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In the March edition of P&F magazine, Quality Assurance International’s (QAI) Jessica Walden answered some of your top questions regarding organic certification for flavors. After publication—in late February—the USDA’s National Organic Program (NOP) published a guidance document regarding flavors and whether or not flavor ingredients need to be sourced organically. You may refer to this document on the NOP website.
In light of this clarification, QAI has amended its stance on how flavor ingredients are evaluated; specifically, QAI is no longer making a distinction between “agricultural” vs. “nonagricultural” flavors. All flavoring ingredients are now assessed according to the NOP requirements for the use of nonagricultural, non-synthetic flavors, which are covered under 205.605(a) of the NOP’s National List of Allowed and Prohibited Substances.
Therefore, QAI's response to several questions posed by Perfumer & Flavorist magazine has been amended. The questions and revised answers can be seen below. (The red text is the revised text.)
P&F: What flavor ingredients are considered “agricultural” vs. “nonagricultural” and how are they assessed for compliance under the NOP Rule?
Walden: Further to the NOP’s clarification, the distinction between “agricultural” and “nonagricultural” flavor ingredients is no longer being enforced by QAI. Now, nonsynthetic flavors, whether agricultural or nonagricultural, may be used in organic products according to the National List, 205.605, and do not need to be sourced organically nor petitioned to be placed on 205.606. As long as flavors meet the definition of a natural flavor, according to the FDA in 21 CFR Part 101.22(a)(3), are from nonsynthetic sources, and are not produced using synthetic solvents and carrier systems or any artificial preservatives, they may be used. They also must be produced without the use of genetically-modified organisms or irradiation. Please note: this does not apply to essences or oils that are added-back to organic juices during processing. “Add-backs” in organic juices must be sourced organically.