Current commercial biodegradable mulch films are a key production aid for sustainable organic farming. We understand that this technology has been safely used for many years and has been found to be effective in help managing weeds and conserving water. Additionally, we know that farmers using these types of materials have found the film meets their production requirements and biodegrades in a timely matter.
The rising cost of labor, a shrinking labor force, and limited means of disposing current polyethylene mulch film, will be a decisive factor in an organic farmer’s continued success. We appreciate that biodegradable mulch film was added to the National List in 2014, but regret that subsequent comments in Memo 15-1 have made this tool unavailable for organic farming. We request that the NOSB and the NOP remove the additional requirement which was added to 7 CFR 205.2 by Memo 15-1. This resolution would permit all organic farmers the ability to assess biodegradable mulch film technology to determine whether it is a production aid which meets their specific needs.