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Organic/Natural Regulations: Reader Follow-Up Questions

Posted: April 16, 2007

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Reader Question 3: How would a chemical like ammoniated glyccyrizan (USA-FDA natural, but EU-artificial) fit into the organic-compliant paradigm? What about butyl butyryllactate (natural ingredients, Maillard reaction, but BBL does not exist in nature, although this type ‘gammish’ is viewed as US-natural)?

Walden: Unfortunately, most certifiers do not have flavor chemists on staff, so we rely largely on signed affidavits from suppliers of natural flavor materials to indicate whether or not the flavor material is compliant with the NOP regulation. Please find QAI’s Flavor Affidavit by clicking here

However, during the certification process for flavors, we do review all flavor ingredients added to the product and if we have reason to believe that an ingredient may not meet the NOP regulation (even if we have received an acceptable flavor affidavit for said ingredient) we ask for further information on how the material is produced. Currently, the NOP Rule requires that flavors are nonsynthetic. Synthetic is defined in the NOP Rule as “a substance that is formulated or manufactured by a chemical process or by a process that chemically changes a substance extracted from naturally occurring plant, animal, or mineral sources, except that such term shall not apply to substances created by naturally occurring biological processes.”2

The NOP recently clarified that flavors used in “organic”/“made with organic” products must meet the FDA’s Natural Flavor definition, 21 CFR Part 101.22(a)(3) and be produced without the use of synthetic solvents, carrier systems or artificial preservatives. The FDAs Natural Flavor definition includes all flavors that are derived from natural substances and are processed using biological and mechanical methods, as opposed to chemical methods. In light of this, QAI would inquire further into how the above mentioned flavor materials—ammoniated glycyrrhizin and butyl butyryllactate—are produced in order to determine if they met the NOP requirements.

Reader Question 4: Can you explain without using the NOP to describe what natural FEMA GRAS approved ingredients are allowable in an organic flavor formulation at 100%, 95% and 70%?