By Dr Tim Marshall and Dr Barry Ferrier
Introduction: Organic standards, certification, & the regulatory environment for organic food
The National Standard for Organic and Bio-Dynamic Produce (the National Standard) is the property of the federal Department of Agriculture, Fisheries and Forestry (DAFF). Certification to the National Standard is a requirement for all exports of organic produce from Australia. For more than three decades since the launch of the National Standard in 1992, the Australian organic industry has used it as a ‘reference standard’ and has often claimed that private standards and certified operators are compliant to the National Standard, but it is important to realise that it has no legal authority in the domestic market. The fact that the National Standard is not relevant to the domestic market was acknowledged by Agriculture Minister John Kerin when he established the Organic Produce Advisory Committee to create the standard in 1990, and by Minister Simon Crean when he launched it in 1992.
The AS6000 is operated by Standards Australia, which produced the first version in 2007 and the current updated version 2015. Although there is no mandatory requirement for certification of organic product sold domestically in Australia, the AS6000 is the standard that is most likely to be referenced by the Australian Competition and Consumer Commission (ACCC) or Australian courts. Certification to the AS6000 does not satisfy DAFF requirements for export of organic products.
Until 2026 there were two organic standards owned by private organisations and widely used in Australia but with the collapse of NASAA Certified Organic in 2025, there is now only one privately owned standard, the Australian Certified Organic Standard (ACOS) which is owned and maintained by Australian Organic Ltd (AOL) and used as a certification standard by ACO Certification Ltd. (previously Australian Certified Organic).
There is no specific regulatory system for organic in Australia and the term “organic” can legally appear on products without third-party verification for domestic sale. However, all food produced or imported for sale in Australia and New Zealand, including organic food, must be labelled in accordance with the Food Standards Code developed by Food Standards Australia New Zealand (FSANZ). All organic claims should be true, and false claims can be prosecuted by the ACCC or under state consumer legislation that requires truth in labelling, with reference to The Commonwealth Competition and Consumer Act 2010.
The two authors of this paper both work with the Organic Consumers Association of Australia (OCAA), which is the only organisation specifically representing consumer interests in the complex landscape of organic standards and certification in Australia. OCAA often partners with Organic Operators Australia (OOA) and supports the OOA One Standard Policy (https://organicoperators.au/IndustryStrategy) which aims to replace the export functions of the National Standard with a new and upgraded version of the AS6000 to simplify the system for regulation of organic in Australia and provide additional consumer guarantees. The current system is unclear for most consumers and for many growers and traders who are part of the organic market or who aspire to become organic. The system as described above is already confused by government owned (the National Standard), government recognised (the AS 6000), or private (ACOS) standards and by the frequent use of the term “Australian Certified’ by private organisations. It is further complicated by an array of terms that are used to cover organic fresh produce, processed products, or inputs to organic farming that may be called “certified”, “permitted”, “allowed” or other terms that are not defined in legislation. Where exceptions are made by certification bodies that use private standards, access to update logs are not transparent for consumers and may not be known, understood, or approved by competing producers of similar products. See below for an explanation of derogations (exceptions). Furthermore, private standard owners and certification bodies have made multiple claims that they comply with the National Standard (the export only standard) without making clear that some of their certified clients are excluded from various accreditations directed at export-only compliance and their contract conditions a may not be included in accreditation reports.
Until organic standards, certification, accreditation and inspection in the domestic market is improved according to the OOA One Standard policy, the sector remains impenetrable to most consumers and is not able to ensure the protection of Australian consumers or producers of organic produce and does not have the confidence of consumer organisations such as CHOICE or OCAA, as reported by many organic industry leaders and the observations of researchers or commentators such as Chang et al., 2004; Do, 2015; Samuel et al., 2021 and Marshall 2026.
What is methionine and why does synthetic methionine appear in organic standards
Methionine is an essential amino acid found in a range of natural foods. Synthetic methionine is also one of the few synthetic inputs permitted in the National Organic Standard, where it is allowed by a derogation for feeding to chickens only (no other livestock). Methionine must appear in the diet because poultry can’t synthesize it. Birds require it for feather development, immune function, and efficient feed conversion. Conventional poultry operations add synthetic DL-methionine to grain-based rations but organic certification in most jurisdictions prohibits synthetic amino acids. The USA is an exception and does permit limited application of synthetic methionine, but the practice is controversial and contested. European organic standards allowed a temporary exemption until 2025; that deadline has now passed.
What is a derogation
A derogation is an exemption or relaxation of the standard for a specific use. Derogations should be used only when there is no organic source or practice that can be applied for essential production requirements such as meeting aspects of government food legislation or, in the case of poultry production, it was argued that synthetic methionine was required by organic growers to avoid health problems for the birds that would otherwise not be compliant with animal husbandry specifications in the standard that oblige growers to avoid suffering.
Derogations must be contained within the text of the standard and should not be determined by the certification body or inspector. If issues arise that are not covered by the standard, derogations should only be applied by the standard owner after a thorough consideration including consultation with any interested parties. That is potentially a problem in Australia where many growers are certified to a private standard. The Standard owner or user may decide to introduce a derogation to the private standard, that is not compliant to either the National Standard (used for export) or the AS 6000 (the standard with the most likelihood of being used by government regulators or the courts).
For this reason, OCAA believes that private standards should not be used, and that Australia should transition to a single regulatory standard for both the export and domestic market, according to the OOA One Standard Policy.
What the standards say
The first version of the AS 6000 (2007) was the first Australian organic standard to permit use of synthetic methionine in a ‘sunset clause’ (a temporary permission to allow producers to transition to an organic solution). That provision was transferred into subsequent editions of the National Standard and by about 2010 has been incorporated into the National Association for Sustainable Agriculture Australia Ltd. (NASAA). It does not appear in the private standards operated by Australian Organic Ltd. (AOL) but it is used by certified operators under derogations that are part of contract conditions but are not easily discovered by organic consumers or other certified operators who compete with users of methionine.
The NASAA Organic Standard 2016 contained the following comment under Table 5 – Livestock Diet and Nutrition
DEROGATION
Methionine may only be added to poultry rations where the certification body has given prior agreement. Methionine may not be used on an ongoing basis, approval will be for a defined period.
Methionine may be used as a last resource in cases where the following conditions have occurred:
- Protein content of grain is low due to seasonal conditions during production of grain and
- Pulse variety and/or variety of food natural to poultry diet are not available, and
- Green paddock feed is not available due to prolonged dry conditions
The current version of the National Standard, Edition 3.8 November 2022, contains the following clause:
1.16.7 Prohibited feed products include, but are not limited to the following:
a. antibiotics, coccidiostats, medicinal substances, growth promoters or any other
substance intended to stimulate growth or production.
b. Amino Acid isolates, with the exception of methionine for poultry1.
c. non-protein nitrogen compound (e.g. urea).
d. GMO products or their derivatives.
And the note attached to 1.67.7.b reads “For guidance on the use of methionine, contact your certifying organisation”.
The National Standards Advisory Committee (NSAC) responsible for the National Standard has generally refused to provide public guidance to the standard, preferring to leave this to the certification body. For much of its history, the committee did not even provide guidance to certification bodies. OCAA believes that NSAC or certification body guidance should make clear that the permission for use of synthetic methionine is an emergency provision only, according to the type of conditions mentioned in the NASAA Standard. The preferred position of OCAA is that the derogation for the use of synthetic methionine should be removed.
The ACOS 2019 does not mention methionine. Section 5.1.28. provides for up to 5% of the annual dry matter feed intake to be brought in from non-organic sources where certified organic is unavailable and where products comply with other stipulations in the Standard (non-GM, non-contaminated, etc.). 5.1.29. allows for supplements including minerals and natural vitamins, kelp and plant-based marine products, stone meal, lime, zeolite and some non-GM yeasts and yeast byproducts, natural herbs, and homeopathic remedies. 5.1.30. prohibits use of growth promotants, stimulants, appetisers and solvent-extracted feeds, growth regulators and synthetic substances of any kind, including synthetic nitrogen compounds and urea. An explanatory paragraph to annexes in the standard sates that allowed inputs into the system are generally prohibited if synthetically compounded.
How did the methionine derogation arise
The Standards Australia management committee for the 2007 version of the AS6000 heard conflicting views from organic operators about the necessity for including synthetic methionine as a permitted input. The Biological Farmers of Australia (BFA was the precursor of AOL) and some of their certified poultry producer clients arranged for some of the main international nutrition consultants to the poultry industry to provide written submissions supporting the necessity for methionine supplementation, to avoid health problems that would cause lower production and suffering for the birds. The consultants were mainly engaged with non-organic production and did not have extensive knowledge of or experience with organic producers. The poultry producers that sought to use synthetic methionine were the largest organic producers. Some also raised non-organic poultry and were familiar with dietary supplementation with methionine.
Evidence from the consultants was accepted by a majority of the standards committee members and a sunset clause permitting synthetic methionine was included in the 2007 version of the AS6000.
The practical challenge is real. Corn-soybean diets that are the backbone of modern poultry nutrition are naturally low in methionine relative to birds’ requirements.
The dissenting view
Many of the smaller organic poultry producers raised predominantly grass-fed birds and opposed the use of methionine. They argued that the larger producers raised birds that were housed in large sheds and although they did have ‘access’ to pasture, there was sometimes little incentive for them to wander far from the shed and they were not truly free-range animals.
They claimed they did not need synthetic supplementation, because their birds had access to protein sources including small seeds and legumes with sulphur-containing amino acids and high methionine density, and insects in the pasture. Some smaller organic producers also provided fish meal with 1.5-2.0% methionine by weight; and some kept a small flock of sheep which they used to provide organic meat meal. Other options were available but not much used including insect meals and some seaweed or algae concentrates with high methionine bioavailability.
Andre Leu, a member of the AS6000 standards committee with extensive experience in importing tropical fruit and flower species into Australia for commercial production, obtained the seed of a high-methionine corn variety from America and paid all the quarantine fees at his own expense. Andre distributed the seed to organic growers, but it appears that no one has continued to grow and expand the variety in Australia. The USA breeder has continued to develop commercial cultivars that produce high yields and perform well under organic conditions, without synthetic pesticides, herbicides, fertilizers, or heavy irrigation.
The concept of ‘organic breeds’ and cultivars has not attracted attention in Australia as it has in Europe and was almost unheard of in the Australian organic industry in the 2000 decade. Some organic poultry producers were highly critical of industry reliance upon breeds developed for non-organic production and equated that strategy to purchasing a high-performance sports car and filling it with low octane fuel. ACOS Version 1. (2010) includes the following:
5.2.19. Selection of genetics shall be such as to conform to the principles and aims of organic production. This shall include preference for slower growing species for meat production and species which are able to perform their natural social and physical functions.
Availability of high methionine feed materials
A systematic search for literature on this topic recovered 92 documents. The vast majority are advocacy materials from food sovereignty organizations such as GRAIN (https://grain.org/en/pages/organisation), La Via Campesina (https://viacampesina.org/en/), ETC Group (https://www.etcgroup.org/issues/farmers-rights-food-sovereignty) addressing corporate consolidation in agriculture, synthetic biology concerns, and peasant farming movements. Some documents from the FAO also deal tangentially with protein sources for animal feed. One study from 2017 examined Brazil nut meal and spray-dried egg powder as methionine sources for organic laying hens (https://www.sciencedirect.com/science/article/pii/S0032579119311897).
Knowledge gaps
The gap in research about alternative feed sources for organic production reveals something about how agricultural research priorities are set, what attracts funding, and where the infrastructure of knowledge production directs attention. Organic poultry represents a small market segment. Most research funding flows toward optimizing conventional production systems where synthetic methionine costs pennies per bird and delivers predictable results. The economic incentive to develop alternatives exists only within an organic niche, which remains too small to command proportional research investment.
Sourcing adequate diets and appropriate supplements for organic poultry sits awkwardly between disciplines. It’s too applied for fundamental animal nutrition research, which focuses on metabolic mechanisms rather than ingredient sourcing. It’s too technical for sustainable agriculture studies, which tend toward systems-level analysis rather than nutrient biochemistry. It’s too specific for food sovereignty advocacy, which addresses power relations in agricultural systems rather than amino acid formulation. The alternative protein sources that might solve the problem such as insect meal, algae, and certain oilseed meals lack developed supply chains but could be a good candidate for transdisciplinary research.
Some knowledge may exist in proprietary form, in organic or integrated poultry operations that view formulation as competitive intelligence.
What the best organic producers do or could do
Some organic producers use fish meal, or organic meat meal. Some use higher-methionine plant proteins like sesame or sunflower meals that may require accepting reduced growth rates or egg production. Some rely exclusively on grass/legume pastures and incidental insects that occur in free range pasture.
Some producers use traditional poultry varieties that are better adapted to free range foraging than modern ‘industrial’ varieties that rely on high-density methionine feed.
Algae and seaweed production can provide useful protein while also contributing to carbon dioxide mitigation by photosynthesis. Chlorella can be 48% protein and Spirulina 63.0% protein (include reference) and contribute minerals and other health promoting antioxidants, and phytochemicals.
Insect-based or invertebrate protein is a promising option (van Broekhoven et al., 2015; Sogari et al., 2019; Belhadj Slimen et al., 2023; Sajid et al., 2023). Earthworms, mealworms, crickets, locusts, silkworms, cockroaches and black soldier fly larvae can have 50% protein (over 65% for earthworms and silkworms), minerals, and essential amino acids including methionine (Sogari et al., 2019) with a high digestibility. Insect and invertebrate-based protein sources have good feed conversion efficiency (Belhadj Slimen et al., 2023; Sajid et al., 2023), are compatible with natural insect foraging behaviour of poultry, and can be produced on a substrate that utilises chicken waste with low greenhouse gas emissions and minimum water requirement, in a circular economy. Manure management from poultry farming that might otherwise contribute to greenhouse gas emissions, environmental pollution and noxious odours can be diverted to rearing invertebrate protein sources.
Organic food processing waste and by-products can also contribute dietary fibre, vitamins, minerals, and health promoting phytochemicals.
Research needs
Specific research could be directed towards pasture and small seed mixes such as buckwheat and traditional grains like kamut and amaranth, that have much higher nutritional density than wheat, barley, and oats.
Poultry varieties and organic breeding including appropriate heritage or rare breeds may provide better genetic diversity, adaptability to local climate, and natural disease resistance. Protein digestibility and feed conversion efficiency could be enhanced by genetic selection and with the construction of dietary mixes that utilise natural enzymes.
Research that integrates poultry nutrition biochemistry, alternative protein sources described above, economic analysis of production and supply chains, and farming systems has never been conducted in Australia but requires breaking down academic disciplinary silos. Organic research generally does not yet occur in any core research domain. Solutions to the problem of organic poultry diets require methionine bioavailability studies, comparative feeding trials, and economic analyses before the knowledge gap can close.
What we can learn about how standards are developed
The knowledge gaps described expose tensions in how organic standards evolve. Regulations get written and deadlines like sunset clauses are set that outpace regulatory ambition. Farmers are faced with production rules before research has generated the knowledge to meet the requirements. This sequencing problem creates pressure to weaken standards or may impose compliance costs that operators do not want to meet.
Critical questions are, do we want to retain exemptions for synthetic indefinitely or should we encourage innovation by delivering the environmental and health benefits that true organic production delivers? Are we prepared to see some producers exit the sector to preserve the organic guarantee that standards and certification promise? Will consumers accept higher costs and will producers accept lower productivity in favour of adhering to organic principles?
Is the organic sector prepared to accept that without support for organic research, future organic poultry meat and egg production may be limited to small local production units.
The optimistic answer is that organic poultry diets represent an innovation opportunity that would have value beyond organic agriculture. Insect meal, seaweed, yeast and algae protein are no longer fringe curiosities anymore, they are emerging industries capable of attracting serious investment.
The pessimistic reading is that knowledge gaps like this persist because the incentive structures that create them remain unchanged. Agricultural research priorities will continue to reflect the needs of conventional agriculture until funding mechanisms fundamentally shift. Organic producers will keep improvising around absent knowledge because they occupy a market segment too small to command research attention but too large to ignore.
A seemingly straightforward technical question about feeding chickens produces absence of information that itself maps the boundaries of what the agricultural research system prioritizes and what it overlooks. It reveals whose problems get solved and whose don’t. And it reminds us that knowledge doesn’t emerge automatically just because questions exist, it requires deliberate investment, institutional support, and someone deciding that this particular gap matters enough to fill.
References (to be completed)
van Broekhoven et al., 2015; Sogari et al., 2019; Belhadj Slimen et al., 2023; Sajid et al., 2023
Chang et al., 2004; Do, 2015; Samuel et al., 2021 and Marshall 2026
Belhadj Slimen et al., 2023; Sajid et al., 2023