Naval Stores Regulation — Federal Grading and Inspection Standards for Turpentine and Rosin

Turpentine and rosin — the primary products extracted from longleaf and slash pines — have been federally regulated since 1923. The Naval Stores Act (7 U.S.C. §§ 91–99) directs USDA's Agricultural Marketing Service to establish and enforce quality standards, grade designations, and a voluntary inspection system for these pine-derived commodities. The regulations implementing the Act live at 7 CFR Part 160 — Regulations and Standards for Naval Stores (102 sections).

"Naval stores" is an archaic term that persists in federal law: in the age of wooden sailing ships, pine pitch, tar, and turpentine were essential for caulking and preserving hulls — hence "stores" kept for naval use. Today, turpentine is used as a paint solvent, cleaning agent, and chemical feedstock; rosin is used in adhesives, paper sizing, printing inks, soap manufacturing, and as a tackifier in rubber and synthetic resins. The U.S. naval stores industry — once dominant in the longleaf pine forests of the Southeast — has contracted significantly since mid-century as petroleum-derived substitutes became cheaper, but the grading standards remain in force for the domestic and export trade in natural pine-derived products.

Legal Authority

• 7 U.S.C. § 91 — Naval Stores Act (1923); authorizes USDA to establish grade standards and a voluntary inspection system for naval stores (turpentine, rosin, and related pine-derived products); prohibits misrepresentation of grades in commerce
• 7 U.S.C. § 92 — Authorizes USDA to establish standards of quality and purity for naval stores and to revise them as warranted
• 7 U.S.C. § 95 — Establishes the voluntary inspection service; authorizes USDA to charge fees for inspection and to license inspectors
• 7 CFR Part 160 — USDA AMS implementing regulation; establishes grade designations (rosin grades A through WG; turpentine quality standards), inspection procedures, licensing requirements for inspection facilities, and fee schedules

Key Mechanics

The Naval Stores Act establishes a voluntary grading and inspection system — not mandatory — administered by USDA's Agricultural Marketing Service. Producers, dealers, or buyers who want an official USDA grade determination submit a request and pay the applicable fee; a licensed inspector certifies the product's compliance with grade standards. Rosin is graded alphabetically from highest (WG — Water White) through the alphabet down to lower grades (B, C, D, etc.) based on color clarity measured by comparison to color glass standards; color is the primary quality indicator for rosin because it affects suitability for different industrial applications (lighter grades command premium prices in adhesives and food-contact applications). Turpentine (spirits of turpentine) is graded for purity against distillation and composition standards. The grade system enables standardized commercial trading — buyers and sellers can transact based on grade designations without independently testing each lot. Products bearing a USDA grade certificate may not misrepresent the grade; misrepresentation is a violation of the Act. The grade standards have been substantively unchanged since the 1950s, reflecting the stability of the product and the contraction of the domestic natural naval stores industry.

Current Rule (2026)

What This Rule Does

The Part 160 regulations establish official federal standards for identifying, classifying, and grading turpentine and rosin. The system serves two functions: (1) it gives buyers and sellers a standardized quality vocabulary for interstate commerce — a barrel labeled "U.S. WW rosin" means the same thing to a buyer in Boston as to a seller in Georgia; and (2) it provides a voluntary federal inspection service through which producers and shippers can obtain official USDA certificates documenting the grade and condition of their product.

Products and types:

• Spirits of turpentine (§ 160.2): a colorless or faintly colored volatile oil, primarily terpene hydrocarbons (C₁₀H₁₆), with a characteristic pine scent, derived from pine-family trees. Three commercial types:

  • Gum turpentine — distilled directly from oleoresin (gum) tapped from living trees
  • Wood turpentine — steam-distilled from the volatile oils in pine wood or wood chips
  • Sulfate (sulphate) turpentine — recovered from the vapors produced when wood pulp is cooked by the kraft (sulfate) pulping process; the most common commercial source today as a byproduct of paper production

• Rosin (§§ 160.3–160.4): the hard, glassy, amber-to-dark resin remaining after turpentine oils are distilled off. Three commercial types:

  • Gum rosin — the residue from distilling gum spirits of turpentine; typically highest purity
  • Wood rosin — recovered from pine stumps and heartwood by solvent extraction or steam distillation
  • Tall oil rosin — the rosin fraction separated from crude tall oil (a byproduct of kraft paper production)

Key Provisions

• § 160.11 — Turpentine quality standard: spirits of turpentine must meet American Society for Testing and Materials (ASTM) specifications to receive any official U.S. grade designation; ASTM is the reference standard for all turpentine quality determinations
• § 160.12 — Rosin type designations: rosin must be labeled as gum, wood, or tall oil rosin — misrepresenting the source type is a violation
• § 160.13 — Rosin grade scale: rosin is graded by color and clarity on a 16-letter scale from highest to lowest: XC, XB, XA, X, WW, WG, N, M, K, I, H, G, F, E, D, B; "WW" (Water White) and "WG" (Window Glass) are the premium grades most common in fine uses like adhesives and paper sizing; "B" is the lowest salable grade; "OP" designates opaque rosin (cloudy from moisture or crystalization); "FF" designates normal wood rosin
• § 160.18 — Grading by comparison: inspectors grade rosin by comparing a prepared sample cube to official standard samples — the rosin receives the grade of the standard it matches or is better than in color, without reaching the next higher grade
• § 160.19 — Sampling protocol: grading samples must be cube-shaped, approximately 7/8 inch thick, cut from at least 4 inches below the surface of the barrel or drum — to avoid sampling only the top layer
• § 160.24 — On-request inspection: official inspectors must sample and certify naval stores whenever an interested party requests it and the request is practical; the certificate is the legal record of condition at the time of inspection
• § 160.32 — Container marking: containers that pass inspection must be marked with the appropriate designation; containers that fail any U.S. Standard may not be marked with any U.S. grade designation
• § 160.36 — Mark integrity: official inspection marks may not be erased, covered, or altered; only an official inspector may authorize changes to marks
• §§ 160.38–160.58 — Licensed inspection system: processors at eligible plants may apply for a permit to use a private "licensed inspector" instead of a traveling USDA official inspector; licensed inspectors must pass a qualifying examination (§ 160.40), must be disinterested from sales and pricing decisions (§ 160.43), and work under USDA supervision; their licenses can be suspended or revoked for repeated errors or non-compliance (§ 160.52)

Fee Schedule

(§§ 160.201–160.205)

How It Affects You

If you produce or trade in turpentine or rosin: The USDA grading system is voluntary — you are not required to have your product officially inspected. But buyers in institutional markets (adhesive manufacturers, paper mills, ink producers) frequently require USDA-certified grade certificates as a condition of purchase or as the basis for price determination. Obtaining a voluntary certificate — either from a traveling AMS inspector or from a licensed inspector at your processing plant — is the industry-standard way to document grade and condition at the point of origin. The licensed inspector option is particularly useful for high-volume processors who prefer on-site continuous inspection to reduce shipment delays.

If you import turpentine or rosin: Imported products are subject to the same grade standards and can be inspected at ports of entry. Import certificates facilitate customs valuation and compliance with buyer contract specifications. Gum turpentine from China and Brazil and tall oil rosin from Scandinavian paper mills are the primary import sources competing with domestic product in U.S. markets.

If you are a downstream user (coatings, adhesives, inks, rubber): Understanding the rosin grade scale matters for procurement specifications. WW and WG grades command premiums for uses requiring high clarity and light color; lower grades (N through B) are acceptable for many industrial applications where color is immaterial. Tall oil rosin is often lower-cost and interchangeable with gum rosin for many industrial uses, though chemical composition differs slightly.

Statutory Authority

This rule implements:

• 7 U.S.C. § 91 — Naval Stores Act definitions: "naval stores" means rosin, turpentine, spirits of turpentine, and all products derived from them; "interstate commerce" broadly construed
• 7 U.S.C. § 92 — Misbranding prohibition: it is unlawful to sell, ship, or offer naval stores in interstate commerce under any false designation or to represent them as meeting a quality standard when they do not
• 7 U.S.C. § 94 — Standards authority: the Secretary of Agriculture shall establish and promulgate standards for naval stores and make them available to the trade; the Secretary may create such inspectors as needed for the work
• 7 U.S.C. § 95 — Voluntary inspection: the Secretary shall, upon request, analyze and classify naval stores and issue certificates; the results are prima facie evidence of fact in any court proceeding
• 7 U.S.C. § 98 — Penalties: violations of the Act are misdemeanors punishable by fine up to $1,000 and imprisonment up to one year

Recent Rulemakings

The last major substantive amendment to 7 CFR Part 160 was published at 47 FR 3345 (January 26, 1982) — adjusting fee schedules and administrative procedures. The grade standards themselves have been largely stable since the 1950s, reflecting the relatively stable chemistry of the products. The ASTM reference standards for turpentine specification (Appendix A) are updated by ASTM independently and incorporated by reference into the regulation. No major rulemakings in the past decade — the naval stores industry is too small and stable to attract regulatory attention.

Pending Action

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