From Flock to Fashion

Since the inception of the Organic Foods Production Act, certified organic wool must originate from a sheep that was managed organically from its last third of gestation, and never received treatments of antibiotics or synthetic parasiticides throughout its entire life. However, the regulatory requirement for parasiticides recently underwent a seemingly minor yet significant adjustment to accommodate sick animals in emergency treatment situations.

Barriers to marketing organic wool

Commercial wool is shorn typically from breeding ewes in the spring as they lamb and the weather warms. When emergencies arise, ewes occasionally must be treated for parasites, although these treatments typically occur at least six months prior to shearing. Until recently, when a ewe was treated with a synthetic parasiticide, it was ineligible for organic slaughter, and its wool also became ineligible for organic labeling. When the wool from some ewes in a flock is eligible for organic labeling and the wool from others is not, the ability for a producer to fill orders and guarantee supply to organic customers becomes very challenging.

Without a guaranteed premium for organic wool, the costs of converting a flock to organic production become less and less attractive, if not impossible. Despite a growing market and strong premiums for organic lamb, the prohibition on using parasiticides, even in an emergency, created a major risk and production challenge for wool-bearing animals and farmers. Accordingly, producers were not transitioning their flocks to organic production.

Responsible use of effective tools

When preventive health care practices are ineffective to control parasites, organic shepherds must respond to infested and sick animals with necessary treatments, as the organic regulations prohibit withholding treatments to maintain organic status. So, if a shepherd must treat a sick animal with a synthetic parasiticide, they face a dilemma: sell that animal and lose desirable genetics, or keep that animal and figure out what to do with non-organic wool. It is not uncommon for organic sheep producers to have wool piling up in the barn that cannot be sold or labeled as organic!

To respond to this situation, the National Organic Standards Board (NOSB) in the spring of 2016 passed a recommendation to allow the use of two specified parasiticides on organic fiber-bearing animals, provided an adequate number of days elapse between treatment and shearing to not impact organic integrity of the fiber products. NOSB maintained this will ensure organic fleece and wool will be free of any treatment residue and still meet consumers’ expectations. This, in turn, would allow producers to maintain the health of their flock and access the organic premium for their wool.

On December 27, 2018, following a proposed rule and another round of public comments, the National Organic Program (NOP) published a final rule amending USDA’s organic regulations. The final rule allows the use of Fenbendazole and Moxidectin (parasiticides) for fiber-bearing animals when used a minimum of 36 days (Based on data from the Food Animal Residue Avoidance Databank) prior to harvesting the fleece or wool. Consistent with the general requirements of the organic regulations, these parasiticides may only be allowed in emergency treatment when organic system plan-approved preventive management does not prevent infestation. The final rule became effective on January 28, aligning with international organic production standards for fiber bearing animals.


The market for organic textiles continues to be the largest and fastest-growing non-food organic category in the U.S., reaching $1.6 billion in sales in 2017. NOP’s final rule to allow restricted parasiticide use on organic fiber-bearing animals is timely given the growing demand for organic fiber and finished textile products certified to the Global Organic Textile Standard (GOTS).

GOTS is a stringent voluntary international standard that enables consumers to purchase processed textiles that are third-party certified organic from field (or flock) to finished product. GOTS was formed in the early 2000s by the Organic Trade Association (OTA), The Soil Association (UK), International Association Natural Textile Industry (IVN) (Germany), and the Japan Organic Cotton Association to harmonize various regional and country standards and develop one global standard.

While USDA’s NOP regulations cover the production of raw agricultural commodities such as cotton and wool, the regulations do not include specific processing standards for finished textile products, such as t-shirts or mattresses. GOTS addresses the entire post-harvest processing (including spinning, knitting, weaving, dyeing and manufacturing) of apparel and textile products made with organic fiber. The standard is similar to that of the NOP regulations only it is specific to textile processing, and includes additional environmental criteria and a social component that evaluates fair labor practices.

As of January, there were approximately 5,024 GOTS-certified facilities in 62 countries, including 99 in the United States. With NOP’s official recognition of GOTS in 2011, the label is increasingly becoming recognized and trusted by shoppers in the United States.

With NOP’s final rule to allow the restricted use of parasiticides in emergencies only on organic fiber-bearing animals, American sheep producers are positioned to respond to textile manufacturers’ clamor for more organic fiber in response to growing demand for GOTS-certified textiles. //

Gwendolyn Wyard is Vice President of Regulatory and Technical Affairs for the Organic Trade Association.