Formal Recommendation 

From: National Organic Standards Board (NOSB)

To: the National Organic Program (NOP)

Date: April 2015

Subject: Petition to add Triethyl Citrate (TEC) at §205.605

NOSB Chair: Jean Richardson

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: 

Guidance Statement:

Other: X 

Statement of the Recommendation (Motion #1): 

Motion to classify Triethyl Citrate (CAS# 77-93-0) as petitioned, as synthetic, passed. 

Statement of the Recommendation (Motion #2): 

Motion to list Triethyl Citrate (CAS# 77-93-0) as petitioned, at §205.605 without annotation, 

failed.

Rationale Supporting Recommendation (including consistency with OFPA and Organic 

Regulations): 

Based on the technical report, TEC is produced from the reaction of citric acid and ethyl alcohol 

(ethanol), both of which are fermentation products from the microbial digestion of a carbon 

substrate.” Thus TEC is considered synthetic. Additionally, there are non-synthetic alternatives 

currently on the National List that can be used for the same purpose.

Committee Vote: 

Motion to classify Triethyl Citrate (CAS# 77-93-0) as petitioned, as synthetic. 

Motion by: Jean Richardson

Seconded by: Zea Sonnabend 

Yes: 14 No: 0 Absent: 1 Abstain: 0 Recuse: 0 

Motion passed

Motion to list Triethyl Citrate (CAS# 77-93-0) as petitioned at §205.605, without annotation.

Motion by: Jean Richardson

Seconded by: Zea Sonnabend

Yes: 0 No: 14 Absent: 1 Abstain: 0 Recuse: 0 

Motion failed
National Organic Standards Board

Handling Subcommittee

Petitioned Material Proposal - Triethyl Citrate

January 6 2015

Summary of Proposed Action:

Triethyl Citrate (TEC), CAS# 77-93-0, is a synthetic substance petitioned to be added to the 

National List at §205.605 as a food additive for the intended use as a whipping enhancer for egg 

whites during processing. TEC is an ester of citric acid, a colorless, odorless liquid used as a 

food additive to stabilize foams, and especially as a whipping aid for egg whites. There are 

alternative non-synthetic substances that can be used for this purpose. Thus, the Handling 

Subcommittee proposes not to recommend that this material be added to the National List of 

Approved Substances. 

Background:

The Petition, dated 2/10/14, was received by the National Organic Standards Board (NOSB) on 

3/4/14. Following initial review, the Handling Subcommittee requested a Technical Report (TR) 

on 4/16/14. The TR was received on 11/6/14 and Sufficiency Review completed on 1/18/14. The 

petition includes no confidential business information (CBI).

Discussion:

The Petitioner states that Triethyl Citrate (TEC is a “natural, organic compliant ingredient flavor 

and is also used by the egg industry as a pasteurized egg white whipping enhancer in baking, 

such as for angel food cakes.” However, the TR indicates that TEC may not meet NOP organic 

requirements for use as a flavor. The Petitioner states, and the TR concurs, that “the main 

reason that TEC is added to egg whites is to recreate textures and related properties which are 

lost during pasteurization.” 

The Petitioner considers TEC nonsynthetic, based on 100% natural raw materials. However, the 

TR indicates that “commercial sources of TEC are produced from the reaction of citric acid and 

ethyl alcohol (ethanol), both of which are fermentation products from the microbial digestion of a 

carbon substrate.”

While there are no known commercial sources of non-synthetic or natural TEC, numerous 

plants and animals are non-commercial sources, including brown seaweed and tobacco. There 

are several alternative substances which can be used, such as sugar, some gums, and cream 

of tartar, which is potassium acid tartrate on the National List at §205.605(b).

TEC does not appear to have adverse impacts on human health or the environment.

TEC is not permitted in organic processing in Canada, the EU or by IFOAM or the CODEX, and 

not listed in JAS.

Evaluation Criteria (see attached checklist for criteria in each category)

 Criteria Satisfied? 

1. Impact on Humans and Environment ☒ Yes ☐ No ☐ N/A 

2. Essential & Availability Criteria ☐ Yes ☒ No ☐ N/A

3. Compatibility & Consistency ☐ Yes ☒ No ☐ N/A 

4. Commercial Supply is Fragile or Potentially Unavailable ☐ Yes ☐ No ☒ N/A 

as Organic (only for §205.606)
Substance Fails Criteria Category: 2, 3

Subcommittee Action & Vote 

Classification Motion: Move to classify Triethyl Citrate, CAS# 77-93-0, as petitioned, as 

synthetic. 

Motion by: Jean Richardson 

Seconded by: Zea Sonnabend 

Yes: 7 No: 0 Absent: 1 Abstain: 0 Recuse: 0 

Listing Motion: Move to list Triethyl Citrate, CAS# 77-93-0, as petitioned, at §205.605 of 

the National List without annotation.

Motion by: Jean Richardson 

Seconded by: Zea Sonnabend

Yes: 0 No: 7 Absent: 1 Abstain: 0 Recuse: 0 

 Proposed Annotation (if any): No annotation proposed

Approved by Harold Austin, Subcommittee Chair, to transmit to NOSB February 24, 2015

NOSB Evaluation Criteria for Substances Added To the National List – Handling

Category 1. Adverse Impacts on humans or the environment? Substance: Triethyl Citrate

Question Yes No N/A Comments/Documentation. (TAP; 

petition; regulatory agency; other)

1. Are there adverse effects on the 

environment, or is there a probability of 

environmental contamination during use 

or misuse of the substance?

[§205.600(b)(2), [§6518(m)(3)]

X

2. Are there adverse effects on the 

environment or is there a probability of 

environmental contamination during 

manufacture or disposal of the 

substance? [§6518(m)(3)]

X

3. Are there any adverse impacts on 

biodiversity? (§205.200)

X

4. Does the substance contain inerts 

classified by EPA as ‘inerts of 

toxicological concern’? [§6517 

(c)(1)(B)(ii)]

X
5. Is there undesirable persistence or 

concentration of the material or 

breakdown products in the environment? 

[§6518(m)(2)]

X

6. Are there any harmful effects on human 

health from the main substance or the 

ancillary substances that may be added 

to it? [§6517(c))(1)(A)(i); 6517 

(c)(2)(A)(i); §6518(m)(4), 205.600(b)(3)] 

X TR lines 423-441

7. Is the substance, and any ancillary 

substances, GRAS when used according 

to FDA’s good manufacturing practices? 

[§205.600(b)(5)]

X TR 3224-344

8. Does the substance contain residues of 

heavy metals or other contaminants in 

excess of FDA tolerances? [§205.600 

(b)(5)]

X TR 325-344

TR 393-397 FDA stipulates no more than 

3 ppm arsenic and 10 ppm lead. Major 

TEC sources meet FDA and FCC 

Category 2. Is the Substance Essential for Organic Production? Substance: Triethyl Citrate

Question Yes No N/A Comments/Documentation. (TAP; 

petition; regulatory agency; other)

1. Is the substance agricultural? [§6502(1)] X

2. Is the substance formulated or 

manufactured by a chemical process? 

[§6502(21)]

X TR 247-284

Esterization of citric acid and ethanol

3. Is the substance formulated or 

manufactured by a process that 

chemically changes a substance 

extracted from naturally occurring plant, 

animal, or mineral sources? 

[§6502(21)]

X

4. Is the substance created by naturally 

occurring biological processes? 

[§6502(21)]

X

5. Is there a natural source of the 

substance? [§ 205.600(b)(1)]

X

6. Is there an organic substitute? 

[§205.600(b)(1)]

X

7. Is the substance essential for handling of 

organically produced agricultural 

products? [§205.600(b)(6)]

X
8. Is there a wholly natural substitute 

product?

[§6517(c)(1)(A)(ii)]

X TR 318-319 – There are no known 

commercial sources of non-synthetic or 

natural TEC. Numerous plants and 

animals are non-commercial sources, 

including brown seaweed and tobacco.

TR 529 and 560 et seq. suggests sugar,

some gums and salt may be used.

9. Are there any alternative substances? 

[§6518(m)(6)]

X TR 525-582 – the main used during the 

whipping stage to enhance egg white 

foaming characteristics is cream of tartar 

(potassium acid tartrate listed at 

205.605(b)) Martha Stewart 2014.

Could use sugar TR 560 et seq.

10. Is there another practice (in farming or 

handling) that would make the substance 

unnecessary? [§6518(m)(6)]

X Could use non-pasteurized egg whites

11. Have the ancillary substances associated 

with the primary substance been 

reviewed? Describe, along with any 

proposed limitations. 

X

Category 3. Is the substance compatible with organic handling practices? 

Substance: Triethyl Citrate

Question Yes No N/A Comments/Documentation. (TAP; 

petition; regulatory agency; other)

1. Is the substance consistent with organic 

handling? 

[§6517(c)(1)(A)(iii); 6517(c)(2)(A)(ii)]

X

2. Is the manner of the substance’s use, 

manufacture, and disposal compatible 

with organic handling? [§205.600(b)(2)]

X

3. Is the substance compatible with a 

system of sustainable agriculture? 

[§6518(m)(7)]

X

4. Are the ancillary substances reviewed 

compatible with organic handling [?

X

5. Is the nutritional quality of the food 

maintained with the substance? 

[§205.600(b)(3)]

X
6. Is the primary use as a preservative? 

[§205.600(b)(4)]

X X TR 354-357 

The addition of TEC could be considered 

both to aid in the foaming process and 

help stabilize the whipped foam. 

Stabilization of foam could be considered 

a preservative function, although it 

prevents deterioration not of the egg itself 

but of the structure achieved by the 

whipping action.

7. Is the primary use to recreate or improve 

flavors, colors, textures, or nutritive 

values lost in processing (except when 

required by law)? [§205.600(b)(4)]

X TR 368-369 et seq. 

The main reason TEC is added to egg 

white it to recreate textures and related 

properties lost during pasteurization.

Category 4. Is the commercial supply of an organic agricultural substance fragile or potentially 

unavailable? [§6610, 6518, 6519, §205.2, § 205.105(d), §205.600(c)] 

Substance: Triethyl citrate

Question Yes No N/A Comments/Documentation. (TAP; 

petition; regulatory agency; other)

1. Is the comparative description as to why 

the non-organic form of the material 

/substance is necessary for use in 

organic handling provided? 

X

2. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained 

organically in the appropriate form to 

fulfill an essential function in a system of 

organic handling? 

X

3. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained 

organically in the appropriate quality to 

fulfill an essential function in a system of 

organic handling? 

X

4. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained 

organically in the appropriate quantity to 

fulfill an essential function in a system of 

organic handling?

X
5. Does the industry information about 

unavailability include (but is not limited 

to) the following?:

a. Regions of production (including 

factors such as climate and number 

of regions);

X

b. Number of suppliers and amount 

produced;

X

c. Current and historical supplies 

related to weather events such as 

hurricanes, floods, and droughts that 

may temporarily halt production or 

destroy crops or supplies; 

X

d. Trade-related issues such as 

evidence of hoarding, war, trade 

barriers, or civil unrest that may 

temporarily restrict supplies; or

X

e.Other issues which may present a 

challenge to a consistent supply?

X