National Organic Standards Board

Handling Subcommittee Petitioned Material Discussion Document

Collagen Gel

August 6, 2018

Summary of Petition

A petition has been submitted by Devro, Inc. to add collagen gel in Section 7 CFR 205.606, 

Nonorganically produced agricultural products allowed as ingredients in or on processed products 

labeled as “organic.” The USDA organic regulations define an agricultural product as “any agricultural 

commodity or product, whether raw or processed, including any commodity or product derived from 

livestock...”. 

The manufacturing process of collagen gel is described in the Devro, Inc’s petition: Collagen gels are 

derived from the corium layer of skins from cows, pigs, chickens and/ or turkeys. Skins are washed and 

treated with acetic acid, lactic acid, or hydrochloric acid to adjust pH in preparation for further 

production into collagen gel. Washed and treated skins are physically sieved through a two stage 

particle size reduction, resulting in a collagen pulp. Water is added and the pH reduced which causes 

the collagen to absorb water; the blend is physically agitated to produce a collagen gel which is 

physically worked and filtered to produce a fine gel. The finished collagen gel is packaged and stored in 

cold storage.

Cellulose powder, derived from plant sources, is an ancillary substance in collagen gel. Cellulose adds 

permeability to the sausage’s skin, allowing for the release of the meat emulsion’s oil and fats during the 

sausage’s cooking process. In finished collagen gel, cellulose is present in the range of 2 – 5%, 

depending on targeted product characteristics.

Collagen gel can be used in sausage production using a co-extrusion system. Typical products produced 

using this ingredient include cooked and smoked sausages. In these co-extrusion systems, collagen gel 

enrobes the sausage meat like a casing as the meat is extruded and holds the form of the meat product. 

The collagen gel is considered an ingredient in the finished product. Current organic options (casings, 

from processed intestines) will not function in this type of co-extrusion sausage production. Collagen, in 

the form of pork collagen appears on the FDA’s “GRAS Notice Inventory,” at GRN No. 21, with an 

intended use “in meat products as a binder and purge reducing agent at levels of 1.0 to 3.5 percent.”

According to the petition, collagen is a naturally occurring structural protein made up of essential amino 

acids and is present in all living organisms. It has no known toxicities and breaks down into its 

constituent amino acids on digestion. It has no environmental persistence and use of collagen is unlikely 

to have any adverse impact on the environment. Collagen is harvested from the skins of edible species 

of commercially harvested livestock processed at USDA inspected facilities following all pertinent 

regulations. It is a co-product of the animal production industry, thereby providing a raw material that 

otherwise has less value. 

Although collagen is used directly in the food industry, it is more widely used in its denatured form, as 

gelatin. Collagen is the native form of gelatin and chemically the two are indistinguishable. The two 

forms of this single protein are only separated by their physical structure; collagen retains the natural 

triple helical structure that defines it in nature. As gelatin, collagen is widely used in the food industry. 

NOSB Oct 2018 proposals and discussion documents pg. 141 of 204
Besides its direct consumption as a natural meat component, purified collagen has also been used for 

decades in the manufacture of sausages. Gelatin is currently listed under §205.606: Nonorganically 

produced agricultural products allowed as ingredients in or on processed products labeled as “organic.”

Summary of Review: 

In May of 2018 the Handling Subcommittee found the petition for collagen gel to be sufficient. A request 

for a technical report was submitted by the Subcommittee to the NOP. At this time, the technical report 

is under development. This petitioned material discussion document is being put forward with the 

intent of gathering public comment and allowing for discussion by the full board at the Fall 2018 NOSB 

meeting. 

Questions:

1. Are there organic sources of collagen gel (e.g., from skins of organically raised livestock) that 

preclude listing as a non-organically produced agricultural product allowed as ingredients in or 

on processed products labeled as “organic?”

2. Is there demand or need for this material in the market place?

3. Are acids other than acetic acid, lactic acid, or hydrochloric acid used in the production of 

collagen gel? Are food-grade acids used for the production of collagen gel?

4. Are there uses of this material other than for manufacturing meat products (such as an 

ingredient in joint health products, bone broth concentrate, or other foods or supplements, 

etc.)? What are they?

Motion to accept the discussion document on collagen gel (casing)

Motion by: Asa Bradman

Seconded by: Scott Rice

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

Approved by Lisa de Lima, Subcommittee Chair, to transmit to NOSB, August 24, 2018

NOSB Oct 2018 proposals and discussion documents pg. 142 of 204