Question

What non-organic ingredients can be used for organic food manufacturing according to the EU and USDA Organic standards?

ANSWER

European Union (EU) Organic Guidelines

Foods may only be marked as “organic” if at least 95% of their agricultural ingredients are organic. Organic ingredients in non-organic food may be listed as organic in the list of ingredients, as long as the ingredient has been produced in accordance with the organic legislation.

The use of GMOs in organic production is prohibited. For the sake of clarity and coherence, it should not be possible to label a product as organic where it has to be labelled as ‘containing GMOs’, ‘consisting of GMOs’ or ‘produced from GMOs’.

By referring to Article 19(2) (b), non-organic agricultural ingredients may be used only if they have been authorized for use in organic production in accordance with Article 21 or have been provisionally authorized by a Member State.

The following conditions shall apply to the composition of organic processed food but only in so far as they have been authorized for use in organic production in accordance with Article 21 of Council Regulation (EC) 834/2008:

 Additives
Processing Aids
Flavourings
Water
Salt
Preparations of micro-organisms and enzymes
Minerals
Trace elements
Vitamins
Amino acids
Micronutrients in foodstuffs for particular nutritional uses

(Council Of The European Union, 2007; 2008).

 

USDA Organic Standards

Foods labelled organic must be certified tinder die National Organic Program (NOP). They must be grown and processed using organic farming methods that recycle resources and promote biodiversity (National Organic Program, 2015).

Only the following non-organically produced agricultural products may be used as ingredients in or on processed products labelled as ―organic,‖ only in accordance with any restrictions specified in this section, and only when the product is not commercially available in organic form:

  • § 205.605 Non-agricultural (nonorganic) substances allowed as ingredients in or on processed products labelled as ―”organic” or ―made with organic (specified ingredients or food group(s))” that are categorized into Non-synthetics and Synthetics group.
Non-synthetics Synthetics
  • Acids (Alginic; Citric—produced by microbial fermentation of carbohydrate substances; and Lactic).
  • Agar-agar.
  • Animal enzymes—(Rennet—animals derived; Catalase—bovine liver; Animal lipase; Pancreatin; Pepsin; and Trypsin).
  • Bentonite.
  • Calcium carbonate.
  • Calcium chloride.
  • Calcium sulfate—mined.
  • Carrageenan.
  • Dairy cultures.
  • Diatomaceous earth—food filtering aid only.
  • Egg white lysozyme (CAS # 9001–63–2).
  • Enzymes—must be derived from edible, nontoxic plants, non-pathogenic fungi, or non-pathogenic bacteria.
  • Flavours, non-synthetic sources only and must not be produced using synthetic solvents and carrier systems or any artificial preservative.
  • Glucono delta-lactone—production by the oxidation of D-glucose with bromine water is prohibited.
  • Kaolin.
  • L-Malic acid (CAS # 97–67–6).
  • Magnesium sulfate, non-synthetic sources only.
  • Microorganisms—any food grades bacteria, fungi, and other microorganism.
  • Nitrogen—oil-free grades.
  • Oxygen—oil-free grades.
  • Perlite—for use only as a filter aid in food processing.
  • Potassium chloride.
  • Potassium iodide.
  • Sodium bicarbonate.
  • Sodium carbonate.
  • Tartaric acid.
  • Waxes—non-synthetic (Carnauba wax; and Wood resin).
  • Yeast—non-synthetic, growth on petrochemical substrate and sulfite waste liquor is prohibited (Autolysate; Bakers; Brewers; Nutritional; and Smoked—non-synthetic smoke flavouring process must be documented).

 

  • Activated charcoal (CAS #s 7440–44–0; 64365–11–3)—only from vegetative sources; for use only as a filtering aid.
  • Alginates.
  • Ammonium bicarbonate—for use only as a leavening agent.
  • Ammonium carbonate—for use only as a leavening agent.
  • Ascorbic acid.
  • Calcium citrate.
  • Calcium hydroxide.
  • Calcium phosphates (monobasic, dibasic, and tribasic).
  • Carbon dioxide.
  • Cellulose—for use in regenerative casings, as an anti-caking agent (non-chlorine bleached) and filtering aid.
  • Chlorine materials—disinfecting and sanitizing food contact surfaces, Except, That, residual chlorine levels in the water shall not exceed the maximum residual disinfectant limit under the Safe Drinking Water Act (Calcium hypochlorite; Chlorine dioxide; and Sodium hypochlorite).
  • Cyclohexylamine (CAS # 108–91–8)—for use only as a boiler water additive for packaging sterilization.
  • Diethylaminoethanol (CAS # 100–37–8)—for use only as a boiler water additive for packaging sterilization.
  • Ethylene—allowed for postharvest ripening of tropical fruit and degreening of citrus.
  • Ferrous sulfate—for iron enrichment or fortification of foods when required by regulation or recommended (independent organization).
  • Glycerides (mono and di)—for use only in drum drying of food.
  • Glycerin—produced by hydrolysis of fats and oils.
  • Hydrogen peroxide.
  • Lecithin—bleached
  • Magnesium carbonate—for use only in agricultural products labelled ―”made with organic (specified ingredients or food group(s)),” prohibited in agricultural products labelled ―”organic”.
  • Magnesium chloride—derived from sea water.
  • Magnesium stearate—for use only in agricultural products labelled ―”made with organic (specified ingredients or food group(s)),” prohibited in agricultural products labelled ―”organic”.
  • Nutrient vitamins and minerals, in accordance with 21 CFR 104.20, Nutritional Quality Guidelines for Foods.
  • Octadecylamine (CAS # 124–30–1)—for use only as a boiler water additive for packaging sterilization.
  • Ozone.
  • Pectin (low-methoxy).
  • Peracetic acid/Peroxyacetic acid (CAS # 79–21–0)—for use in wash and/or rinse water according to FDA limitations. For use as a sanitizer on food contact surfaces.
  • Phosphoric acid—cleaning of food-contact surfaces and equipment only.
  • Potassium acid tartrate.
  • Potassium carbonate.
  • Potassium citrate.
  • Potassium hydroxide—prohibited for use in lye peeling of fruits and vegetables except when used for peeling peaches during the Individually Quick Frozen (IQF) production process.
  • Potassium iodide—for use only in agricultural products labelled ―”made with organic (specified ingredients or food group(s)),” prohibited in agricultural products labelled ―”organic”.
  • Potassium phosphate—for use only in agricultural products labelled ―”made with organic (specific ingredients or food group(s)),” prohibited in agricultural products labelled ―”organic”.
  • Silicon dioxide.
  • Sodium acid pyrophosphate (CAS # 7758–16–9)—for use only as a leavening agent.
  • Sodium citrate.
  • Sodium hydroxide—prohibited for use in lye peeling of fruits and vegetables.
  • Sodium phosphates—for use only in dairy foods.
  • Sulfur dioxide—for use only in wine labelled ―”made with organic grapes,” Provided, that, total sulfite concentration does not exceed 100 ppm.
  • Tartaric acid.
  • Tetrasodium pyrophosphate (CAS # 7722–88–5)—for use only in meat analog products.
  • Tocopherols—derived from vegetable oil when rosemary extracts are not a suitable alternative.
  • Xanthan gum.
  • §205.606 Non-organically produced agricultural products allowed as ingredients in or on processed products labelled as ―”organic”.
Colours derived from agricultural products Starches Others
  • Annatto extracts colour (pigment CAS # 1393–63–1)—water and oil soluble.
  • Beet juice extract colour (pigment CAS # 7659–95–2).
  • Beta-carotene extract colour, derived from carrots (CAS # 1393–63–1).
  • Black currant juice colour (pigment CAS #’s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
  • Black/Purple carrot juice colour (pigment CAS #’s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
  • Blueberry juice colour (pigment CAS #’s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
  • Carrot juice colour (pigment CAS # 1393–63–1).
  • Cherry juice colour (pigment CAS #’s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
  • Chokeberry—Aronia juice colour (pigment CAS #’s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
  • Elderberry juice colour (pigment CAS #’s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
  • Grape juice colour (pigment CAS #’s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
  • Grape skin extract colour (pigment CAS #’s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
  • Paprika colour (CAS # 68917–78–2)—dried, and oil extracted.
  • Pumpkin juice colour (pigment CAS # 127–40–2).
  • Purple potato juice (pigment CAS #’s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
  • Red cabbage extract colour (pigment CAS #’s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
  • Red radish extract colour (pigment CAS #’s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
  • Saffron extract colour (pigment CAS # 1393–63–1).
  • Turmeric extract colour (CAS # 458–37–7).
  • Cornstarch (native).
  • Rice starch, unmodified (CAS # 977000–08–0)—for use in organic handling until June 21, 2009.
  • Sweet potato starches—for bean thread production only.
  • Casings, from processed intestines.
  • Celery powder Chia (Salvia hispanica L.).
  • Chia (Salvia hispanica L.).
  • Dill weed oil (CAS # 8006–75–5).
  • Fish oil (Fatty acid CAS #’s: 10417–94–4, and 25167–62–8)—stabilized with organic ingredients or only with ingredients on the National List, §§205.605 and 205.606.
  • Fructo-oligosaccharides (CAS # 308066–66–2).
  • Galangal, frozen.
  • Gelatin (CAS # 9000–70–8).
  • Gums—water extracted only (Arabic; Guar; Locust bean; and Carob bean).
  • Inulin-oligofructose enriched (CAS # 9005–80–5).
  • Kelp—for use only as a thickener and dietary supplement.
  • Konjac flour (CAS # 37220–17–0).
  • Lecithin—unbleached.
  • Lemongrass—frozen.
  • Orange shellac-unbleached (CAS # 9000–59–3).
  • Pectin (high-methoxy).
  • Peppers (Chipotle chile).
  • Turkish bay leaves.
  • Wakame seaweed (Undaria pinnatifida).
  • Whey protein concentrates.

 

References

Council Of The European Union. (2007). Commission Regulation (EC) No 834/2007 on organic production and labelling of organic products and repealing Regulation (EEC) No 2092/91.

Council Of The European Union. (2008). Commission Regulation (EC) No 834/2008 on organic production and labelling of organic products and repealing Regulation (EEC) No 2092/91.

National Organic Program. (2015). Subpart G—Administrative —National Organic Program: The National Lost of Allowed and Prohibited Substances. Washington, DC: U.S. Government Printing Office.

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