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Organic Flavor Clarification

Posted: March 21, 2007

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Walden: Beginning June 9, 2007, all nonorganic agricultural ingredients in products labeled as organic must be listed on 205.606 and must be demonstrated as commercially unavailable. If these ingredients are not listed on 205.606 by June 9, 2007, the company will be required to either source the organic version or change the labels to a “made with organic” claim. As a certified flavor manufacturer, you are required to follow this commercial availability requirement for all agricultural ingredients, e.g., fruit purees, sugar, ethyl alcohol, maltodextrin. To have ingredients reviewed for inclusion on 205.606, you must petition the USDA NOP. For information on the NOP Petition process, please visit www.ams.usda.gov/nop/petition/petitionhome.html.

Again, due to the recent NOP clarification on flavors, all flavor ingredients are currently covered under the allowed nonagricultural ingredients that may be used in “organic” and “made with organic” products, so long as they meet the NOP restriction regarding synthetic solvents, carriers and preservatives, are not produced with genetically modified organisms or irradiation and meet the FDA definition of natural flavor. Therefore, any flavor ingredients that you source to use in your organic flavors (e.g., citral, delta-lactone, orange oil, bergamot oil) do not need to be organically produced.

P&F: For those of us already manufacturing and selling certified organic flavors, how will the upcoming changes (sunset, definitions of “agricultural” and “nonsynthetic”) affect our current certified organic flavors and the ingredients we use to make them?

Walden: Sunsetting, which occurs once every five years, is when all materials on the National List of Allowed and Prohibited Substances are reviewed and either voted to stay on the list or to be removed. We have just completed our first sunset period and the only item removed from the National List (205.605) was colors. Flavors are still allowed, but will be reassessed in five years. Regarding the current NOP definitions of agricultural, nonagricultural, nonsynthetic and synthetic, they are currently being considered and will possibly be amended by the National Organic Standards Board (NOSB). At this time, it is unclear how the definitions will change or if and how they will affect our certified clients. It is important to note that once the NOSB makes its recommendations, it will open for public comment. In any case, if the definition changes will affect certified operators, then there will be a phase-in time to allow for changes to products, if applicable.

Regarding the NOP’s recent clarification on flavors, it is important to note that for those flavor manufacturers who are already using organic flavor ingredients, or who are in the process of obtaining organic flavor ingredients (e.g., organic essential oils), they may want to continue to follow that path. The outcome of the NOSB’s recommended definitions of “agricultural” and “nonagricultural” may impact the NOP’s guidance on flavors; additionally, the NOSB may recommend changes to the National List with regard to flavors. Using certified organic flavor ingredients now is perhaps the safest approach, and will buffer organic flavor products against any changes regarding flavors in the future.