vs. plastic comparison and the true cost of plastic mulch removal break down. New to the topic? Start with the complete guide.

Frequently asked questions