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Organic Flavor Clarification

Posted: March 21, 2007

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The FDA definition of natural flavor is as follows: “The term natural flavor or natural flavoring means the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional. Natural flavors include the natural essence or extractives obtained from plants listed in 182.10, 182.20, 182.40, and 182.50 and part 184 of this chapter, and the substances listed in 172.510 of this chapter.” FDA 21 CFR Part 101.22(a)(3)

P&F: What are the organic requirements for flavor ingredients?

Walden: All ingredients in the flavor, including carriers or solvents, must be organically produced, approved non-organic agricultural materials, or approved nonagricultural ingredients, which are listed in the NOP Regulation, section 205.605. For products making a 100% organic claim, all ingredients in the product must be certified 100% organic, and any processing aids used must be organic. For the organic claim, all organic ingredients must equal 95% of the product’s formulation (excluding water and salt). The remaining 5% either must be ingredients listed in section 205.605 or, beginning June 2007, listed in section 205.606.

For products making a “made with organic (specified ingredients or food groups)” claim, at least 70% of the product (excluding water and salt) must be composed of organic ingredients. The remaining 30% may be from nonorganic agricultural ingredients or nonagricultural ingredients listed in section 205.605 of the NOP Regulation. All nonorganic ingredients in an organic or made with organic product must be produced without genetically modified organisms, irradiation or sewage sludge. All certified organic flavors and flavor ingredients must be nonsynthetic and produced without synthetic solvents, carriers or preservatives.

P&F: How will the commercial availability changes that will be enforced starting June 9, 2007 affect ingredients used in organic flavors?