Sunset 2021

Meeting 1 - Request for Public Comment 

Handling Substances §§205.605(a), 205.605(b), 205.606

April 2019

Introduction

As part of the Sunset Process, the National Organic Program (NOP) announces substances on the 

National List of Allowed and Prohibited Substances (National List) that are coming up for sunset review 

by the National Organic Standard Board (NOSB). The following list announces substances that are on the 

National List for use in organic handling that must be reviewed by the NOSB and renewed by the USDA 

before their sunset dates. This document provides the substance’s current status on the National List, 

use description, references to past technical reports, past NOSB actions, and regulatory history, as 

applicable. If a new technical report has been requested for a substance, this is noted in this list. To see 

if any new technical report is available, please check for updates under the substance name in the 

Petitioned Substances Database. 

Request for Comments

While the NOSB will not complete its review and any recommendations on these substances until the 

Fall 2019 public meeting, the NOP is requesting that the public provide comments about these 

substances to the NOSB as part of the Spring 2019 public meeting. Comments should be provided via

Regulations.gov at www.regulations.gov by April 4, 2019, as explained in the meeting notice published 

in the Federal Register. 

These comments are necessary to guide the NOSB’s review of each substance against the criteria in the 

Organic Foods Production Act (7 U.S.C. 6518(m)) and the USDA organic regulations (7 CFR 205.600). The 

current substances on the National List were originally recommended by the NOSB based on evidence 

available to the NOSB at the time of their last review, which demonstrated that the substances were 

found to be: (1) not harmful to human health or the environment, (2) necessary because of the 

unavailability of wholly nonsynthetic alternatives, and (3) consistent and compatible with organic 

practices. 

Public comments should focus on providing new information about a substance since its last NOSB 

review. Such information could include research or data that may support a change in the NOSB’s 

determination for a substance. Public comment should also address the continuing need for a substance 

or whether the substance is no longer needed or in demand.

Guidance on Submitting Your Comments

Comments should clearly indicate your position on the allowance or prohibition of substances on the list 

and explain the reasons for your position. You should include relevant information and data to support 

your position (e.g., scientific, environmental, manufacturing, industry impact information, etc.). 

For Comments That Support Substances Under Review:

If you provide comments in support of an allowance of a substance on the National List, you should 

provide information demonstrating that the substance is: 

(1) not harmful to human health or the environment;

(2) necessary to the production of the agricultural products because of the unavailability of wholly 

nonsynthetic substitute products; and 

(3) consistent with organic handling. 

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For Comments That Do Not Support Substances Under Review: 

If you provide comments that do not support a substance on the National List, you should provide 

reasons why the use of the substance should no longer be allowed in organic production or handling. 

Specifically, comments that support the removal of a substance from the National List should provide 

new information since its last NOSB review to demonstrate that the substance is: 

(1) harmful to human health or the environment; 

(2) unnecessary because of the availability of alternatives; and 

(3) inconsistent with handling. 

For Comments Addressing the Availability of Alternatives: 

Comments may present information about the viability of alternatives for a substance under sunset 

review. Viable alternatives include, but are not limited to:

• Alternative management practices that would eliminate the need for the specific substance; 

• Other currently exempted substances that are on the National List, which could eliminate the 

need for this specific substance; and

• Other organic or nonorganic agricultural substances. 

Your comments should address whether any alternatives have a function and effect equivalent to or 

better than the allowed substance, and whether you want the substance to be allowed or removed from 

the National List. Assertions about alternative substances, except for those alternatives that already 

appear on the National List, should, if possible, include the name and address of the manufacturer of the 

alternative. Further, your comments should include a copy or the specific source of any supportive 

literature, which could include product or practice descriptions; performance and test data; reference 

standards; names and addresses of producers or handlers who have used the alternative under similar 

conditions and the date of use; and an itemized comparison of the function and effect of the proposed 

alternative(s) with substance under review. 

For Comments on Nonorganic Agricultural Substances at Section 205.606.

For nonorganic agricultural substances on section 205.606, the NOSB Handling Subcommittee requests 

current industry information regarding availability of and history of unavailability of an organic form of 

the substance in the appropriate form, quality, or quantity of the substance. The NOSB Handling 

Subcommittee would like to know if there is a change in supply of organic forms of the substance or 

demand for the substance (i.e. is an allowance for the nonorganic form still needed), as well as any new 

information about alternative substances that the NOSB did not previously consider.

Written public comments will be accepted through April 4, 2019, via www.regulations.gov. Comments 

received after that date may not be reviewed by the NOSB before the meeting. 

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Sunset 2021

Meeting 1 - Request for Public Comment 

Handling Substances §§205.605(a), 205.605(b), 205.606

April 2019

Note: With the exception of Activated Charcoal, L-Malic Acid, Microorganisms, Peracetic 

Acid/Peroxyacetic Acid, and Sodium Acid Pyrophosphate, the materials included in this list are 

undergoing early sunset review as part of November 18, 2016, NOSB recommendation on efficient 

workload re-organization. 

Reference: 7 CFR 205.605 Nonagricultural (Nonorganic) substances allowed as ingredients in or on 

processed products labeled as ‘‘organic’’ or ‘‘made with organic (specified ingredients or food 

group(s)).’’

§205.605(a) Nonsynthetics allowed:

Acid, Citric

Acid, Lactic

Calcium chloride

Dairy cultures

Enzymes

L-Malic acid

Magnesium sulfate

Microorganisms

Perlite

Potassium iodide

Yeast

§205.605(b) Synthetics allowed:

Acid, Alginic

Activated charcoal

Ascorbic acid

Calcium citrate

Ferrous sulfate

Hydrogen peroxide

Nutrient vitamins and minerals

Peracetic acid

Potassium citrate

Potassium phosphate

Sodium acid pyrophosphate

Sodium citrate

Tocopherols

Reference: 7 CFR 205.606 Nonorganically produced agricultural products allowed as ingredients in or 

on processed products labeled as “organic.”

Celery powder

Fish oil

Gelatin

Orange pulp, dried

Seaweed, Pacific kombu

Wakame seaweed (Undaria pinnatifida)

Links to additional references and supporting materials for each substance can be found on the NOP 

website: http://www.ams.usda.gov/rules-regulations/organic/national-list/petitioned

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Acids – Citric

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(a) Nonsynthetics allowed: Acids (Citric – produced by microbial fermentation of 

carbohydrate substances; and Lactic).

Technical Report: 1995 TAP - Citric; 2015 TR - Citric; 1995 TAP – Lactic; 2015 TR - Lactic

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 03/2010 sunset 

recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from Subcommittee: 

Use:

Citric acid is widely used in food processing. It is used as an ingredient, acidulant, pH control agent, 

flavoring, and as a sequestrant. It is used as a dispersant in flavor or color additives. It is also an 

ingredient in dietary supplements and a nutrient, sequestrant, buffer, antioxidant, firming agent, acidity 

regulator (in jams and jellies, soft drinks and wines), raising agent, and emulsifying salt for many other 

products. It is also used to improve baking properties of flours, and as a stabilizer, and to inhibit color 

and flavor deterioration in fruits. Roughly 75% of all citric acid commercially produced is used by the 

food industry including baby food, breakfast cereals, frozen desserts, frozen entrees and certified 

organic personal care products. The remainder is used in cleaning agents, or in the cosmetics and 

pharmaceutical industries. 

Manufacture:

First isolated from lemons, it was extracted from lemons and limes until 1919 when production shifted 

to fermentation (a biological process by which sugars are metabolized to acids, gases, and/or alcohol). 

Today, the mold Aspergillus niger is cultured with low pH values and high levels of sugars and mineral 

salts to economically produce high yields through fermentation. Various chemical synthesis of citric acid 

appeared but none have reached the economics derived from the fermentation process. The 

fermentation process has been refined over the years to produce high levels of citric acid instead of high 

levels of the by-product oxalic acid. Some public commenters expressed a concern that the 

fermentation process involves the use of synthetic chemical reactions that were not considered in the 

original 1995 classification. 

International Acceptance:

Citric acid is an allowed ingredient in all international organic standards reviewed in the 2015 TR. The 

only noted annotation is that Japan Agriculture Standards allow citric acid but only as a pH adjuster for 

processed fruits and processed vegetables.

Environmental Issues:

Although it is a weak acid, exposure to pure citric acid may cause coughing, shortness of breath, and skin 

irritation. The fermentation process does produce by-products including oxalic acid. Citric acid will 

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degrade to produce non-toxic and non-persistent environmental products. The last time EPA evaluated 

citric acid was 1992 at which time they found it posed no environmental risk. 

Discussion: 

Citric acid has been approved for organic use under 205.605 if the citric acid used is produced by 

microbial fermentation of carbohydrate substances (non-synthetic). The NOSB in its initial request for 

public comment in 2017 did not ask for any specific information from stakeholders. While there were no 

specific questions asked of the public, the subcommittee did receive several comments from various 

stakeholders. 

Citric acid has GRAS status (Generally Recognized as Safe) by the FDA. Citric acid has many uses in food 

production. It has a history of safe use in organic foods dating back to 1995. Natural citric acid may be 

isolated from organically grown fruit but has not been commercially available in the quantities that 

would be required to service the organic sector. Alternate acids are not more natural and do not give 

the same flavor profile. It is used as a pH adjuster for organic fruit processing and spreads. There are no 

other alternatives to date that can replace citric acid.

While there were some public concerns from the 2015 sunset review about the relisting of this material, 

the majority of public comments from the 2015 sunset review stated that it is necessary in the organic 

industry for proper pH control in many foods. There are currently no allowed alternatives available to 

citric acid. 

This material satisfies the OFPA Evaluation criteria. 

Several commenters were in favor of relisting, stating citric acid is a naturally occurring substance but 

classified as a synthetic due to chemical processing through fermentation. One commenter suggested 

malic acid may work for lowering pH instead of citric acid but there are no studies that determine 

feasibility and the effect on product profiles. Comments from cut-fruit manufacturers stated no other 

alternatives provide the same shelf life extension as the fruit treated with citric acid. 

Additional information requested by Subcommittee:

1. Are there any commercially available sources of citric acid derived from organically grown crops?

Acids – Lactic

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(a) Nonsynthetics allowed: Acids (Citric – produced by microbial fermentation of 

carbohydrate substances; and Lactic).

Technical Report: 1995 TAP - Citric; 2015 TR - Citric; 1995 TAP – Lactic; 2015 TR - Lactic

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 03/2010 sunset 

recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

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Background from subcommittee: 

Use:

Lactic acid is widely used in almost every segment of the food industry, where it carries out a wide range 

of functions. The major use of lactic acid is in food and food-related applications, which in the U.S. 

accounts for approximately 85% of the demand. It is found naturally in milk, meat, and beer but is 

normally associated with sour milk. Lactic acid controls the growth of bacteria including listeria (NOSB 

Fall Meeting Transcript 2015 pp. 263). The other uses are non-food industrial applications. Lactic acid 

occurs naturally in many food products. It has been in use as an acidulant and pH regulator for many 

years. It regulates microflora in food and has been found to be very effective against certain types of 

microorganisms, giving it pronounced efficacy as a preservative (Vijayakumar, Aravindan and Viruthagiri 

2008). Other uses include mixing with sodium, potassium, and distilled water to form intravenous fluids 

commonly used after blood loss. It is sometimes used in the pharmaceutical industry to adjust acidity. 

Lactic acid appears on the National List, 7 CFR Part 205.605(a), as a non-synthetic material with no 

restrictions on use.

Common uses include, but are not limited to: 

1. In sugar confectionery, it is used in a continuous production line for high boiled sweets to make 

perfectly clear sweets with minimum sugar inversion and with no air trapped. 

2. In bakery products it is used for direct acidification of bread. 

3. It increases butter stability and volume. 

4. It produces a mild and pleasant taste in acid pickles, relishes and salad dressings. 

5. Lactic acid suppresses Coliform and NOSB Mesentericur groups of bacteria. 

6. Lactic acid can be used as a meat carcass “wash” or in meat products to reduce microbial 

contamination.

7. It is used in jams, jellies, and frozen fruit desserts. 

8. In dairy products such as cottage cheese, the addition of lactic acid is preferred by some 

manufacturers to fermentation. 

9. Used in imitation dairy products such as non-dairy cheese and non-dairy yogurt powder. 

10. Lactic acid is widely used in preserving fruits, for example helping to maintain firmness of apple 

slices during processing. It also inhibits discoloration of fruits and some vegetables. 

11. Buffered lactic acid improves the taste and flavor of many beverages, such as soft drinks, mineral 

water and carbonated fruit juices. 

12. In breweries, lactic acid is used for pre-adjustments during the mashing process and during cooking. 

13. Acidification of lager beer with lactic acid improves the microbial stability as well as flavor. 

14. It is used in processing of meal in sauces for canned fish, to improve the taste and flavors and to 

mask amine flavor from fish meal. 

15. Lactic acid is used for flavor development and the control of microorganisms in soy cheese.

Manufacture:

First isolated in 1780 from sour milk, lactic acid can be produced both naturally and synthetically. It can 

be produced in either a solid, water-soluble state, or a colorless liquid state. Lactic acid is produced on 

an industrial scale through carbohydrate fermentation performed by lactic acid bacteria converting 

simple carbohydrates such as glucose, sucrose, or galactose to lactic acid. A secondary manufacturing 

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process involves chemical synthesis of adding hydrogen cyanide to acetaldehyde, an organic chemical 

compound found in coffee, bread, ripe fruit, coal, or crude oil. This process only exists today in Japan. 

There is also a group of microbes known broadly as Lactic Acid Bacteria which produce lactic acid as a 

result of carbohydrate fermentation. 

International Acceptance:

Lactic acid is permitted under all five major organic standards (US, EU, Canada, Japan Agriculture, and 

IFOAM). Canada classifies it as non-organic “for fermented vegetable products or in sausage”. CODEX 

permits its use “food of plant origin”, or “food of animal origin”. European Economic Council permits use 

in processing foodstuffs of both plant and animal origin, or for the regulation of pH in yeast production. 

Japan Agriculture Standards permits use in processed vegetables or rice products, sausage, for dairy 

products, and for cheese.

Environmental Issues:

The fermentation process produces calcium sulfate waste (sometimes sold as fertilizer) but it is not 

known to create any negative environmental impacts. 

Discussion:

Lactic acid is a “Direct Food Substance Affirmed as Generally Recognized as Safe,” or GRAS, as an 

antimicrobial agent, curing and pickling agent, flavor enhancer, flavoring agent and adjuvant, pH control 

agent, and as a solvent and vehicle, with no limitation other than current good manufacturing practice 

according to FDA regulations at 21 CFR 184.1061. 

Lactic acid is one of the most widely distributed acids and preservatives in nature. It is produced 

naturally by humans, animals, and microorganisms. Lactic acid is an acidulate that is a natural organic 

acid present in milk, meat and beer, but is normally associated with sour milk. It occurs naturally in two 

isomers (D) and (L). (D) is harmful to humans so (L) is the preferred isomer for food and 

pharmaceuticals. It functions as a flavor agent, preservative and acidity adjuster in foods. 

There is no known organic alternative to lactic acid. Currently, it is not being produced organically. Since 

raw material sourcing for dextrose or sucrose could include corn and beet sugar, the TR (lines 569-572) 

stated the purification process would remove any traces of GMO DNA from the final product.

Past public comments for relisting were mostly in favor. Some comments expressed a concern that 

because of the chemical reactions in the purification process lactic acid should be considered synthetic.

Additional information requested by Subcommittee: None

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Calcium chloride

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(a) Nonsynthetics allowed: Calcium chloride.

Technical Report: 1995 TAP

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 03/2010 

sunset recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from subcommittee: 

Use: Used in a wide variety of food processing applications including as a firming agent (in tofu, cut fruit 

and canning applications), as a sodium replacement, to adjust water mineral content in brewing 

applications and as a nutritional electrolyte application. 

Manufacturing: Calcium chloride can be obtained by extraction of nonsynthetic brines. When calcium 

chloride is extracted from a nonsynthetic source, its molecular structure is not changed during 

extraction and thus should be classified as nonsynthetic. The starting material is a natural brine solution 

that is pumped out from underground salt beds. Synthetic materials are used in the purification process, 

but without changing the chemical structure of the material. Calcium chloride may also be commercially 

obtained as a byproduct in the ammonia-soda (Solvay) process (TR 2015)

International: Calcium chloride is allowed for use with various annotations under the Canadian, EU, 

Japanese, IFOAM and Codex standards.

Discussion: None

Additional information requested by Subcommittee:

Is this material currently in use by the organic food processing industry and in what applications? 

Dairy cultures

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(a) Nonsynthetics allowed: Dairy cultures.

Technical Report: 1995 TAP; 2014 TR for Ancillary Substances

Petition(s): N/A

Past NOSB Actions: 05/2003 NOSB minutes and vote; 11/2005 sunset recommendation; 03/2010 sunset 

recommendation; 10/2015 NOSB Final Review

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Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from subcommittee: 

Use: Dairy cultures are used by organic dairy processors to make yogurt, cheese, cultured sour cream 

and other fermented milk products. The use of these cultures can increase the digestibility of milk 

products, create different flavors and textures, and provide potential health benefits to the consumer.

Manufacture: There are a variety of ways a dairy culture can be produced but generally a dairy or other 

medium is inoculated with a sample of the fermented food to produce a starter culture. Different 

microbiological species produce different flavor compounds and in turn produce different traditional 

dairy products. 

International: According to the 2014 TR on microorganisms, there is widespread international 

acceptance of microorganisms and dairy cultures: 

European Union: Article 19 states, “The following conditions shall apply to the composition of organic 

processed food: ...(b) only additives, processing aids, flavorings, water, salt, preparations of microorganisms and enzymes...may be used, and only in so far as they have been authorized for use in organic 

production in accordance with Article 21.” “In addition, the products and substances referred to in 

Article 19(2)(b) are to be found in nature and may have undergone only mechanical, physical, biological, 

enzymatic or microbial processes, except where such products and substances from such sources are 

not available in sufficient quantities or qualities on the market.” 

Canada - Canadian General Standards Board Permitted Substances List: Microorganisms are permitted 

in organic processed foods as nonorganic ingredients that are not classified as food additives. This 

appears in 32.311 Table 6.4 as follows: “Microorganisms (processing derivatives) derived from genetic 

engineering or with the addition of chemosynthetic substance are prohibited.”

CODEX Alimentarius Commission, Guidelines for the Production, Processing, Labeling and Marketing of 

Organically Produced Foods (GL 32-1999) Joint FAO/WHO Food Standards Programme: Microorganisms, 

probiotics, and enzymes are allowed for use as additives and processing aids. “Substances found in 

nature from biological/enzymatic processes and microbial processes (e.g., fermentation)” are allowed

for use “as additives or processing aids in the preparation or preservation of food” (Section 5.1(c)). Any 

preparation of microorganisms can be used in food processing except those derived from genetic 

engineering (Table 3.4). 

European Economic Community (EEC) Council Regulation: EC No. 834/2007 and 889/2008: 

Microorganisms and enzymes “normally found in food processing” are permitted for use (Article 

2y(1)(b)). 

Japan Agricultural Standard (JAS) for Organic Production: Microorganisms do not specifically appear in 

the JAS standard for Organic Processed Food (Article 3) nor they considered food additives (Table 1). 

However, the JAS Standard includes language that indicates that microorganisms are allowed (see the 

TR for more details). 

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International Federation of Organic Agriculture Movements (IFOAM): The IFOAM standard, Section 

7.2.5, states, “preparations of micro-organisms and enzymes commonly used in food processing may be 

used, with the exception of genetically engineered micro-organisms and their products. 

Ancillary Substances: Ancillary substances may be present in dairy cultures. Ancillary substances for 

microorganisms primarily include the growth media used to produce the microorganism and then fillers 

or carriers to bring the microorganisms to purchasers in a stable and predictable form. Additional 

preservatives or anti-caking agents are used with some species. 

The Handling Subcommittee put forth a document listing the ancillary substances permitted for use in 

dairy cultures in 2015. These include: 

Functional class Substance name 

Anti-caking & anti-stick agents magnesium stearate, calcium silicate, silicon dioxide 

Carriers and fillers, agricultural or 

nonsynthetic 

lactose, maltodextrins, sucrose, dextrose, potato starch, non-GMO 

soy oil, rice protein, grain (rice, wheat, corn, barley) flour, milk, 

autolyzed yeast, inulin, cornstarch, sucrose. 

Carriers and fillers, synthetic 

micro-crystalline cellulose, propylene glycol, stearic acid, dicalcium 

phosphate. potassium phosphate, potassium sulfate, tricalcium 

phosphate. 

Preservatives sodium benzoate, potassium sorbate, ascorbic acid, sodium 

formate 

Stabilizers maltodextrin 

Cryoprotectants used to freeze-dry 

(& freeze) microorganisms and Dairy 

Cultures 

liquid nitrogen, maltodextrin, magnesium sulfate, dimethyl 

sulfoxide, sodium aspartate, mannitol, sorbitol , polysorbate 

Substrate that may remain in final 

product 

milk, lactose, grain (rice, barley, wheat) flour, brewed black tea 

and sugar, soy 

That document noted that use of these ancillary substances had not been found to cause negative 

effects. Additionally, as with all organic materials, any culture that is genetically modified is disallowed. 

Discussion: 

Dairy cultures have been a staple in food production for centuries and they are generally viewed as a 

necessary input for organic production of certain dairy products. They pose minimal health risks, and in

many cases can enhance health. In the October 2015, NOSB review of dairy cultures comments were 

received from trade associations, industry, certifiers and a technical organization. All comments were 

generally in favor of continued allowance of dairy cultures. The question was asked whether these 

should be listed separately or combined with microorganisms. Most industry stakeholders, while 

agreeing the dairy cultures were covered under microorganisms, still wanted a separate listing for dairy 

cultures. Several certifiers and a technical organization agreed that the listing of dairy cultures was 

redundant to microorganisms and could be removed. The ancillary substances used in dairy cultures has 

raised potential concerns about their compatibility with organic handling standards, but that has not 

prevented the support for continued listing of these cultures. 

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Additional information requested by Subcommittee:

1. Are there any additional ancillary substances not listed in the chart?

2. Is the dairy culture listing redundant and should it be combined with the microorganism listing?

Enzymes

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(a) Nonsynthetics allowed: Enzymes—must be derived from edible, nontoxic plants, 

nonpathogenic fungi, or nonpathogenic bacteria.

Technical Report: 1995 TAP; 1996 TAP; 2011 TR; 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 04/2011 sunset 

recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from subcommittee: 

Use: Enzymes are naturally occurring proteins that act as highly efficient catalysts in biochemical 

reactions. They are used to carry out naturally occurring biological processes that are useful in the 

processing of food products or ingredients. Commonly used in the production of sweeteners, chocolate 

syrups, bakery products, alcoholic beverages, precooked cereals, infant foods, fish meal, cheese and 

dairy products, egg products, fruit juice, soft drinks, vegetable oil and puree, candy, spice and flavor 

extracts, and liquid coffee, and are used for dough conditioning, chill proofing of beer, flavor 

development, and meat tenderizing. Enzymes can also be used to help reduce production costs, reduce 

the length of time required for aging foods such as cheese, clarify or stabilize food products, and control 

the content of alcohol and sugar in certain foods (Enzyme Technical Association 2001). (Technical Report 

2011 lines 140-148) 

Manufacture: Microbial rennet describes a coagulating agent produced by a specific type of mold, 

fungus, or yeast organism, grown and fermented in a lab. (TR 2011 466-467) 

Fermentation produced chymosin (FPC) rennet is derived from genetically modified organisms and is not 

allowed in organic agriculture. 

Bromelain is extracted from the pineapple’s fruit, stem, peel and juice. First the fruit is crushed. 

Bromelain is then further isolated, separated, and purified using chromatography, ultrafiltration, 

precipitation, freeze drying, and other procedures. (TR 2011 494-496) 

Pectinase is produced by the controlled fermentation of nonpathogenic and nontoxigenic strains of 

Aspergillus niger that are isolated from growth medium (FOA, 2000). (TR 2011 504-505) 

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International: 

Canadian General Standards Board: Permits the use of egg white lysozyme and animal-derived rennet 

in organic food processing. Animal-derived rennet is described as a nonorganic ingredient that is not 

classified as a food additive... Animal-derived enzymes, including rennet, should be from an organic 

source unless no such source is commercially available. The Canadian General Standards Board also 

permits the use of any preparations of enzymes normally used in food processing derived from edible, 

nontoxic plants, nonpathogenic fungi, or nonpathogenic bacteria. Therefore, the Canadian organic 

standards allow the use of pectinase and bromelain in organic food processing. 

The European Economic Community (EEC) Council: Regulation (EC) No 889/2008, Article 27, 1(b) 

indicates that the use of “enzymes normally used in food processing” is permitted in organic food 

processing practices (EC No 889/2008). This would include animal-derived rennet, egg white lysozyme, 

pectinase preparations from Aspergillus niger, and plant-based enzymes such as bromelain. 

The Codex Alimentarius Commission: Organic food guidelines allow preparations of microorganisms 

and enzymes, specifically, "any preparations of micro-organisms and enzymes normally used in food 

processing, with the exception of micro-organisms genetically engineered/modified or enzymes derived 

from genetic engineering" (Codex Alimentarius Commission, 1999; USDA, 2000). 

International Federation of Organic Agriculture Movements (IFOAM): Basic Standards considers 

enzymes acceptable for use in organic food processing provided they are based on the established 

Procedure to Evaluate Additives and Processing Aids for Organic Food Products (IFOAM, 2005; USDA, 

2003). These standards are generally parallel to the OFPA criteria. 

Ancillary substances: Explained in the Enzymes Technical Evaluation Report – Limited Scope, (NOP 

2015): 

“Enzyme products used in food processing may be single ingredient, stand-alone preparations of the 

enzyme, or formulated with other ingredients (OMRI, 2015). In many cases the enzyme product which 

results from a fermentation process is not effective in food applications without further formulation 

(Whitehurst & Van Oort , 2009). Enzyme preparations therefore commonly contain other substances, 

not only as incidental secondary metabolites and residual growth media from the enzyme production, 

but also intentionally added ingredients which function as diluents, preservatives, stabilizers, 

antioxidants, etc. (FDA, 2010). These additives must be generally recognized as safe (GRAS), or be FDA 

approved food additives for this use (FDA, 2014).” 

To prevent the loss of enzyme activity, ancillary substances, such as stabilizers, are added. This is 

especially true for liquid enzyme preparations due to the destabilizing effect of water. Stabilizers are 

also used to combat the degradation of enzyme structures due to autolysis or proteolysis. 

To control microbial contamination of enzyme preparations, preservatives are added. The development 

of alternatives to preservatives (plant extracts, peptides, compounds from herbs and spices) is 

increasing but there are microbial resistance challenges and the need for continued research. Currently 

it is unknown if natural preservatives are being used in any enzyme formulations. 

The following additional ancillary substances were identified through public comment during the last 

sunset review:

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Anti-caking & anti-stick agents: calcium stearate, magnesium silicate/talc, magnesium sulfate, sodium 

aluminosilicate. 

Carriers and fillers: calcium phosphate, calcium acetate, calcium carbonate, calcium chloride, calcium 

sulfate, dextrin, dried glucose syrup, ethyl alcohol, glucose, glycol, lactic acid, maltose, mannitol, mineral

oil, palm oil, propylene, purity gum (starch), saccharose, sorbitol, soy flour, soy oil, sunflower oil, 

trehalose, vegetable oil. 

Preservatives: alpha (hops) extract, benzoic acids and their salts, calcium propionate, citric acid, 

potassium chloride, potassium phosphate, sodium acetate, sodium chloride, sodium propionate, sodium 

sulfate, sorbic acid and its salts, stearic acid, tannic acid, trisodium citrate, zinc sulfate. 

Stabilizers: betaine (trimethylglycine), glucose, glycerol, sodium chloride, sodium phytate, sorbitol, 

sucrose. 

pH control, buffers: acetic acid, citric acid anhydrous, sodium citrate, sodium phosphate, trisodium 

citrate. 

Discussion: During the last sunset review in 2015, a variety of organizations and manufacturers 

commented in support of keeping enzymes on the National List. There were no commenters opposed. 

One organization suggested that enzymes be classified as synthetic unless annotated to define those 

that have not undergone synthetic chemical change. 

The 2011 TR did not find the manufacture or use of enzymes to be harmful to the environment or 

biodiversity. Enzymes are used in small amounts, are biodegradable, and the release of enzymes into the 

environment is not an environmental concern. 

The 2011 TR did not find significant effects upon human health. Enzymes can remain active after they 

are digested and, as proteins, cause allergic reactions in sensitive individuals. FDA reports it is not aware 

of any allergic reactions associate with the ingestion of food containing enzymes commonly used in food 

processing (TR 2011 752- 758). 

Additional information requested by Subcommittee:

1. Are there any additional ancillary substances to list for enzymes?

L-Malic acid

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(a) Nonsynthetics allowed: L-malic acid (CAS # 97-67-6).

Technical Report: Malic Acid April 2003; 2019 TR pending (to be posted at 

https://www.ams.usda.gov/rules-regulations/organic/national-list/l) 

Petition(s): L-Malic Acid 11/01/02 

Past NOSB Actions: 05/2003 sunset recommendation; 11/2009 sunset recommendation 

Recent Regulatory Background: Added to National List 09/11/06 (71 FR 53299)

Renewed 08/03/2011 (76 FR 46595); Renewed 09/12/16 (81 FR 8821) 

Sunset Date: 9/12/2021

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Background from Subcommittee: 

Use: 

There are two forms of Malic acid, D-Malic and L-Malic. D-Malic acid is not approved on the National List 

because a non-synthetic viable alternative is available. (TAP 2003). L-Malic acid is used as a flavor 

enhancer, flavoring agent and adjuvant, and as a pH control agent in a variety of foods to inhibit 

bacterial growth. Malic acid is more versatile for commercial black tea production and storage than citric 

acid. There are no alternatives to malic acid for this application. 

Approximately 55% of all industrially produced L-Malic acid is used in beverages, and 20% is used in 

food. 

GRAS: Title 21, Chapter 1, Part 184 of the Code of Federal Regulation Direct food substances affirmed as 

generally recognized as safe (GRAS), except for use in infant foods. Is approved for use as a Flavor 

enhancer, flavoring agent, adjuvant, and pH control agent (included in Appendix A, Exhibit 2).

OMRI: Organic Materials Review Institute includes malic acid on the January 2001 Processing

and Handling Materials OMRI Generic Materials list as an allowed non-organic ingredient.

(included in Appendix A, Exhibit 3)

Pennsylvania Certified Organic - approved use of Malic Acid by Honest Tea through 12/31/02,

and during petitioning process until September 31, 2003 (letter of initial approval included in

Appendix A, Exhibit 4)

Manufacture: 

L-Malic acid is the natural form of malic acid occurring in fruits such as apples and cherries. It is 

produced by the fermentation of fumaric acid. Fumaric acid can be produced by fermentation from 

glucose. 

International Acceptance: 

CODEX: Malic Acid meets the specifications of the Food Chemicals Codex, 3rd Edition (1981)

pp. 183-184. Available from the National Academy Press, 2101 Constitution Ave., NW.

Washington, D.C. 20418 (included in Appendix A, Exhibit 1).

Canada: CAN/CGSB-32-310 - National Standard of Canada Organic Agriculture - Malic acid

is allowed without restriction in Appendix D, Permitted Substances List for Processing

(Appendix 4) (included in Appendix B, Exhibit 1)

Australia: the Organic Federation of Australia Inc.’s guide to the Use of the National Standard for 

Organic Produce includes malic acid as a substance approved for post-harvest/ storage requirements.

Europe: EU 2092/91 - UKROFS Standards for Organic Food Production - Malic acid is

approved as an allowed material for organic food processing in Annex VI, section A with no

restrictions (included in Appendix B, Exhibit 2).

Japan: Japanese Agricultural Standard of Organic Agricultural Product Processed Foods - 

Malic acid is allowed to be used as a food additive without restriction in Article 5, Food

Additives Table 1, Appendix B (included in Appendix B, Exhibit 3).

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Environmental Issues: 

Malic acid is sometimes combined with citric acid to make a mild pesticide. Because it is easily 

metabolized in the body and occurs naturally in many fruits, there are no known reports of animal or 

human toxicity (Cornell Cooperative Extension 2016).

Malic acid is listed on the EPA active chemical code report with no restrictions. Prolonged exposure can 

result in dermatitis.

Discussion:

The NOSB received public comment in 2014 from one certifier with 7 current clients using L-Malic acid in 

the wine, juice and bottled tea sectors. Another large producer gave comment confirming their current 

use and need for this substance. Two other commenters expressed concern that the original TAP review 

evaluated DL-malic acid, the synthetic form, rather than L-malic acid, the non-synthetic form currently 

listed. However, a review of the 2003 TAP shows that the reviewers very clearly accounted for the fact 

that there are two forms of this substance, and recommended that the synthetic form not be listed, and 

that L-malic acid be listed on 205.605(a). 

L-Malic acid (CAS #97-67-6) was added to the National List (Federal Register Vol. 71, No. 175) 

§205.605(a) on September 11, 2006. This addition was based on a review of L-malic acid by the NOSB at 

its May 13-14, 2003 meeting. This material underwent its first sunset review at the Fall 2009 NOSB 

meeting and was relisted. The 2009 Subcommittee review indicated that there are no ancillary 

substances. There have been no ancillary substances declared by stakeholders during the public 

comment periods (both oral and written). 

In 2014 the Handling Subcommittee requested a TR, but one was not contracted. A TR was contracted in 

2018 and is currently pending. 

Additional information requested by Subcommittee: None

Magnesium sulfate

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(a) Nonsynthetics allowed. Magnesium sulfate, nonsynthetic sources only. 

Technical Report:1995 TAP ; 2011 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 04/2011 sunset 

recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

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Background from subcommittee: 

Use:

Magnesium Sulfate has a wide variety of uses in food processing and personal care products. It is used 

as a firming agent in the production of tofu. According to the 2011 technical report (TR), magnesium 

sulfate is sometimes combined with other coagulators in the production of tofu. Natural nigari (derived 

from seawater) is a popular coagulant in Japan that contains magnesium sulfate and a number of other 

minerals. Nigari is predominantly magnesium chloride, with much smaller amount of magnesium 

sulfate, sodium chloride, potassium chloride, and other minerals. However, natural nigari is not 

approved by the FDA for use in the US and is not generally recognized as safe (GRAS). Magnesium 

sulfate is also used as a nutrient in salt-replacer products, dietary supplements, carbonated beverages, 

sports drinks and fortified water beverages, and as a fermentation and malting aid in beer, ale, and 

other malt beverages.

Magnesium sulfate is generally regarded as safe (GRAS), listed at 21 CFR 184.1443. The Food and 

Nutrition Board, an organization established by the Institute of Medicine that provides guidance to the 

public and policy makers on nutrition and food sciences, has recommended that cereal grain products 

be fortified with magnesium in response to the potential risk of deficiency among significant segments 

of the population. A common name for magnesium sulfate is Epsom salt.

Manufacture: 

Several mineral forms of magnesium sulfate are recovered from the ground. The magnesium sulfate 

generally found in nature is in the hydrated form (i.e., contains water). Specifically, magnesium sulfate 

monohydrate and magnesium sulfate heptahydrate occur in nature as the minerals kieserite 

(MgSO4•H2O) and epsomite ((MgSO4•7H2O), respectively.

International: 

The Canada Food Inspection Agency, Food and Drug Regulations permit the use of non-synthetic sources 

of magnesium sulfate, which are classified as a food additive. Sulfates produced using sulfuric acid are 

prohibited.

Ancillary Substances: 

None identified.

Discussion: 

The 2011 TR notes that dietary doses of magnesium generally do not pose health risks. The TR does not 

fully address the environmental impact of mined forms of magnesium sulfate, noting it is not mined in 

the U.S. and therefore mining-related impacts are not an issue in the U.S. The TR does not address 

international mining impacts.

A number of alternative coagulants can be used in tofu production; however, these alternatives will 

affect texture, chewiness, color and other properties of the final product.

Calcium sulfate can be used in beer processing as an alternative to magnesium sulfate to increase water 

hardness and its mined form is on the National List.

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While many other flavor enhancers are on the National List, it is unclear if any of these substances are 

suitable alternatives to magnesium sulfate.

Additional information requested by Subcommittee: 

Is this material still essential to organic production?

Microorganisms

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(a) Nonsynthetics allowed: Microorganisms—any food grade bacteria, fungi, and

other microorganism. 

Technical Report: 2003 TAP; 2014 TR; 2015 Ancillary Substances

Petition(s): 2002 petition

Past NOSB Actions: 09/2002 minutes and vote; 11/2009 sunset recommendation

Recent Regulatory Background: Added to National List with annotation 09/11/06 (71 FR 53299)

Renewed 08/03/2011 (76 FR 46595); Renewed 09/12/16 (81 FR 8821)

Sunset Date 9/12/2021

Background from Subcommittee: 

Use: 

Microorganisms used in organic handling include those that are used as probiotics, for fermentation, 

and bacteriophages used for food safety. Microorganisms are used by organic processors to make many 

well-known products including miso, shoyu, sake, and yogurts. The use of these microorganisms can 

increase the digestibility of products, create different flavors and textures, and provide potential health 

benefits to the consumer. Additionally, bacteriophages can work to decrease harmful food organisms 

and increase the safety of processed foods.

Manufacture: 

There are a variety of ways microorganisms can be produced. As noted in the 2014 technical report 

(TR), generally a medium is inoculated with a sample of the fermented food to produce a starter culture. 

Different microbiological species produce different flavor compounds and in turn produce different 

products. Depending on the organism desired, different mediums ranging from milk products to rice 

may be used to create the starter culture. After a culture is generated, the starter culture may be 

inoculated directly into a product that will be altered by the microorganisms or the culture may be 

preserved by drying, encapsulating, freezing or other method and used at a later time in the handling 

process. 

International: 

According to the 2014 TR on microorganisms, there is widespread international acceptance of 

microorganisms: 

European Union: Article 19 states, “The following conditions shall apply to the composition of organic 

processed food: ...(b) only additives, processing aids, flavorings, water, salt, preparations of microorganisms and enzymes...may be used, and only in so far as they have been authorized for use in organic 

production in accordance with Article 21.” “In addition, the products and substances referred to in 

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Article 19(2)(b) are to be found in nature and may have undergone only mechanical, physical, biological, 

enzymatic or microbial processes, except where such products and substances from such sources are 

not available in sufficient quantities or qualities on the market.” 

Canada - Canadian General Standards Board Permitted Substances List: Microorganisms are permitted 

in organic processed foods as nonorganic ingredients that are not classified as food additives. This 

appears in 32.311 Table 6.4 as follows: “Microorganisms (processing derivatives) derived from genetic 

engineering or with the addition of chemosynthetic substance are prohibited.”

CODEX Alimentarius Commission, Guidelines for the Production, Processing, Labeling and Marketing of 

Organically Produced Foods (GL 32-1999) Joint FAO/WHO Food Standards Programme: Microorganisms, 

probiotics, and enzymes are allowed for use as additives and processing aids. “Substances found in 

nature from biological/enzymatic processes and microbial processes (e.g., fermentation)” are allowed 

for use “as additives or processing aids in the preparation or preservation of food” (Section 5.1(c)). Any 

preparation of microorganisms can be used in food processing except those derived from genetic 

engineering (Table 3.4). 

European Economic Community (EEC) Council Regulation: EC No. 834/2007 and 889/2008: 

Microorganisms and enzymes “normally found in food processing” are permitted for use (Article 

2y(1)(b)). 

Japan Agricultural Standard (JAS) for Organic Production: Microorganisms do not specifically appear in 

the JAS standard for Organic Processed Food (Article 3) nor they considered food additives (Table 1). 

However, the JAS Standard includes language that indicates that microorganisms are allowed (see the 

TR for more details). 

International Federation of Organic Agriculture Movements (IFOAM): The IFOAM standard, Section 

7.2.5, states, “preparations of micro-organisms and enzymes commonly used in food processing may be 

used, with the exception of genetically engineered micro-organisms and their products. 

Ancillary Substances: Ancillary substances may be present in microorganism cultures. Ancillary 

substances for microorganisms primarily include the growth media used to produce the microorganism 

and then fillers or carriers to bring the microorganisms to purchasers in a stable and predictable form. 

Additional preservatives or anti-caking agents are used with some species. 

The Handling Subcommittee put forth a document listing the ancillary substances permitted for use in 

dairy cultures in 2015. These include: 

Functional class Substance name 

Anti-caking & anti-stick agents magnesium stearate, calcium silicate, silicon dioxide 

Carriers and fillers, agricultural or 

nonsynthetic 

lactose, maltodextrins, sucrose, dextrose, potato starch, non-GMO 

soy oil, rice protein, grain (rice, wheat, corn, barley) flour, milk, 

autolyzed yeast, inulin, cornstarch, sucrose. 

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Carriers and fillers, synthetic 

micro-crystalline cellulose, propylene glycol, stearic acid, dicalcium 

phosphate. potassium phosphate, potassium sulfate, tricalcium 

phosphate. 

Preservatives sodium benzoate, potassium sorbate, ascorbic acid, sodium 

formate 

Stabilizers maltodextrin 

Cryoprotectants used to freeze-dry 

(& freeze) microorganisms and Dairy 

Cultures 

liquid nitrogen, maltodextrin, magnesium sulfate, dimethyl 

sulfoxide, sodium aspartate, mannitol, sorbitol , polysorbate 

Substrate that may remain in final 

product 

milk, lactose, grain (rice, barley, wheat) flour, brewed black tea 

and sugar, soy 

That document noted that use of these ancillary substances had not been found to cause negative 

effects. Additionally, as with all organic materials, any culture that is genetically modified is disallowed.

Discussion: 

Microorganisms have been a staple in food production for centuries and they are generally viewed as a 

necessary input for organic production of many products. They pose minimal health risks, and in many 

cases can enhance health. As noted in the 2014 TR, the health effects can be expressed directly through 

the interactions of the ingestion of the live microorganisms (probiotic effect) or indirectly as the result of 

ingesting the metabolites synthesized by the microbes during fermentation (biogenic effect). Foodgrade bacteria may also be used for improved vitamin production, raw food materials are often fortified 

with food grade bacteria that produce an excess of B vitamins in situ and bacteriophages are utilized as 

an antimicrobial to control bacteria during the production of foods on the farm, on perishable foods 

post- harvest, and during food processing (2014 TR).

Potential concerns have been raised about ancillary substances used in cultures and their compatibility 

with organic handling standards. Functional foods may contain a combination of probiotic culture with 

a prebiotic substrate that favors its growth (2014 TR). The use of ancillary substances has not prevented 

the relisting and general support for microorganisms. In general, they have not been implicated in 

negative health effects, but are something that should be continually monitored. 

In general, microorganisms are essential to the production of many organic foods and they are widely 

used in the industry.

Additional information requested by Subcommittee:

1. Are there any additional ancillary substances not listed in the chart?

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Perlite

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(a) Nonsynthetics allowed: Perlite—for use only as a filter aid in food processing.

Technical Report: 1996 TAP

Petition(s): N/A

Past NOSB Actions: 09/1996 NOSB minutes and vote; 11/2005 sunset recommendation; 03/2010 sunset 

recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022 

Background from Subcommittee: 

Use:

Perlite is used as a filter aid in food processing, such as filtration of juices, beer, wine, and vegetable oils.

Manufacture: 

Perlite is an amorphous volcanic glass that occurs naturally and is sourced primarily from mines in the 

U.S., Greece, Turkey and China. The high-water content of the mineral causes it to expand many times 

its original volume when exposed to temperatures of 850-900 °C.

International: 

Canada General Standards Board Permitted Substances List allows the use of perlite as a filtering aid.

Codex Alimentarius lists perlite as a processing aid which may be used for the preparation of products of 

agricultural origin.

European Economic Community Council Commission Regulations (EC) No 834/2007 lists perlite for the 

preparation of foodstuffs of plant origin. In reference to use in foodstuffs of animal origin, its use is 

limited to gelatin.

IFOAM Norms Appendix 4 – Table 1 lists perlite as allowed for use as a processing and post-harvest 

handling aid. 

Japan Ministry of Agriculture, Forestry, and Fisheries limits the use of perlite for processed foods of 

plant origin.

UK Soil Association Standards for Food and Drink lists perlite for the preparation of foodstuffs of plant 

origin. In reference to use in foodstuffs of animal origin, its use is limited to gelatin.

Ancillary Substances: 

None identified.

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Discussion:

The listing of perlite has been consistently supported by the NOSB and organic stakeholders. There is 

some concern with the potential human health hazard of inhalation of fine silica dust when using this 

material. Personal protective equipment such as a dust mask can minimize this risk.

Additional information requested by NOSB: 

Is this material still essential to organic production?

Potassium iodide

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(a) Nonsynthetics allowed: Potassium iodide. 

Technical Report: 1995 TAP; 2011 TR 

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 04/2011 Formal 

recommendation by the NOSB; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from subcommittee: 

Use: Potassium iodide is used as a form of iodine in trace mineral supplements. Iodine is an essential 

component of the thyroid hormones that regulate basal metabolism. Iodine deficiency causes thyroid 

enlargement (goiter), mental retardation that can be severe (cretinism in 10% of the population), and 

hypothyroidism. The developing brain is the most sensitive organ; iodine deficiency reduces IQ by 13.5 

points. Iodization of salt completely eliminated new cases of cretinism in Switzerland. According to FDA, 

potassium iodide may be used as a food additive in the following functions:

• A nutrient in table salt as a source of iodine

• A dietary supplement for human consumption and in animal feeds.

• A sanitizing agent for food processing equipment. (2015 TR pg 15)

Manufacture: Potassium iodide can be refined nonsynthetically from sea water and salt deposits. It can 

be produced synthetically by reacting hydriodic acid with potassium bicarbonate or by electrolysis of 

hydriodic acid and potassium bicarbonate or, industrially, by treating potassium hydroxide with iodine. 

[21 CFR 184.1634] (2015 TR pg 27).

International: Nonsynthetic potassium iodide is listed on the Canadian standards for use where required 

by law and the synthetic form is allowed in products in the 70-95% category. It could be used under the 

EU/Codex standards where required elsewhere by law. It is not listed on the Japanese or IFOAM 

standards. 

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Discussion: In the past public comment has been limited. It is unclear if potassium iodide is being used 

for sanitizing purposes or only as a dietary supplement. 

Additional information requested by Subcommittee:

1. Is potassium iodide utilized as a sanitizing agent for food processing equipment? If so, in what 

applications? 

2. If potassium iodide is used for nutritional supplementation only – is this substance redundant to 

the current Nutrient Vitamin and Mineral listing? If so, should this separate listing be removed?

3. Are certifiers limiting the use of potassium iodide to non-synthetic forms even with the 

205.605(b) synthetic allowance for Nutrient Vitamin and Mineral listing? 

Yeast

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(a) Nonsynthetics allowed: Yeast—When used as food or a fermentation agent, 

yeast must be organic if its end use is for human consumption; nonorganic yeast may be used when 

equivalent organic yeast is not commercially available. Growth on petrochemical substrate and sulfite 

waste liquor is prohibited. For smoked yeast, nonsynthetic smoke flavoring process must be 

documented.

Technical Report: 1995 TAP (Smoked Yeast); 1995 TAP (Baker’s Yeast); 2014 TR

Petition(s): 2006 Petition; 2010 Petition Supplement; 2010 Petition memo 

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 3/2007 NOSB 

committee recommendation; 10/2010 sunset recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290): Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from subcommittee: 

Use: 

Yeast is a microorganism that is commonly used for fermentation, baking, food flavors, adding 

nutritional value, and providing health benefits. Yeasts are in kingdom Fungi and are single celled 

eukaryotic organisms. They utilize organic materials for energy by releasing enzymes that digest organic 

matter or by absorbing simple molecules directly through their cell walls. Yeasts differ from other fungi, 

such as molds and mushrooms, in that they exist as individual cells rather than forming hyphae that 

interconnect with other cells.

In general, yeast species (brewer’s yeast) used in anaerobic conditions are for fermentation whereby 

they convert sugars to ethanol. This process includes ciders, beers, wines, and distilled spirits. Other 

uses for yeast are generally in aerobic conditions where they may be used as leavening agents (baker’s 

yeast), for the addition of vitamins or minerals (nutritional yeast, chromium yeast, selenium yeast, 

torula yeast), as probiotics that may prevent or treat pathological conditions (probiotic yeast), and for 

flavoring (smoked yeast, torula yeast) (2014 TR). As the TR notes, they may be used synergistically or in 

conjunction with bacteria or other materials to create specific foods such as when kombucha is 

fermented with yeast and acetic acid bacteria to create fermented, sweetened tea.

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The way the yeast is used in processing as well as the action of the yeast depends on the type of end 

products produced as well as the specific type of yeast being utilized. 

Manufacture: Many yeasts are ubiquitous in the environment and in some cases handlers use these wild 

yeasts to make breads or for fermentation. However, since most handlers prefer more control over the 

specific type and strain of yeast that is utilized, most yeasts are grown under controlled conditions and 

then sold to end users. Typically, yeast is grown in a lab environment so as to prevent contamination 

from undesirable or pathogenic organisms. The lab grown yeast is then used to inoculate growth media 

for industrial production (2014 TR). In a number of cases there are several iterations of inoculation and 

addition of growth media in order to achieve the desired quantities. The yeast may then be used 

directly for food production or be concentrated and packaged for future use. Traditionally, smoked 

yeast is made by passing smoke through dried yeast but it may also be manufactured using chemical 

processes. This necessitated the annotation that when smoked yeast is used, documentation that the 

yeast is smoked by natural processes must be submitted by the user. 

International: According to the 2014 TR, yeast is listed separately as an allowed substance in Canada 

and the European Union whereas it is indirectly referred to by CODEX Alimentarius, Japan and IFOAM. 

Listed below are excerpts from the TR listings – refer to the TR for additional details. 

Canadian General Standards Board: Table 6.4, titled “Non-organic Ingredients Not Classified as 

Food Additives” of the Canadian Permitted Substance List states that only non-synthetic yeast is 

allowed in organic handling. The types of yeast include “autolysate, bakers’ (may contain lecithin, 

obtained without the use of bleaches and organic solvents), brewers’, nutritional, and smoked. 

Non-synthetic smoke flavouring process shall be documented. Growth petrochemical substrate and 

sulfite waste liquor are prohibited.” 

CODEX Alimentarius: Yeast in the CODEX Alimentarius does not appear separately as it does in the 

USDA organic regulations. Under Additives and Processing Aids, "probiotics, microorganisms and 

enzymes are allowed." GL 32-1999 section 3.4 states that “any preparations of microorganisms and 

enzymes normally used as processing aids in food processing” are permitted for use “with the 

exception of genetically engineered/modified organisms and enzymes derived from genetically 

engineered/modified organisms.” 

European Economic Community Council: Article 20 allows for the labeling of organically produced 

yeast as organic, and states that "only organically produced substrates are to be used for the 

production of organic yeast and organic yeast should not be present in organic food or feed 

together with non-organic yeast" 

Japan Agricultural Standard (JAS): The JAS Standard for Organic Processed Food does not 

specifically identify the allowance for yeast, in Table 1: Food Additives of the Japanese Agricultural 

Standard for Organic Processed Foods (Japanese Agricultural Standard for Organic Processed Foods 

(Notification No. 1606) 2005). However, the standard includes the following language that indicates 

that microorganisms, including yeasts, are allowed: “Only physical method or method using

biological function (except for those produced by the recombinant DNA technology; hereafter the 

same) shall be used for the manufacturing or processing.” 

International Federation of Organic Agriculture Movements (IFOAM): Yeast is permitted in 

IFOAM per Section 7.2.5 which states that “preparations of micro-organisms and enzymes 

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commonly used in food processing may be used, with the exception of genetically engineered 

micro-organisms and their products. Cultures that are prepared or multiplied in-house shall comply 

with the requirements for the organic production of microorganisms.” 

Ancillary Substances: According to the 2014 TR, there are a few yeast species that are formulated with 

no ancillary substances, however, many commercially available yeasts are formulated with other 

ingredients. These substances, such as ascorbic acid, may be listed on the National List. However, other 

ancillary ingredients not appearing on the National List are routinely combined with yeast on a 

commercial scale. These may be water, emulsifiers, and cutting oils. The compounds used for 

emulsifiers are enumerated in the TR (2014 TR) and that extensive list should be referred to for specific 

details of ancillary substances in yeast products. During the prior sunset review in 2015, the following 

functional classes were reviewed for ancillary substances in yeasts: Antioxidants, preservatives, 

emulsifiers, defoaming agents, and substrate that may remain in the final product. It was suggested that 

starch be added to this list during that review. One substance on the chart, BHT, was questioned as 

being problematic with regard to exposure.

Discussion: Yeast is widely used and has been for centuries. Many organic products rely on the use of 

yeast for their distinctive features and characteristics. While there has been broad support for the 

relisting of yeast on the National List in past reviews, significant discussion has been centered on 

ancillary substances and whether organic forms of yeast are available. Yeast underwent a significant 

review that led to a change in the listing in 2010. The 2014 technical review added information about 

the current status of various yeasts and looked at the ancillary substances. As part of the prior sunset 

review many commenters noted that organic yeast forms are readily available, but that for certain uses 

there are some forms that are not yet organically produced in sufficient quantity or quality. These 

included torula yeast, nutritional yeast for livestock feed, gluten-free yeast, fresh yeast, and some types 

of wine yeast. This led to the extensive annotation on the National List for the yeast. 

During the prior sunset review in 2015, the following functional classes were reviewed for ancillary 

substances in yeasts: Antioxidants, preservatives, emulsifiers, defoaming agents, and substrate that may 

remain in the final product. It was suggested that starch be added to this list during that review. One 

substance on the chart, BHT, was questioned as being problematic with regard to exposure.

Finally, it should be noted that while yeast itself is often considered as a minimal risk material to both 

the environment and in use, there can be negative environmental impacts from the manufacturing 

processes used to create yeast formulations. Appropriate mitigation strategies for these impacts, such 

as the emissions of acetaldehyde and ethanol, exist and when appropriately used minimize 

environmental impact (2014 TR).

Additional information requested by Subcommittee:

1. Are there still types or forms of organic yeast that are not available in sufficient quality or 

quantity for production of organic products? Specifically, have organic forms of torula yeast, 

nutritional yeast for livestock feed, gluten-free yeast, fresh yeast, and some types of wine yeast 

become available since the last sunset review in 2015?

2. Have there been changes in ancillary materials added to yeast compounds since the 2014 TR?

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§205.605(b) Synthetics allowed:

Acid, Alginic

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: Alginic acid (CAS #9005-32-7).

Technical Report: 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 03/2010 sunset 

recommendation; 10/2015 sunset recommendation; 10/2015 formal recommendation (reclassification)

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420); Proposed rule 1/17/2018 (83 FR 2498); Reclassified effective 01/28/2019 (83 

FR 66559) 

Sunset Date: 01/28/2024

Background from subcommittee: 

Use:

Alginic acid is used in the food industry as an emulsifier, emulsifier salt, formulation aid, and thickening 

agent for soups and soup mixes. FDA limits the use of alginic acid as a stabilizer, emulsifier and thickener 

in soups and soup mixes. 

Manufacture:

Alginic acid is derived from wild harvested brown cold-water seaweeds. Alginic acid exists naturally in 

both brown seaweeds and two bacterial genera. However, alginic acid is manufactured on an industrial 

scale through a chemical separation process that involves the maceration, alkali treatment, and acid 

precipitation of alginic acid from brown seaweeds. In order to separate alginic acid from its salt form, it 

is subjected to numerous pH adjustments to promote ion exchange. These chemical processes result in a 

pure alginic acid and its classification as a synthetic. Since alginic acid is present in seaweeds in its 

calcium, sodium, magnesium or other salt forms, and not in the free acid form, the free acid form does 

not appear in nature (2015 TR – Alginic Acid, Lines 283-286). 

International Acceptance:

The 2015 TR noted the following:

Canadian General Standards Board - permits the use of alginic acid under the Organic Production 

Systems Permitted List as a non-organic food additive. It is also found in the same table under the 

heading Alginates. 

CODEX – alginic acid is permitted under the Guidelines for the Production of Organically Produced Foods 

as a food additive of non-agricultural origin for foods of plant origin. The General Standard for Food 

Additives within CODEX list a number of provisional uses that FDA does not identify such as a bulking 

agent, foaming gent, glazing agent, in various food types. 

European Economic Community (EEC) lists alginic acid as an approved food additive for use in the 

production of processed organic foods. 

Japan Agricultural Standards (JAS) allows alginic acid as a food additive limited to only processed foods 

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of plant origin. 

The International Federation of Organic Agriculture movements (IFOAM) lists alginic acid as an approved 

additive for use in organic processed products without any annotations.

Environmental Issues:

Alginic acid is derived from harvesting brown wild seaweed. There has been little research into 

production of alginic acid and alginates from a biological fermentation process. However, commercially 

available quantities are sourced from brown seaweed, (2015 Technical Review – Alginic Acid, Lines 299-

300). Most are derived from wild harvested seaweed, but some seaweed is cultivated. Brown seaweed 

is harvested in cold water. Recent public comments expressed concern of over-harvesting and the 

impact on local ecosystems. Some negative comments cited that wild harvested seaweed is a bioaccumulator of heavy metals and because alginic acid is used primarily to enhance texture in foods it is 

therefore not “essential” according to OFPA criteria. The 2015 TR did not cite any evidence supporting 

those concerns.

Discussion:

In the 1995 TAP review for alginic acid, reviewers determined the material was non-synthetic. However, 

given the Classification of Materials document (in draft form in 2015) and the information presented in 

the 2015 TR, it was recommended by the NOSB that alginic acid be reclassified as synthetic. In January 

2019, it was relisted from 205.605(a) nonsynthetic, to 205.605(b) synthetic. The majority of public 

comment from the 2015 sunset review was in favor of relisting of alginic acid. Those in favor of its 

relisting note the long history of use with no ill effects on either the human digestive system or on the 

ecosystem due to harvesting and assert that the properties imparted by alginic acid are essential for 

some processed food formulations. Those opposed cited that wild seaweed is a bio-accumulator of 

heavy metals, and over harvesting was detrimental to local ecosystems. The Board did recognize in 

October 2018 that further research may be needed on the sustainability of harvest practices. There was 

one public comment in October 2018 in favor of relisting alginic acid under 205.605(b) citing that 

harvesting practices of wild seaweed were safe and sustainable.

The Federal Register Notice published December 27, 2018, effective January 28, 2019 (Vol. 83, No.247, 

pp 66559-66574), amends the National List and moves Alginic Acid from 606.605(a), nonsynthetic 

substances allowed etc. to 606.605(b), synthetic substances allowed etc. The complete listing under 

205.605(b) is Alginic acid (CAS# 9005-32-7)

Additional information requested by Subcommittee:

1. Is there a way to assess whether or not current brown seaweed harvesting practices are 

sustainable or damaging to local ecosystems? 

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Activated charcoal

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: Activated charcoal (CAS #s 7440-44-0; 64365-11-3)—only 

from vegetative sources; for use only as a filtering aid.

Technical Report: 2002 TAP

Petition(s): 2002 petition 

Past NOSB Actions: 09/2002 sunset recommendation ; 11/2009 sunset recommendation.

Regulatory Background: 

Added to National List with annotation 9/11/06 (71 FR 53299); Renewed 8/03/2011 (76 FR 46595); 

Renewed 09/12/16 (81 FR 8821)

Sunset Date: 9/12/2021

Background from Subcommittee: 

Use:

Activated charcoal is used in processing as mechanical filtration involving the physical separation of 

suspended solids from a liquid passing through carbon arrayed as a porous media in a column or bed. 

This type of filtration is used as a taste and odor-removing agent and purification agent in water and 

food. Activated carbon has a very large surface area and pore volume that gives it its unique adsorption 

capacity.

Manufacture: 

Activated charcoal of vegetative origin can be made from a large variety of sources such as hardwoods, 

grain hulls, corn cobs and nut shells. The material undergoes pyrolysis at a very high heat. These 

agricultural byproducts may be chemically activated using a variety of acids and bases. Acids may be 

acetic acid, and potassium hydroxide and sodium hydroxide are possible bases. The charcoal may also 

be activated through exposure to oxygenated gas or steam.

International: 

Canada General Standards Board Permitted Substances List allows the use of activated charcoal as an 

ingredient classified as a food additive. Shall be of plant origin. Prohibited for use in the production of 

maple syrup.

Codex Alimentarius lists activated carbon as a processing aid which may be used for the preparation of 

products of agricultural origin.

European Economic Community Council Commission Regulations (EC) No 834/2007 lists activated 

carbon for the preparation of foodstuffs of plant origin.

IFOAM Norms Appendix 4 – Table 1 lists activated carbon as allowed for use as a processing and postharvest handling aid. 

Japan Ministry of Agriculture, Forestry, and Fisheries limits the use of active carbon for processed foods 

of plant origin.

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UK Soil Association Standards for Food and Drink lists charcoal for oenological use, with a restriction that 

limits use to musts and new wines still in fermentation, rectified concentrated grape must and white 

wines. No more than 100g dry production per hl.

Ancillary Substances: 

None identified.

Discussion: 

Activated charcoal has minimal impact on human health and the environment. It may cause respiratory 

problems for those who handle it, especially as the particle size decreases. Its use in processing doesn’t 

generally have an effect or chemical interaction in the agroecosystem. The greatest impact of activated 

charcoal from vegetative sources is the removal of organic matter from the system. 

Additional information requested by Subcommittee:

Is this material still essential to organic production?

Ascorbic acid

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: Ascorbic acid.

Technical Report: 1995 TAP; 2019 TR pending (to be posted at https://www.ams.usda.gov/rulesregulations/organic/national-list/a) 

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 04/2010 

sunset recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from Subcommittee:

Use: Ascorbic acid is used as a dietary supplement and nutrient, flavor ingredient, used in meat and 

meat containing products, curing and pickling, in flour to improve baking quality, as an antioxidant in 

fats and oils, and a wide variety of other food processing uses. Ascorbic acid is one of the most common 

sources of Vitamin C. It is also used in frozen and precut fruits as an antioxidant. Industrially produced Lascorbic acid is widely used in the feed, food, and pharmaceutical sector as a nutritional supplement and 

preservative, making use of its antioxidative properties.

Manufacture: 

The majority of industrial production of ascorbic acid is synthesized using the Reichstein and Grussner 

process which is a six-step process developed in the 1930’s that begins with D-glucose and involves 

hydrogenation, oxidizing, and treatment with acetone and then hydrogen chloride to yield L-ascorbic 

acid. Modern industrial production processes use fermentation with additional bio-oxidation steps 

adding a bio-catalyst which eliminates the need for the chemical steps. Synthetic ascorbic acid is 

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identical in molecular structure and in function to natural ascorbic acid. The majority of industrial 

production comes from China.

International Acceptance:

Ascorbic acid is GRAS as a chemical preservative (21CFR182.3013), a dietary supplement 

(21CFR182.5013), and nutrient (21CFR182.8013) when used in accordance with Good Manufacturing 

Practices. It is allowed by CODEX and the European Union. 

Environmental Issues: 

Ascorbic acid is considered non-toxic. The quantities needed to cause harm to humans are in the 

magnitude of one quart per 150 lbs. body weight. The potential for environmental pollution is slight (TR 

pp. 20).

Discussion: 

Ascorbic acid is a vital nutrient necessary for humans and other primates. Humans cannot synthesize 

Vitamin C and must rely on dietary intake. It is added to many foods to restore Vitamin C lost during 

processing (Fall 2015 pp. 1146). Some FDA regulations require Vitamin C fortification, which is often 

achieved with ascorbic acid. It is manufactured using a culture process from dextrose. 

Public comment for ascorbic acid was divided, with some comments remarking that ascorbic acid is 

being used as a preservative and therefore not consistent with organic agriculture. However, the 

majority of commenters strongly supported relisting of ascorbic acid, stating the ingredient to be 

critically essential to maintaining nutrients and freshness in their products (Ref: Transcript Fall 2015, 

pp.67-69). There is no known substitute in food processing. 

Additional information requested by Subcommittee:

(May be addressed in the pending TR). Is the modern industrial manufacturing process which utilizes 

additional bio-oxidation an excluded method?

Calcium citrate

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: Calcium citrate.

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 4/2010 sunset 

recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

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Background from Subcommittee:

Use: 

Calcium citrate is used as an ingredient in dietary supplements, although there are other calcium 

sources for supplementation purposes permitted at §205.605(b) under the listing Nutrient Vitamins and 

Minerals. Calcium citrate can be used as a sequestrant, buffer, antioxidant, firming agent, acidity 

regulator (in jams and jellies, soft drinks and wines), as a raising agent and an emulsifying salt. It is also 

used to improve the baking properties of flours and as a stabilizer. It can also be used as a water 

softener due to its chelation properties. It is used to wash processing equipment in order to eliminate 

off flavors, and as a pH adjuster and chelator in cleaning and sanitizing products. It is also used for its 

chelating properties to remove scale from boilers, evaporators and other processing equipment. 

Calcium citrate is widely used in cosmetic and personal care products for many of these same functions. 

Manufacture:

Calcium citrate is the calcium salt of citric acid. It is prepared by neutralizing citric acid with calcium 

hydroxide or calcium carbonate and subsequent crystallization. 

Citric acid is listed under 21 CFR 184.1195 as Generally Recognized as Safe (GRAS). It is prepared by 

neutralizing citric acid with calcium hydroxide or calcium carbonate. It is permitted in food with no 

limitations other than current good manufacturing practice. It is also permitted by FDA in infant formula. 

Calcium citrate is GRAS as listed at 184.1195

The EPA listed citric acid and its salts in the 2004 List 4A (minimal risk inerts). 

International: 

Allowed by Canada, European Economic Community (EEC) (as an ingredient in the preparation of foods 

of animal origin), and International Federation of Organic Agriculture Movements (IFOAM) (allowed as 

an additive). 

Ancillary Substances: 

According to the 2015 TR, citric acid and its salts (including calcium citrate) are commercially supplied as 

pure compounds and do not contain ancillary substances. 

Discussion: 

According to the 2015 TR, based on various toxicology studies, citric acid and its salts (including calcium 

citrate) are not expected to pose any significant health hazard upon ingestion. The manufacture of 

calcium citrate was not addressed in terms of potential harm to the environment. 

The TR cited the versatility of citric acid and its salts as the reason why no alternative practices could be 

used to substitute for all functions they provide. Additionally, there are no nonsynthetic sources or 

alternatives for the citrate salts

Additional information requested by Subcommittee: None

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Ferrous sulfate

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: Ferrous sulfate—for iron enrichment or fortification of 

foods when required by regulation or recommended (independent organization).

Technical Report: 1995 TAP; 2015 TR Nutrient Vitamins and Minerals

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from Subcommittee:

Use: Ferrous sulfate is commonly added to flours and cereal products to make an optional enriched 

claim and often found in baked products and infant snacks (oat cereal, teething biscuits, etc.). Iron is an 

essential component of hemoglobin, enzymes involved in energy metabolism, and other enzymes. 

Hemoglobin transports oxygen to body tissues. Iron deficiency leads to anemia, poor work performance 

and endurance, persistent cognitive and developmental impairment, increased maternal perinatal 

mortality and a greater rate of premature labor and delivery, and depressed immune function. (2015 

TR, pg 15)

Manufacture: Ferrous sulfate is made by reacting sulfuric acid with iron. [21 CFR 184.1315] (TR 2015, pg 

28)

International: Ferrous sulfate is listed on the Canadian standards for use where required or allowed, it 

could be used under the EU/Codex standards where required elsewhere by law. It is not listed on the 

Japanese or IFOAM standards. 

Discussion: It appears this material is solely used is as a nutritional additive to address population-based 

iron deficiency. 

Additional information requested by Subcommittee:

1. If applications are for nutritional supplementation only – is this substance redundant to the 

current Nutrient Vitamin and Mineral listing? If yes, should this item be removed?

Hydrogen peroxide

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: Hydrogen peroxide.

Technical Report: N/A (2015 TR Crops) 

Petition(s): N/A

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Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 04/2010 

sunset recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from Subcommittee:

Use: 

Hydrogen Peroxide (CAS# 7722-84-1) is a very simple molecule with a formula of H2O2. It is a weak acid 

but also a strong oxidizer which makes it an effective microbial pesticide for organic handling purposes. 

It is used as a disinfectant and sanitizer and also for post-harvest treatment of produce. USDA organic 

regulations currently allow the use of hydrogen peroxide in organic crop production under 7 CFR 

§205.601(a) as an algicide, disinfectant and sanitizer, and under 7 CFR 205.601(i) for plant disease 

control as a fungicide. Hydrogen peroxide is also permitted for use in organic livestock production as a 

disinfectant, sanitizer and medical treatment (7 CFR 205.603(a)). Lastly, synthetic hydrogen peroxide 

may be used as an ingredient in or on processed products labeled as “organic” or “made with 

organic(specified ingredients or food group(s)).” (7 CFR 205.605(b)).

Manufacture: 

According to the TR, commercially available hydrogen peroxide is industrially produced using the 

anthraquinone autoxidation (AO) process. The AO method involves initial catalytic reduction of an alkyl 

anthraquinone with hydrogen to form the corresponding hydroquinone. Subsequent autoxidation of the 

hydroquinone intermediate in air regenerates the anthraquinone with concomitant liberation of 

hydrogen peroxide. The simplified overall reaction involves direct combination of gaseous hydrogen 

(H2) and oxygen (O2): H2+ O2→H2O2

International: 

Canada: Allowed for many uses, including as food-grade cleaners, disinfectants and sanitizers” that are 

allowed without mandatory removal of residues, and “cleaners, disinfectants and sanitizers allowed on 

food contact surfaces including equipment, provided that substances are removed from food contact 

surfaces prior to organic production”

European Union: Allowed for similar uses to Canada and U.S. 

IFOAM: Allowed as cleanser and disinfectant among other uses.

Japan: Not listed.

Codex: Allowed as a cleanser and disinfectant among other uses

Ancillary substances: 

None. Inerts may include peroxyacetic acid (listed separately on the National List). The TR reports other 

potential materials including caprylic acid and mono-and di-potassium salts of phosphorous acid. 

Human Health and the Environment: 

Concentrated solutions may be corrosive to eyes, exposed skin, and mucous membranes. Warnings for 

high concentrations include:

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Corrosive. Causes irreversible eye damage. May be fatal if swallowed or absorbed through the skin. 

Causes skin burns or temporary discoloration on exposed skin. Do not breathe vapor. Do not get in eyes, 

on skin or on clothing. Wear protective eyewear such as goggles or face shield. Wash thoroughly with 

soap and water after handling. Remove and wash contaminated clothing before reuse.

Extensive toxicological testing of hydrogen peroxide has been completed, and it is unlikely to cause 

chronic systemic toxicity or reproductive, development, or carcinogenic effects. However, chronic 

exposure to vapors may damage lungs. Hydrogen peroxide is described to have low to moderate 

toxicity to aquatic invertebrates and no danger to fish. Because hydrogen peroxide is unstable and 

breaks down into water and oxygen gas, long-term impacts on the environment are unlikely. According 

to the TR, some toxic chemicals used to manufacture hydrogen peroxide including alkyl anthraquinones, 

aromatic solvents and metal catalysts (e.g., nickel and palladium) are removed from the product and can 

be returned to the reactors to make more product. Overall, this material is relatively safe but should be 

used according to FDA, USDA, and EPA labels and regulations.

Discussion: 

Like peracetic acid, this material has received strong support and has been consistently relisted on the 

National List. Its overall profile is relatively safe, especially compared to many other sanitizers, such as 

chlorine compounds, and when used appropriately should not have adverse impacts on human health 

and the environment. In summary, hydrogen peroxide is an important tool for handling. 

Additional information requested by Subcommittee:

Is this material still essential for the production and handling of organic products?

Nutrient vitamins and minerals

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: Nutrient vitamins and minerals, in accordance with 21 CFR 

104.20, Nutritional Quality Guidelines For Foods. 

Technical Report: 1995 TAP - Minerals; 1995 TAP - Vitamins; 2015 TR 

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 03/2011 

Handling Subcommittee Proposal; 04/2011 sunset recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from Subcommittee:

Use: Nutrient vitamins and minerals are used to recreate or add nutritional content to foods. 

Sometimes this nutritional content is added due to public health guidance (e.g. Iron in cereal to combat 

iron anemia), to mimic analog products (calcium fortification of non-dairy milks, fortification of infant 

formulas), to make up nutrients lost in processing (Vitamin A in skim milk) or for product marketing 

purposes (enriched flours). There are very few legally required fortified foods. Those that are required 

to be fortified are listed in the chart below, as noted in the 2015 technical review:

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Standards of Identity in Title 21 CFR that require Nutrient Fortification 

Food class Regulation Specific vitamins or minerals required by FDA 

Infant formula 21 CFR 107.100 All nutrients known to be essential and listed therein 

21 CFR 107.10 

Margarine 21 CFR 166.110 Vitamin A 

Milk 21 CFR Part 131 Vitamins A & D (required by some states) 

There are more food classes with standards of identity that allow for the use the fortification, however 

these fortifications are optional. It should be noted that foods eligible for the “Women, Infants and 

Children” federal programs may be required to be the fortified standard of identity form. 

Use of vitamins and minerals will depend on the application and the specific substances being used. 

These substances will often be processed with accessory additives to make the vitamins or minerals 

stable and useable in food applications.

Manufacturing: The 2015 technical review states:

According to Vandamme (Vandamme 1992), “vitamins are now either prepared chemically or 

biotechnologically via fermentation or bioconversion processes. Several vitamins and related 

biofactors are now (1992) only or mainly produced chemically (vitamin A, cholecalciferol (D3), 

tocopherol (E), vitamin 432 K2, thiamine (B1), niacin (PP or B3), pantothenic acid (B5), 

pyridoxine (B6), biotin (H or B8), folic acid (B9)]or via extraction processes (β-carotene or 

provitamin A, provitamin D3, tocopherol, vitamin F-group). However, for several of these 

compounds microbiological or algal methods also exist or are rapidly emerging. Other vitamins 

are produced practically exclusively via fermentation (ergosterol or provitamin D2, riboflavin 

(B2), cyanocobalamin (B12), orotic acid (B13), vitamin F-group ATP, nucleosides, coenzymes, 

etc.] or via microalgal culture (β-carotene, E, F). Both chemical and microbial processes are run 

industrially for vitamin B2, while vitamin C (ascorbic acid) is produced via a combination of 

chemical reactions and fermentation processes. In the past twenty-five years, numerous patents 

have been issued disclosing fermentations by genetically modified microorganisms to produce 

various water-soluble vitamins... As the above descriptions detail, most vitamin and mineral 

nutrients are synthetic substances, even including some with natural or agricultural origins... 

Most vitamins and minerals are not available from nonsynthetic sources.... The current National 

List listings creates confusion for those nutrient vitamins and minerals specifically listed at 

§205.605(a), which requires a nonsynthetic source, whereas “Nutrient vitamins and mineral” are 

a class of “allowed synthetics.” For example, the producer of a nutritional product may not be 

sure if supplemental magnesium as magnesium sulfate is restricted to a nonsynthetic source. “

The technical report details many individual manufacturing methods. 

International: The Codex and EU standards only allow the use of synthetic vitamins and minerals where 

required by law. The Canadian standards allow synthetic vitamins and minerals where required by law 

as well as in “non-dairy substitute products” on a “voluntary basis, if legally permitted.” Canadian 

standards also allow for the use of “Ferrous sulphate—Shall be used if legally required and may be used, 

on a voluntary basis, if legally permitted.” IFOAM allows by law or when “strongly recommended in 

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food products in which they are incorporated.” Japanese standards do not allow for vitamins and 

minerals (2015 TR, pg 20-21). All standards list some substances that may be considered vitamins and 

minerals (i.e. ascorbic acid or calcium carbonate) – the review above does not include these individual 

substances, just categorical listings. 

Discussion: 

Brief history: 

• In 1995 the NOSB added nutrient vitamins and minerals to the National List with the following 

annotation, ‘‘Accepted for use in organic foods for enrichment or fortification when required by 

regulation or recommended by an independent professional organization.’’ A second 

recommendation was also passed entitled ‘‘Final Recommendation Addendum Number 13, The Use of 

Nutrient Supplementation in Organic Food.’’ This stated, ‘‘Upon implementation of the National 

Organic Program (NOP), the use of synthetic vitamins, minerals, and/or accessory nutrients in 

products labeled as organic must be limited to that which is required by regulation or recommended 

for enrichment and fortification by independent professional associations.’’

• The final rule published in 2000 (65 FR 13512) included the current annotation. It was recognized soon 

after that the cross reference to the FDA’s fortification policy for food at 21 CFR 104.20 was not 

accurate and that a correction to the current listing was necessary. 

• In 2007 the NOP provided an interpretation of the regulation that mistakenly concluded that 21 CFR 

 104.20 allowed a wide variety of nutrients that were not limited to just vitamins and minerals.

• In 2010 the NOP met with the FDA to clarify the meaning of the FDA guidance at 21 CFR 104.20. The 

 NOP issued a memo to the NOSB in April 2010 explaining this clarification.

• The existing annotation is not what the original NOSB recommended in 1995. In 2011 the Handling 

Subcommittee proposed to change the annotation at sunset but received approximately 2000 

comments against it due to concerns about broadening the scope. The Subcommittee withdrew the 

proposal prior to the April 2011 NOSB meeting and the NOSB supported relisting with the existing 

annotation for the 2012 sunset review. 

• On January 12, 2012 a proposed rule was published in the Federal Register (77 FR 1980) to change the 

 annotation to: § 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on 

 processed products labeled as ‘‘organic’’ or ‘‘made with organic (specified ingredients or food 

 groups(s)).’’ 

(b) Synthetics allowed, 

Vitamins and minerals. For food— vitamins and minerals identified as essential in 21 CFR 101.9. 

For infant formula—vitamins and minerals as required by 21 CFR 107.100 or § 107.10.

• This proposed rule clarified that "nutrients" that were not in these CFR sections had to be petitioned 

 individually for the National List because this listing did not include them.

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• NOP did not finalize the proposed rule, but on September 27, 2012 published an Interim Rule (77 FR 

 59287), which renewed without change the original listing, as per the NOSB April 2011 

 recommendation.

• In 2011 through 2013 many other nutrients were petitioned. Some were recommended for listing by 

 the NOSB while others were not. No rulemaking in this area has occurred.

• In 2014 the Handling Subcommittee commissioned a new technical report in preparation for Sunset 

 2017 reviews. This was completed in February 2015 and clarifies which substances are required and 

 permitted and which are covered by the 21 CFR citations or other regulations.

• In 2015 the NOSB voted to renew the listing noting the following about the technical review and 

 public comment:

“Since this is a huge group of different substances, the TR went into length about their 

manufacturing processes, effects on human health, effects on the environment and uses. There 

was no information among these pages that gave concern that these substances did not meet 

the review criteria. Likewise, public comment was received with concerns about the 

unnecessary use of synthetic ingredients, but no new information was provided in comments 

from the first posting regarding the review criteria beyond the alternatives and compatibility 

issues. 

Regarding alternatives, the primary alternative is for people to get their vitamins and minerals 

from the food itself rather than supplementation. ...There is no literature to suggest that the 

manufacture or use of vitamins and minerals with ancillary substances is harmful to the 

environment or to biodiversity." 

 • In 2016 the Handling Subcommittee brought forward a discussion document with two options:

Option 1

Proposed Annotation #1: §205.605 (b) Vitamins and minerals, synthetic. For food – 

Minerals (including trace elements), vitamins and similar isolated ingredients are 

allowed only when their use is required by law or to meet an FDA standard of identity in 

which they are incorporated. 

Proposed Annotation #2: §205.605 (b) Vitamins and minerals, synthetic. For food – 

Minerals (including trace elements) and vitamins identified as essential in 21 CFR 101.9. 

For infant formula—vitamins and minerals as required by 21 CFR 107.100 or § 107.10 

are allowed for use in agricultural products labeled “made with organic (specified 

ingredients or food group(s)),” prohibited in agricultural products labeled “organic” 

(except as noted in annotation #1).

Proposed Annotation #3: §205.605 (a) Vitamins and minerals, non-synthetic. For food – 

Minerals (including trace elements) and vitamins identified as essential in 21 CFR 101.9. 

For infant formula—vitamins and minerals as required by 21 CFR 107.100 or § 107.10 

are allowed for use in agricultural products labeled Organic.

Option 2

Proposed Annotation #4: §205.605 (b) Vitamins and minerals, synthetic. For food – 

Minerals (including trace elements) and vitamins identified as essential in 21 CFR 101.9. 

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For infant formula—vitamins and minerals as required by 21 CFR 107.100 or § 107.10 

are allowed for use in agricultural products labeled "organic" and “made with organic 

(specified ingredients or food group(s))”.

•To Date the NOSB has taken no further action on this subject

Additional information requested by Subcommittee:

1. Is the current listing meeting the needs of the organic community, certifiers and industry – if 

not, how should it be revised? 

2. How are certifiers currently dealing with non-synthetic nutrient vitamins and minerals?

3. It is speculated that the 2012 rulemaking was stopped due to the impact this change would have 

on the currently established organic infant formula market which has both established 

manufacturers and consumers. How should the NOSB move this topic forward in light of this 

issue? 

4. Given that added vitamins and minerals need to be listed on ingredient panels, are consumers 

enabled enough to make educated purchasing decisions on fortified foods? If not, please 

explain. 

Peracetic acid

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: 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.

Technical Report: 2000 TAP; 2016 TR

Petition(s): 2008 Petition

Past NOSB Actions: 11/2000 sunset recommendation; 04/2004 NODB meeting summary; 11/2009 NOSB 

formal recommendation 

Recent Regulatory Background: Added to National List with annotation 9/11/06 (71 FR 53299);

Renewed 8/03/2011 (76 FR 46595); Renewed 09/12/16 (81 FR 8821)

Sunset Date: 9/12/2021

Background from Subcommittee:

Use:

Peracetic acid (CAS # 79-21-0) is currently allowed for use in organic handling in wash water and rinse 

water, including during post-harvest handling, to disinfect organically produced agricultural products 

according to FDA limitations, and to sanitize food contact surfaces, including dairy-processing 

equipment and food-processing equipment and utensils. It is an important sanitizer used in organic 

handling. It is widely used as a sanitizer on food contact surfaces and as a disinfectant for fruits and 

vegetables. Peracetic acid/Peroxyacetic acid was added to the National List on September 12, 2006, with 

the annotation, “for use in wash and/or rinse water according to FDA limitations. For use as a sanitizer 

on food contact surfaces.” (It is also on the National List at §205.601 and §205.603 for use in Crops and 

Livestock respectively). Peracetic acid disinfects by oxidizing the outer cell membrane of vegetative 

bacterial cells, endospores, yeast, and mold spores, making it an effective sanitizer against all 

microorganisms, including bacterial spores. The end products of peracetic acid oxidation are acetic acid 

and water.

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Manufacture: 

According to the 2016 technical report (TR), solutions of peracetic acid used as sanitizers are created by 

combining aqueous mixtures of two substances: acetic acid (the acid in vinegar) and hydrogen peroxide. 

At cool temperatures, acetic acid and hydrogen peroxide react over a few days to form an equilibrium 

solution containing peracetic acid, acetic acid, and hydrogen peroxide. The equilibrium solution is the 

substance sold commercially as the sanitizer “peracetic acid.” Solutions of peracetic acid, hydrogen 

peroxide, acetic acid and water are produced by reacting glacial acetic acid with hydrogen peroxide, 

often in the presence of a catalyst such as a mineral acid (e.g., sulfuric acid). Commercial grades are 

available in concentrations ranging from about 0.3 to 40 % by weight. A peracetic acid solution can also 

be generated in situ by dissolving an activator and a persalt in water or on site by adding sodium 

hydroxide to triacetin and hydrogen peroxide. 

International: 

Japan: Not listed

Codex: Not listed.

Canada: Allowed

IFOAM: Allowed

European Union: Allowed

Ancillary substances: 

HEDP and dipicolinic acid (DPA) are added to peracetic acid solutions to chelate metals, especially iron, 

copper and manganese, because decomposition of peracetic acid and, thus, loss of sanitizing power is 

accelerated by these impurities. However, in past reviews, stakeholders did not declare the inclusion of 

ancillary substances (See below).

Human Health Environment: 

peracetic acid likely has no significant environmental impacts. Like other oxidative sanitizers (i.e., 

chlorine compounds), concentrated solutions of peracetic acid are strong irritants to the skin, eyes, 

mucous membranes, and respiratory system. As reviewed in the TR, whenusing fully diluted sanitizing

solutions, no special eye, hand, skin, or respiratory protective equipment is normally required. No risk 

through dietary exposure is anticipated. All uses of this material should be consistent with FDA, USDA, 

and EPA labels and regulations and utilize personal protective equipment as needed.

Discussion: 

Peracetic acid has been relisted each time it was reviewed during the sunset review process. There has 

generally been strong support for continued availability. Overall, this material is considered effective 

and offers a less toxic profile then several other sanitizing materials, including many chlorine 

compounds. The TR does not offer new evidence of unacceptable adverse impacts on human health or 

the environment. During the last review, use of a synthetic stabilizer such as 1-hydroxyethylidene-1,1-

diphosphonic acid (HEDP) or 2,6-pyridinedicarboxylic (dipicolinic) acid to slow the rate of oxidation or 

decomposition were judged to be “inerts” for EPA registration as an antimicrobial and not subject to 

review as an ancillary substance. Furthermore, the annotation currently states “for use in wash and/or 

rinse water according to FDA limitation”, which defines the permitted stabilizers.

Additional information requested by Subcommittee:

1) Is peracetic acid still essential for handling and processing of organic products?

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Potassium citrate

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: Potassium citrate. 

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 04/2010 

sunset recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from Subcommittee:

Uses: Antioxidant, acidulant, pH control, flavoring agent, sequestrant, emulsifying salt, stabilizer, and as 

a dispersant in flavor or color additives. Commonly used in biscuits, baby food, soup mixes, soft drinks, 

and fermented meat products. It is also used to wash processing equipment to remove off flavors.

Potassium citrate is used to replaced sodium citrate whenever a low sodium content is desired. 

Manufacture:

Potassium citrate is the potassium salt of citric acid. It is prepared by neutralizing citric acid with 

potassium hydroxide or potassium carbonate and subsequent crystallization. 

Potassium citrate is Generally Recognized as Safe (GRAS) as listed under 21 CFR 184.1625. 

International:

Allowed by Canada and International Federation of Organic Agriculture Movements (IFOAM) (allowed as 

an additive). 

Ancillary substances: 

According to the 2015 TR, citric acid and its salts (including calcium citrate) are commercially supplied as 

pure compounds and do not contain ancillary substances. 

Discussion:

According to the 2015 TR, based on various toxicology studies, citric acid and its salts (including 

potassium citrate) are not expected to pose any significant health hazard upon ingestion. The 

manufacture of potassium citrate was not addressed in terms of potential harm to the environment. 

The TR cited the versatility of citric acid and its salts as the reason why no alternative practices could be 

used to substitute for all functions they provide. Additionally, there are no nonsynthetic sources or 

alternatives for the citrate salts.

Additional information requested by Subcommittee: none

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Potassium phosphate

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: Potassium phosphate—for use only in agricultural products 

labeled “made with organic (specific ingredients or food group(s)),” prohibited in agricultural products 

labeled “organic”. 

Technical Report: 1995 TAP, 2016 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 04/2010 

sunset recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from Subcommittee:

Use: Potassium phosphate can be used as a pH control in milk and dairy products, to make acidified milk 

products and in milk protein stabilization. It can also be used as a nutritional additive for a source of 

potassium and as a nutrient in yeast. Potassium phosphate can also be used in prepared meat 

applications and liquid eggs. The initial technical advisory panel report (TAP) included a 

recommendation to list this material as an approved synthetic in products labeled “organic,” but was 

only approved for use in “made with” products. 

Manufacture: The initial technical report (TR) noted that potassium phosphates are isolated from brines 

or salt deposits. However, the 2015 TR explained the manufacturing process to be as follows: All of the 

orthophosphate derivatives of potassium can be generated by neutralization of phosphoric acid with 

potassium hydroxide (Budavari 1996). Phosphoric acid is produced by treating phosphate rock 

(tricalcium phosphate) with sulfuric acid, forming phosphoric acid and calcium sulfate (Budavari 1996). 

Potassium hydroxide is obtained commercially from the electrolysis of potassium chloride solution in the 

presence of a porous diaphragm. [21 CFR 184.1631]. (2015 TR, pg 30-31)

International: Potassium phosphate is not listed in CODEX, does not appear on the EU, JAS or IFOAM 

organic standards, but is listed in the Canadian organic standard for products in the 70%-95% category 

only.

Discussion: During the 2017 sunset review cycle, the NOSB received public comment in support of 

potassium phosphate, noting it is an efficient pH buffering substance with no organic alternatives. The 

industry indicated that potassium phosphate is used in non-dairy beverages; it prevents precipitation 

and impaired mouthfeel; that the alternatives are not as good; and loss of this product would mean 

impaired quality and marketability. Other commenters noted a concern with the use of phosphates in 

production of processed foods and that phosphorus may not appear on the nutritional panel making it 

difficult to be informed about total phosphorous intake– although they would appear on the ingredient 

list. In particular there were concerns raised about the cumulative health impacts of phosphorous 

additives in food and in 2015 the NOSB requested a technical review and work agenda item to study this 

issue further. Concerns were based on peer reviewed research indicating that the cumulative effects of 

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phosphates as a group are contributing to renal damage and failure, osteoporosis, and heart failure. A 

brief literature review shows clinical research from 2010 (Journal of Kidney Disease: April 2010 4(2):89-

100), and 2013 (Sim et al, American Journal of Medicine, January 2013) suggesting potential serious 

renal impacts in subjects with normal renal function, from cumulative phosphorus. A daily limit of 70 

mg/kg/day was recommended in one study. Populations are at risk for bone health and kidney failure 

were especially impacted. In 2016 the NOSB Handling Subcommittee published a discussion document 

on the cumulative health impacts of phosphates and the NOSB decided to address phosphates 

individually during sunset reviews. Sodium phosphate was reviewed in 2017 and the NOSB came to the 

following conclusion:

No single phosphate food additive or ingredient can be implicated as an isolated risk factor. 

Concerns arise from the increase in cumulative use of phosphates and possible health effects on 

the general population. Given the new information and research since last sunset review, the 

Handling Subcommittee requested a new Technical Report (TR) which it received in 2016. The 

TR indicates that small amounts of sodium phosphates may not cause human health problems, 

but long-term cumulative impacts are not fully understood.

Additional information requested by Subcommittee:

1. Does industry still find the listing for potassium phosphate necessary? In what applications is 

this substance currently being used in products marketed as “made with organic.”

2. If applications are for nutritional supplementation only – is this substance redundant to the 

current Nutrient Vitamin and Mineral listing? If yes, should this listing be removed?

Sodium acid pyrophosphate

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: Sodium acid pyrophosphate (CAS # 7758-16-9)—for use only 

as a leavening agent.

Technical Report: 2001 TAP (Sodium Phosphates); 2010 TR; 2016 TR

Petition(s): 10/2002 petition; 03/2007 petition for expand use

Past NOSB Actions: 05/2003 sunset recommendation; 11/2009 sunset recommendation; 04/2011 

sunset recommendation

Regulatory Background: Added to National List 09/12/06 (71 FR 53299); Renewed 8/03/2011 (76 FR 

46595); Renewed 09/12/16 (81 FR 8821)

Sunset Date: 9/12/2021

Background from Subcommittee:

Use:

Sodium acid pyrophosphate is a common food additive for the purpose of a sequestrant/chelating agent 

in processed potatoes, an emulsifying agent in cheese, an inhibitor agent in canned tuna, and a curing 

accelerator in processed meats. This listing limits its use as a leavening agent. Sodium acid 

pyrophosphate is used as a leavening agent in baked goods, where it reacts with baking soda (sodium 

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bicarbonate) to liberate carbon dioxide, ‘leavening’ the dough and creating the desired ‘airy’ texture 

that consumers expect of baked goods such as cakes and cookies. It is GRAS, listed at 21 CFR 182.1087.

Manufacture: 

Sodium carbonate is reacted with phosphoric acid to form monosodium phosphate, followed by heating 

the monosodium carbonate to 220oC to form sodium acid pyrophosphate. It is expressed by the formula 

Na2H2P2O7 and is composed of 20.72% Na, 0.91% H, 27.91% P, and 50.46% O. Sodium is isolated from 

brines or salt deposits. Phosphorous is isolated from phosphate rock. Food grade phosphates are 

formed by reacting purified phosphoric acid with sodium, potassium, or calcium hydroxides.

International: 

The Canadian General Standards Board Permitted Substances List (CAN/CGSB 32.311-2006) permits 

these phosphate salts with usage annotations identical to the NOP regulations.

CODEX Alimentarius Commission Guidelines for the Production, Processing, Labelling and Marketing

of Organically Produced Foods (GL 32-1999)

These guidelines only permit monocalcium phosphate (341(i)) and “only for raising flour” (as a leavening 

agent).

European Economic Community (EEC) Council Regulation, EC No. 834/2007 and 889/2008

ANNEX VIII, Certain products and substances for use in production of processed organic food referred to 

in Article 27(1)(a), Section A – Food Additives, including Carriers, lists only monocalcium phosphate 

(341(i)) as a “Raising agent for self-raising flour” (as a leavening agent).

Japanese Agricultural Standard for Organic Processed Foods (Notification No. 1606 of the Ministry of

Agriculture, Forestry and Fisheries of October 27, 2005)

Table 1, “Food Additives,” lists INS 341(i), Calcium dihydrogen phosphate (a.k.a. monocalcium 

phosphate), with the annotation “Limited to be used for powders as expanding agent” (as a leavening 

agent).

IFOAM – Organics International (IFOAM)

The IFOAM norms for Organic Production and Processing, Version 2014, list monocalcium phosphate, 

INS 341, as a food additive “Only for ‘raising flour’” (as a leavening agent).

Ancillary Substances: 

None identified.

Discussion: 

During the last sunset review, this material received positive support from stakeholders. While excess 

phosphates in wastewater contributed to environmental degradation in the past, this was largely due to 

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its use in detergents. Its use in detergents has waned and in this use as a food additive, phosphates 

would have little environmental impact.

The 2016 technical report (TR) on phosphates includes extensive discussion on the impact of 

phosphorous on the human diet, with particular focus on health effects of phosphorous provided by 

phosphate additives versus natural phosphorous in foods. Added phosphorous, as is found in sodium 

acid pyrophosphate, is immediately and completely bioavailable upon consumption whereas “food” 

phosphorous is much less available.

High blood phosphate levels are associated with kidney and vascular disease. A sufficiently high intake 

of calcium appears to counteract some of the ill effects of excess dietary phosphorus but leads to an 

increased requirement for magnesium. Due to the restrictions on phosphate use in organic foods, it 

would be expected that basing a diet on organic foods would reduce phosphorus intake.

Yeast, a natural leavener used for time immemorial, is a common and alternative to chemical leavening. 

However, yeast leavened baked goods have a different physical texture and require more time than 

chemically-leavened foods. Chemical leavening is used instead of yeast for products where fermentation 

flavors would be undesirable or where the batter lacks the elastic structure to hold gas bubbles for more 

than a few minutes such as found with muffins, pancakes and cookies.

Additional information requested by Subcommittee:

Is this material still essential to organic production?

Sodium citrate

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: Sodium citrate.

Technical Report: 1995 TAP; 2015 TR

Petition(s): N/A

Past NOSB Actions: 04/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 10/2010 

sunset recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from Subcommittee:

Uses: Acidulant, pH control, flavoring agent, sequestrant, and buffering agent. Used as an emulsifier in 

dairy products to keep fats from separating, and in cheese making where it allows the cheeses to melt 

without becoming greasy. Also used as dispersants in flavor or color additives, and to wash processing 

equipment in order to eliminate off flavors. 

During the last review of sodium citrate in 2015, public comment included these specific reasons for use: 

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• Potassium citrate is an option, but it has an unpleasant metallic taste. Sodium phosphates are 

another option but they need to be used in higher quantities and are not as effective. 

• We use sodium citrate as part of the process of preparing fresh fruit for use in our yogurts. We use 

sodium citrate primarily for its ability to buffer pH, neither citric acid nor potassium citrate would 

have the same buffering effect in our products.

• Sodium citrate is used in a personal care product (lubricant).

Manufacture:

Sodium citrate is the sodium salt of citric acid. It is prepared by neutralizing citric acid with sodium 

hydroxide or sodium carbonate and subsequent crystallization.

Sodium citrate is listed under 21 CFR 184.1751 as Generally Recognized as Safe (GRAS). The listing allows 

its production from citric acid and sodium hydroxide or sodium carbonate. It is allowed as an ingredient 

used in food with no limitation other than current good manufacturing practice. 

The EPA lists citric acid and its salts in the 2004 List 4A (minimal risk inerts). 

International: 

Canada: Sodium citrate is allowed but restricted to use with sausages or milk products. 

CODEX Alimentarius Commission: Sodium citrate is listed for sausages/pasteurization of egg 

whites/milk products. 

European Economic Community (EEC): Sodium citrate is allowed as an ingredient in the preparation of 

foods of animal origin. 

Japan Agricultural Standard (JAS): Sodium citrate is allowed, but limited to use for dairy products, or for 

albumen and sausage as low temperature pasteurization. 

International Federation of Organic Agriculture Movements (IFOAM): allowed as an additive. 

Ancillary substances: 

According to the 2015 TR, citric acid and its salts (including calcium citrate) are commercially supplied as 

pure compounds and do not contain ancillary substances. 

Discussion: 

According to the 2015 TR, based on various toxicology studies, citric acid and its salts (including sodium 

citrate) are not expected to pose any significant health hazard upon ingestion. The manufacture of 

sodium citrate was not addressed in terms of potential harm to the environment. 

The TR cited the versatility of citric acid and its salts as the reason why no alternative practices could be 

used to substitute for all functions they provide. Additionally, there are no nonsynthetic sources or 

alternatives for the citrate salts.

Additional information requested by Subcommittee: None

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Tocopherols

§205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed 

products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”

Reference: 205.605(b) Synthetics allowed: Tocopherols—derived from vegetable oil when rosemary 

extracts are not a suitable alternative.

Technical Report: 1995 TAP; 2015 limited scope TR

Petition(s): N/A

Past NOSB Actions: 10/1995 NOSB minutes and vote; 11/2005 sunset recommendation; 04/2011 

sunset recommendation; 10/2015 NOSB Final Review; 09/2016 Handling Subcommittee proposal 

additional listing of Tocopherol

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from Subcommittee:

Use: 

Synthetic tocopherols are currently permitted for use in organic agriculture handling/processing as an 

antioxidant ingredient in foods (2015 TR). Tocopherols are added to foods to help prevent oxidation of 

the fatty acids present in the lipid components of the food. Tocopherols derived from vegetable oil are 

allowed for use as ingredients in or on processed products labeled as “organic” or “made with organic 

(specified ingredients or food group[s])” when rosemary extracts are not a suitable alternative (7 CFR 

205.605[b]).

Manufacture: 

Tocopherols are a group of lipophilic phenolic antioxidants that occur naturally in a variety of plant 

species. Sources of naturally-occurring tocopherols include cereal grains, oilseeds, nuts, and vegetables. 

As described in the 2015 TR, tocopherols are separated from the other compounds in the oil distillate by 

multiple extraction and refining steps. These steps can include solvent extraction, chemical treatment, 

crystallization, complexation, and vacuum or molecular distillation. The total tocopherol content of the 

resulting product is usually 30 - 80%. Liquid forms of mixed tocopherols are commercially available 

diluted in vegetable oils and are also available as mixtures with rosemary extracts, ascorbyl 

palmitate/ascorbic acid, lecithin and/or citric acid. Powdered forms of tocopherols are produced by 

spray-drying the liquid tocopherol oils onto a carrier or mixture of carriers.

International:

Japan: Listed for processed meats.

Codex: Allowed.

Canada: Allowed

IFOAM: Allowed

European Union: Allowed

Ancillary Substances: 

Table 1 from the most recent Technical Review (TR) shows some of the more common formulations 

along with their ancillary substances.

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Background from subcommittee: 

The NOSB has consistently relisted this material due to its essentiality for many processed food 

products. However, there has been extensive discussion about the need for synthetically derived 

tocopherols. Public comment has historically been divided on the relisting due to concerns that the 

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material’s primary use is as a preservative and therefore inconsistent with organic production. 

Additionally, commenters have asserted that non-synthetic tocopherols are commercially available and 

should be used instead of synthetic. However, many past commenters have expressed strong support of 

relisting, stating that tocopherols are critically essential to maintaining food safety, preventing rancidity, 

and providing nutrients to their products, and that rosemary oil imparted off flavors or fragrances to 

their products that were not acceptable to consumers. Given past feedback on the commercial 

availability of non-synthetic tocopherols, the Handling Subcommittee considered the possibility of 

reclassifying tocopherols to 205.605(a), or listing on both 205.605(a) and 205.605(b) with different uses 

annotated for each listing and/or an annotation about availability; however, as discussed at the Fall 

2017 meeting, the Handling Subcommittee concluded to not move forward with the tocopherol 

annotation change. The meeting transcripts note that “if there is sufficient commercial availability of 

this material in another form, we encourage members of the public or industry to petition the NOSB to 

make this change, and we would take it up at that time”.

Human Health and the Environment: 

Tocopherols are one of the main sources of Vitamin E. No major impacts on human health or the 

environment are likely.

Additional information requested by Subcommittee:

1) Are there any additional ancillary substances not listed in the chart that should be considered?

2) Since the last sunset review, are new sources of non-synthetic tocopherols available that fulfill 

the needs of organic food processing?

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Reference: 7 CFR §205.606

Celery powder

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

products labeled as “organic.”

Reference: 205.606(c) Celery powder. 

Technical Report: N/A

Petition(s): 2007 Petition; 2018 TR pending

 Past NOSB Actions: 03/2007 NOSB recommendation; 04/2010 sunset recommendation; 10/2015 NOSB

Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from subcommittee: 

Use: 

Celery powder is used in a variety of processed meat products (hot dogs, bacon, ham, corned beef, 

pastrami, pepperoni, salami, etc.) to provide “cured” meat attributes without using prohibited nitrites. 

Celery powder is naturally high in nitrates that are converted to nitrites during fermentation by a lactic 

acid culture. Celery powder and the presence of nitrate and nitrites protects against spoilage and also 

reduces risk from food borne pathogens, including clostridium botulinum, which produces botulin toxin. 

Celery powder is used in place of synthetic chemical nitrate and nitrite which are not currentlypermitted 

in U.S. organic agriculture. Although functionally similar to the use of synthetic nitrate and nitrite, meat 

products processed with celery powder must be labeled “uncured.”

Manufacture: 

Celery is cleaned, macerated, physically separated (liquid/solid), and the liquid is concentrated by 

evaporation, heated and vacuum dried. According to the original petition, 0.2-0.5% celery powder and 

0.01-0.5% of lactic acid starter culture are used to convert the nitrates to nitrite and thus create the 

curing agent. According to the Kerry Inc. patent 

(https://patentimages.storage.googleapis.com/1b/75/a5/082eb2538620f2/US20080305213A1.pdf), “the 

curing agent can further comprise additional components, including but not limited to, yeast extract, 

protein hydrolyzates, amino acids, vitamins, minerals, and carbohydrates. Prior to the conversion of 

nitrate to nitrite, the pH and salt content of the plant material can be adjusted with the addition of a 

suitable acid, base, salt, or combination thereof. The plant material can be subjected to additional 

processing steps prior to conversion of nitrate to nitrite. Such processing steps can include, but are not 

limited to, heat treatment, filter sterilization, or a process which reduces the initial microbial load.” 

Celery powder is typically standardized to a specific nitrite content. According to past information 

reviewed by the NOSB, meat preservation via natural nitrites/lactic acid is an ancient technology. 

Concerns have been raised during past reviews that production of high nitrate conventional nonorganic 

celery used for celery powder production requires enhanced use of synthetic nitrate fertilizers. 

According to the Kerry Inc. patent, other plants high in nitrate that could be used “include, but are not 

limited to, celery, beet, spinach, lettuce, cabbage, cucumber, eggplant, mushroom, green pepper, 

butternut squash, zucchini, mixed salad greens, carrot, artichoke, green bean, lima bean, broccoli, 

cauliflower, collard green, com, mustard, okra, onion, Chinese pea pod, black eyed pea, green pea, 

potato, turnip, sauerkraut, radish and the like. Other edible plant material containing nitrate, preferably 

at least about 50 ppm nitrate, also can be used. Any mixture or combination of plant materials can be 

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used to make the curing agent.”

International: 

There is no list of individual non-organic agricultural commodities allowed under the Japanese 

Agricultural Standards (JAS), International Federation of Organic Agricultural Movements (IFOAM) or 

Codex standards – however these standards allow for up to 5% non-organic content. Celery powder is not 

listed in the EU Organic Standards, however, sodium nitrate is allowed for meat products (an alternative 

to celery powder not currently listed on the National List).

Ancillary substances: 

Possibly materials listed in the patent: “including but not limited to, yeast extract, protein hydrolyzates, 

amino acids, vitamins, minerals, and carbohydrates.”

Human Health and the Environment

Nonorganic celery is used to produce celery powder, with concomitant use of allowed conventional 

pesticides and fertilizers. These materials may pose risks to workers, consumers and the environment. 

Additionally, health concerns have been raised about the use of synthetic nitrates and nitrites in 

processed meats (allowed in the European Union). For example, the International Association for 

Research in Cancer (IARC) listed processed meats as carcinogenic to humans, albeit with low potency, 

and the review committee was not unanimous. Nitrates and nitrites from celery powder may pose 

similar risks.

Discussion (including OFPA criteria): 

Celery powder was listed as a nonorganic handling material in response to a 2007 petition asserting the 

need for a uniform, agriculturally produced material necessary to produce organic processed meats such 

as bacon, hot dogs, and sausages. Several commenters argue that this material allowed substantial 

growth of the organic meat industry while complying with the “organic” or “made with organic” claims of 

processed foods. However, concerns were, and continue to be, raised about the direct dependence on a 

conventionally grown agricultural product in organic trade and concomitant impacts on human health 

and the environment. Particular concerns have been raised about the possibility of enhanced use of 

nitrate fertilizers to “supercharge” the product used for celery powder manufacture. 

Celery powder was last reviewed by the NOSB in 2015, and there were extensive comments by celery 

powder manufacturers, trade groups, producers, and the larger organic community about the need for 

this material, as well as commitments by producers to address the lack of organically sourced material 

going forward to the next sunset review, which is occurring now. To address these concerns and in lieu 

of a technical report, the NOSB will be convening a panel discussion at the Spring 2019 NOSB meeting 

that will include agronomic specialists, celery powder manufactures, meat processors, and experts in 

meat science and nitrates and nitrites. This discussion will help flesh out the information needed for the 

Fall 2019 review and vote on whether to relist celery powder. 

Additional information requested by Subcommittee:

1. Is nonorganic celery powder still essential for the production of processed meats?

2. Compared with growing celery for vegetable production, is increased use of synthetic nitrogen 

fertilizers required to produce source plants with enough nitrate for celery power production?

3. Since 2015, what progress has been made on the production of organic celery for powder 

production?

4. Are there strategies to produce organic celery powder that is standardized to consistently meet 

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safety and other requirements of the meat processing industry? 

5. If not, enough organic celery is being produced to support the meat industry, why not?

6. Are there commercially available agriculturally produced alternatives to celery powder? What is 

your experience with them? Are they organic? Does their use vary by application? Are they 

more effective in one application compared to another? 

7. What is the latest information on the human health risks of nitrate and nitrites present in 

processed meats from either synthetic or plant-based sources?

Fish oil

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

products labeled as “organic.”

Reference: 205.606(e) 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.

Technical Report: 2015 TR

Petition(s): 2007 Petition

Past NOSB Actions: 03/2007 sunset recommendation; 04/2010 sunset recommendation ; 10/2015 

NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from subcommittee: 

Section 205.606 allows for use of non-organically produced ingredients to be used in processed products 

labeled “organic” when the ingredient is not commercially available in organic form. 

 

The NOP does not presently have production standards for aquaculture, therefore organic fish cannot 

be commercially available as organic. 

Uses: Fish oil is used in organic processing and handling as an ingredient to increase the content of 

omega-3 fatty acids—primarily, eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA)—in foods 

to benefit human health by contributing to healthy brain development and reducing risks of 

cardiovascular disease, diabetes, inflammation, atherosclerosis (Chang et al., 2009; Lee et al., 2014). Fish 

oil is used in a variety of food products, including breads, pies, cereals, yogurt, cheese products, frozen 

dairy products, meat products, cookies, crackers, snack foods, condiments, sauces, and soup mixes 

(Rizliya and Mendis, 25 2014). (Technical Report 2015 lines 19-25). 

 

In addition to aquaculture—estimated to use about 81% of the fish oil produced worldwide—fish oil is 

used in feed for livestock such as pigs, cattle, poultry, and sheep. Industrial applications of fish oil 

include paint production, leather making, and biodiesel manufacture. 

 

History: Fish Oil was added to the National List in 2007, based on a petition from a manufacturer. At that 

time the NOSB did not request a Technical Report or TAP. The 2007 NOSB recommendation indicated 

that the OFPA criteria were met in all categories but provided no scientific rationale or citations to 

support such findings. However, the NOSB final recommendation from May 9, 2007 stated ...”pursuant 

to the judgment in Harvey v. Johanns, the NOSB was instructed to develop criteria for determining 

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commercial availability, an essential tool in evaluating whether or not petitioned materials could be 

listed on §205.606. These criteria were finalized in the NOSB “Recommendation for the Establishment of 

Commercial Availability Criteria National List §205.606” of October 19, 2006. “That recommendation 

allows for pro-active listing on §205.606 of materials which may currently be available in an organic 

form, but the supply of which has a history of fragility due to factors such as limited growing regions, 

weather or trade-related issues. Furthermore, the recommendation reiterates the role of the Accredited 

Certifying Agent (ACA) in making the ultimate decision as to whether a §205.606-listed material may be 

used, on a case by case basis. ...” “.... After discussion, the Board decided to add an annotation to the 

recommendation to list fish oil to the National List. The annotation states: “stabilized using only allowed 

ingredients on the National List.” The Board considered this annotation to be not overly prescriptive 

since a nonorganic material that falls within the annotation exists on the market.” The NOSB (2007) 

further noted that “There were no public comments specifically opposing the listing of fish oil on 

§205.606....” 

In its five-year review in April 2010 the NOSB received no public comment and fish oil remained on the 

List. In February 2015 the NOSB posed the following questions in the first posting of this material under 

the new sunset procedure: 

1. What are the primary geographic sources of fish oil and primary fish species harvested for the 

purpose of oil extraction? 

2. Are there conservation and environmental issues surrounding harvest of wild caught fish for fish oil? 

3. What is the manufacturing and purification process? 

4. Is there a mandatory standard for fish oil purity with limits on contaminants, dioxins and PCB’s for 

example? How is purity assessed? 

5. Is the Voluntary Standard from the Council of Responsible Nutrition (CRN) for contaminant limits still

in effect? 

6. What is the most current research on plant-derived alternatives such as flax and chia and how 

comparable are they to the Omega 3 in fish and algal oils? 

In addition, in preparing for the 2017 sunset review the NOSB requested a full technical report (TR) 

which was received in March 2015. The 2015 TR provides a valuable in-depth analysis and provides up to 

date research and citations allowing the Subcommittee to re-evaluate fish oil comprehensively against 

the OFPA criteria. Sources: Fish oil is derived from a wide range of wild caught fish species including, 

tuna, mackerel, sardines, anchovy, halibut, (TR lines 69-79). NOTE: The TR also lists fish oil from whales 

and seal under fish, although these are mammals. (TR lines 75-76). 

Fish oil is produced from fish by-products or from fish that are caught specifically for the purpose of 

making fish oil (TR lines 283-284). Farmed fish are not a source of fish oil; they are often fed fish oil 

supplements to boost their own levels of omega 3 fatty acids (TR 332-333). Based on 2009 data from 

the 2010 International Fishmeal and Fish Oil Organization (IFFO) Fishmeal and Fish Oil Statistical 

Yearbook, Peru produces the most fish oil worldwide and is responsible for one-third of the global 

production of fish oil, followed by Chile and the United States (Fréon et al., 2014; SEAFISH, 2011). 

Denmark, Japan, and Iceland are also prominent producers of fish oil. Overall, Peru is the world’s largest 

exporter of fish oil; together, Peru and Chile are responsible for 39% of global fish oil exports Most of 

the fish oil produced in Peru and Chile is refined by companies in Norway, the United States, and Canada 

although domestic refineries for fish oil are emerging in Peru, Chile, and other South American countries 

(Dowling, 2012; GOED, 2014). (TR 90-110) 

Manufacturing: Fish oil remains intact through the purification process and is not chemically modified 

(TR 338). Fish oil used for feed, aquaculture, supplements, or food applications is further purified using 

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a carbon filter to reduce contaminants (e.g., dioxins/furans, polybrominated diphenyl ethers [PBDEs], 

polychlorinated biphenyl [PCBs], polycyclic aromatic hydrocarbons [PAHs]) that may be present in the oil 

(Rizliya and Mendis, 2014). Further extraction and purification of the oil can be performed by selective 

hydrolysis, followed by filtration, neutralization with sodium hydroxide, removal of oxidized oil by clay, 

and deodorization using steam distillation (EPAX Norway, undated; U.S. FDA, 2002) (TR 307320). There 

are also other purification methods, which are discussed in the TR. 

International: Fish oil is not listed as allowed for organic processing in Canada, Japan, EU, or under 

IFOAM and is not listed in CODEX (TR 245-275). However, it should be noted that CODEX, IFOAM and JAS 

do not have discreet lists for non-organic agricultural substances. The EU does have a positive list and it 

does not list fish oil, but the EU Organic Standards also allow for organic certification of aquaculture. 

There are EU organic fish oil products being sold. 

Discussion: 

Human Health: Fish oil is a naturally sourced product that appears to provide a multitude of health 

benefits (as listed above under “Uses”). It is one of the best sources of Omega 3 EPA and DHA fatty 

acids. Fish oil such as cod liver oil has been given to children in many areas of the world for generations 

to promote healthy brain development and prevent inflammation. Fish oils are added to many foods 

and taken as dietary food supplements to promote heart health and reduce risk of atherosclerosis. 

However, the health benefits from consumption of fish oil is currently a debated topic in the scientific 

community (TR 471) and some sources suggest that there are health risks from fish consumption that 

may outweigh the benefit of omega 3 fatty acids from fish oil (TR 489-494). Fish bioaccumulate many 

contaminants (TR 503-507). A laboratory analysis of 31 fish oil supplements found that every product 

contained measurable amounts of mercury, with an average concentration of 2.9 parts per billion (ppb) 

across all brands (LabDoor, 2014). The highest level of mercury recorded in the supplements was 6 ppb 

(LabDoor, 2014). It should be noted however, that these tests were on fish oil supplements, not on fish 

oil used in food products which is controlled under different regulations than dietary supplements. The 

FDA action level for methylmercury in fish is 1 part per million (ppm) (U.S. FDA, 2011). The Global 

Organization for and DHA Omega-3 (GOED) sets voluntary standards for fish oil. GOED recommends a 

maximum value of 0.1 mg/kg (i.e., 0.1 ppm or 100 ppb) mercury in fish oil. The GOED has set the same 

0.1-ppm voluntary standard value for lead, cadmium, and inorganic arsenic (GOED, 2012). 

PCBs might also be present in fish oil. The levels of PCBs and other lipophilic organochlorine chemicals 

will be more concentrated in the oil fraction of the fish than in the whole fish (U.S. FDA, 2011). The FDA 

tolerance for PCBs is 2 ppm for all fish (U.S. FDA, 2011). An analysis of 13 over-the-counter children’s fish 

oil dietary supplements showed that every supplement contained PCBs, with a mean concentration of 9 

(± 415 8) ppb (Ashley et al., 2013). The GOED maximum value for PCBs in fish oil is 0.09 ppm (GOED, 

2012). Dioxins and furans are hazardous environmental compounds that may also be found in fish and 

fish oil. In one study, 30 samples of omega-3-enriched dietary supplements were analyzed for the 

presence of dioxins/furans and PBDEs. Twenty-four of the samples had dioxin levels above detection, 

while all samples had PBDE levels above detection. Average intake estimates for dioxins and PBDE’s 

from the supplements were 4.3 picograms (pg) and 25,100 pg per day, respectively (Rawn et al., 2009). 

The GOED maximum values for dioxins; dioxin-like PCBs; and total dioxins, furans, and dioxin like PCBs 

are 2 pg, 3 pg, and 4 pg, respectively (GOED, 2012). There are no FDA action levels for dioxins and 

PBDEs, nor are their guidance levels of these compounds in supplements. (TR 404-426). Note: The TR 

addresses the February 2015 NOSB Questions 1, 2, 3 and 6 listed above under History, and partially 

answers Question 4, but it is not clear if the Voluntary Standard for contaminant limits is still in effect 

(Question 5). 

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Conservation issues: There is a very high demand for fish oil. 81% of fish oil goes to Aquaculture. 

Demands on fisheries may overburden the current supply of fish (TR 441-450). Fish oil used is from wild 

caught and not farmed fish. Overfishing may also lead to species extinctions and a decrease in 

biodiversity. There are more than 100 confirmed cases of extinctions in marine fish population’s 

worldwide (Jenkins et al., 2009). Exploitation of fisheries is the largest contributor to marine extinctions, 

higher than habitat loss, climate change, invasive species, pollution, and disease (Dulvy et al., 2003) (TR 

462-465). While some countries have highly regulated fisheries to prevent overfishing, many do not. 

According the Food and Agriculture Organization’s (FAO) State of the World’s Fisheries and Aquaculture, 

most of the pelagic fish stocks, globally, are considered either fully fished or overfished. Food and 

Agriculture Organization of the United Nations Fisheries and Aquaculture Department (2014). The State 

of the World Fisheries and Aquaculture. pp. 39. While many different species are used for fishmeal and 

fish oil, small pelagics are most commonly used due to their high oil content. Peruvian anchoveta, 

Japanese anchovy, and Atlantic herring are the most common pelagic species harvested for fishmeal and 

fish oil, with primary stocks in the Southeast Pacific, Northwest Pacific, and Northeast and Northwest 

Atlantic, respectively. In 2010, all of these were either fully exploited or depleted. (Food and Agriculture 

Organization of the United Nations Fisheries and Aquaculture Department. (2010) The State of the 

World Fisheries and Aquaculture. pp. 35. Available at: 

http://www.fao.org/docrep/013/i1820e/i1820e.pdf ) 

In the Mediterranean, sardine and anchovy stocks have been assessed as fully fished (FAO 2014, p 40). 

According to FAO, fisheries that target species of a specific trophic level, such as those that target 

pelagics for fishmeal and fish oil production, remove “one ecosystem component without considering 

cascading effects on the dependent species...Concerns about the impacts of harvest strategies that fail 

to consider trophic relationships in a given ecosystem have been recognized for decades, and abundant 

scientific literature exists underpinning its possible negative impacts on the structure and functioning of 

aquatic ecosystems.” (FAO 2014, p 136). Sardines, anchovies, and herring play a key ecological role in 

the survival of larger predatory fish, mammals, and seabirds, serving as an important link in the transfer

of energy from plankton to species higher in the marine food web, some of which are endangered (FAO 

2014, p 137), such as humpback whales. 

The NOSB and public were divided with regard to this substance during the 2015 review. . There was 

high consumer demand and industry strongly supports continued listing, especially as there are no 

organic sources. Industry comments (April 2015) include the following: “Used in Gummy Confections, 

Gummy Nutritional Supplements, Panned Jelly Beans.... Fish Oil is used in our products as a natural 

source of DHA. An organic form is not available.... No alternative management practices that would 

eliminate the need for the specific substance. This ingredient is essential to our organic products.” Other 

Industry comments: “Fish oil provides nutritional benefits which our consumers are seeking”; “Peru 

fisheries are well regulated”; “specification sheets indicate levels of PCB’s, arsenic, cadmium and lead 

are tested 3 times a year to meet very strict guidelines; plant sources of omega 3 are not as complete as 

found in fish oil”. On the other hand, conservation groups are concerned about impact on word 

fisheries, and NGO’s, concerned about the cumulative risk impact of fish oil on human health, 

recommend removing fish oil as it fails to meet OFPA criteria relating to human health, environmental 

conservation, and compatibility with a sustainable system of agriculture. The NOSB received public 

comment about the essentiality of this substance, however, essentiality is not a criterion in OFPA or the 

Organic regulations used to review agricultural substances. . Essentiality is only a criterion applied to 

synthetic substances, adjuvants and processing aids. In the end the NOSB did not vote to remove fish oil 

and the substance was renewed. 

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Additional information requested by Subcommittee:

1. Is there a mandatory standard for fish oil purity with limits on contaminants, dioxins and PCB’s for 

example? How is purity assessed? 

2. How is industry controlling for the risk of contaminants such as heavy metals and PCBs?

3. Is the Voluntary Standard from the Council of Responsible Nutrition (CRN) for contaminant limits still 

in effect? 

4. How can the annotation be modified to control for the noted conservation concerns?

Gelatin 

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

products labeled as “organic.”

Reference: 205.606(g) Gelatin (CAS # 9000-70-8).

Technical Report: 2002 TAP; 2019 TR

Petition(s): 2001 Petition ; 2007 Petition

Past NOSB Actions: 05/2002 NOSB Recommendation; 05/2007 Recommendation to add to the national 

list; 04/2010 NOSB sunset recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from subcommittee: 

Use: 

Gelatin is used in a wide range of products as a clarification or fining agent in teas, juice, and wine, as a 

stabilizer, texturizer, thickener, and in capsules. It may either be an ingredient or a processing aid in 

candies (gummy bears), desserts (puddings, jello, marshmallows), dairy products (yogurt, sour cream, 

ice cream), cereals and cosmetics. Fish gelatin is widely preferred for uses in kosher foods. Collagen gel 

has recently been petitioned for inclusion on the National List under §205.606. 

Manufacture:

Gelatin can be made from many different sources of collagen. Cattle bones, hides, pigskin, and fish are 

the principle commercial sources. Gelatin may be prepared in a way that is more like cooking and could 

be considered nonsynthetic. However, gelatin may also be processed in ways that would render it 

synthetic. All manufacturing operations extract and hydrolyze collagen found in fish skins, bovine bone, 

and porcine skin with subsequent purification, concentration, and drying operations. These can be 

either simple or complicated operations.

International: 

EU 2092/91 — Annex VI — Gelatin is listed under “Processing aids and other products which may be 

used for processing of ingredients of agricultural origin” in Section B and under “Ingredients of 

Agricultural Origin Which Have Not Been Produced Organically” in Section C. 

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Codex Alimentarius — Guideline for the Production, Processing, Labelling, and Marketing of Organically 

Produced Foods CAC/GL 32-1999, Table 2 Substance for Plant Pest and Disease Control, 1. Plant and 

Animal: listed. Table 4: Listed under “processing aids which may be used for the preparation of products 

of agricultural origin.” 

IFOAM — Basic Standards for Organic Production and Processing, September 2000, Appendix 4 List of 

Approved Ingredients of Non-Agricultural Origin and Processing Aids Used in Food Processing, 

Processing Aids and Other Products: listed for use in fruit & vegetable products and wine. 

Ministry of Agricultural, Forestry and Fisheries of Japan (MAFF) — Japan Agricultural Standard, 

Notification #60, Table 2 of food additives: allowed, with no annotation. 

Canada — Canadian General Standards Board National Standard for Organic Agriculture (CAN/CGSB32.310-99), June 1999: permitted as a clarifying agent. 

Certified Organic Associations of British Columbia (COABC) — British Columbia Certified Organic 

Production Operation Policies and Farm Management Standards, Section 9.14 Processing and Handling 

Materials List, March 2001: non hydrolyzed or hydrolyzed, regulated as a processing production aid; 

Either form of gelatin maybe used as a product processing aid, for now, but the producer must submit to 

the certifying agency written details of their search to replace the hydrolyzed gelatin format with a nonhydrolyzed gelatin or a completely different product. Allowed for fruits and vegetables and in 

winemaking.

Naturland, Germany — Listed in the August 1999 General Processing Standards in the “List of Permitted 

Ingredients, Additives, and Auxiliary Products” as “food gelatin without additives (exclusively for creamlike masses).” 

Ancillary Substances: 

It does not appear that there are any ancillary ingredients used regularly for gelatin, such as anti-caking 

agents, preservatives, colorings etc.

Discussion: 

There are currently no NOP standards for organic aquaculture, and therefore no possibility of obtaining 

fish gelatin in any form, quantity or quality from a certified organic source. For animal-based gelatin, 

public comment stated concern over gelatin sourced from conventional animal sources.

Additional information requested by Subcommittee:

1) Are there organic sources of collagen that preclude the listing of gelatin as a non-organically 

produced agricultural product allowed as ingredients in or on processed products labeled as 

‘organic’?

2) Are there any ancillary ingredients typically found in commercially available gelatin?

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Orange pulp, dried 

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

products labeled as “organic.”

Reference: 205.606(n) Orange pulp, dried.

Technical Report: N/A

Petition(s): 2008 Petition

Past NOSB Actions: 11/2008 NOSB recommendation for addition to the National List; 10/2015 NOSB 

Final Review

Recent Regulatory Background: Added to NL effective 03/15/2012 (77 FR 8089); Renewed 03/15/2017 

(82 FR 14420)

Sunset Date: 3/15/2022

Background from subcommittee: 

Uses: 

According to the petitioner, dried orange pulp is a fiber with about 33.3% soluble fiber and 34.9% 

insoluble fiber. It is used as a moisture retention agent and fat substitute in baked goods, pastas, salad 

dressing, confectionary, processed cheese spreads, beverages, meat products and frozen foods. Dried 

orange pulp is used in rates up to 5 percent depending on use, but is self-limiting after that point due to 

loss of desirable eating qualities.

Manufacture: 

Dried orange pulp is a byproduct of the orange juice industry and is manufactured from the washed 

orange peel, core and rag (membrane) remaining after juicing. The pulp is then mechanically dewatered, 

stabilized with heat, dried and mill-ground to a powder. The only processing aid used is water and no 

chemicals are used to process the product. The petitioner notes, due to food safety and economics, 

dried orange pulp manufacture must be co-located with orange juice processing facilities. 

International:

There is no list of individual non-organic agricultural commodities allowed under the Japanese 

Agricultural Standards (JAS), International Federation of Organic Agricultural Movements (IFOAM) or 

Codex standards – however these standards allow for up to 5% non-organic content. The EU Organic 

Standards do not list dried orange pulp. 

Ancillary substances: 

No ancillary substances were noted in the petition. 

Discussion:

The 2015 NOSB requested information from the public related to (1) commercial demand, (2)

commercial availability, (3) alternatives, and (4) necessity and use. No specific comments were received 

supporting relisting or addressing commercial unavailability of dried orange pulp. No organic handlers 

commented in favor of the material. While the NOSB could not find organic dried orange pulp during a 

search of publicly available sourcing resources in February 2015, there were several listed organic 

suppliers of oranges, organic juice, dried oranges and orange pulp – feedstock raw materials and 

byproduct industries for dried orange pulp. 

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Additional information requested by Subcommittee: 

1) Is there an organic supply of international orange pulp, dried?

2) Is there a domestic supply of organic orange pulp, dried? 

3) Have manufacturers using this nonorganic orange pulp in organic products tried to develop an 

organic orange pulp? 

4) Please describe any barriers to the production of organic orange pulp?

5) Are there other organic agricultural products or materials on the national list that have the same 

function and could replace the nonorganic orange pulp where it is currently used? 

6) Are there any ancillary ingredients contained in dried organic pulp when sold commercially?

 Seaweed, Pacific kombu 

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

products labeled as “organic.”

Reference: 205.606(q) Seaweed, Pacific kombu.

Technical Report: 2016 TR (Marine Plants & Algae)

Petition(s): 2007 Petition

Past NOSB Actions: 05/2008 NOSB recommendation; 10/2015 NOSB Final Review

Recent Regulatory Background: Added to NL effective 03/15/12 (77 FR 8089); Renewed 03/15/2017 (82 

FR 14420)

Sunset Date: 03/15/2022

Background from subcommittee: 

Use: 

Marine plants (seaweed) and algae are included in the National List in several sections and allowed for 

use in organic production and handling: 

1) At §205.601(j)(1), Aquatic plant extracts are synthetic substances allowed in organic crop production, 

as plant or soil amendments, from other than hydrolyzed extracts where the 46-extraction process is 

limited to the use of potassium hydroxide or sodium hydroxide; the solvent amount used is limited to 

that amount necessary for extraction. 

2) At §205.605 (a) and (b), products from marine plants and algae including non-synthetic substances: 

alginic acid, agar, carrageenan, and the alginates are nonagricultural (nonorganic) substances 

allowed as ingredients in or on processed products labeled as ‘‘organic’’ or ‘‘made with organic 

(specified ingredients or food group(s))’’ and may be used as ingredients in or on processed products 

labeled as ‘‘organic’’ or ‘‘made with organic (specified ingredients or food group(s)).” In addition, 

some minerals used for nutrient fortification, such as calcium, may be derived from marine plants. 

3) In §205.606(d), four substances from marine plants and algae are specifically identified as 

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

labeled as ‘‘organic’’ when the specific product is not commercially available in “organic” form: (d)(2) 

beta-carotene extract color, derived from algae (Dunaliella salina), not produced using synthetic 

solvents and carrier systems or any artificial preservative; (k) Kelp used only as a thickener and 

dietary supplement; (q) Pacific kombu; and (u) Wakame seaweed (Undaria pinnatifida). 

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4) In addition, calcium used for fortification may be derived from marine plants In 2012, about 23.8 

million metric tons worldwide of seaweed and other algae were harvested from aquaculture. Capture 

production, also known as wildcrafting produced about 1.1 million metric tons. Seaweed was used as 

food, in cosmetics and fertilizers, processed to extract thickening agents, and as an additive to animal 

feed (FAO, 2014).

 Currently, Kombu is used as an ingredient to make stock for Instant Miso Soup and Yuzu Ponzu. 

Kombu is integral to the preparation of most Japanese traditional foods as stock.

Manufacture:

Kombu is harvested from the ocean. After the crop is harvested, it is sun-dried. In general, the 

preparation of stock for Japanese traditional food, dried Kombu is boiled in water. 

International: 

Canada - Canadian General Standards Board Permitted Substances List. This list was updated in 

November 2015. Although there is a Canadian organic aquaculture standard and accredited certifying 

bodies can certify to it, the standard itself is not referenced in government regulations and organic 

aquaculture products may not carry the Canada Organic logo. Aquatic plants and aquatic plant products 

not containing synthetic preservatives, such as formaldehyde, either extracted naturally (non-synthetic) 

or with potassium hydroxide or sodium hydroxide in approved situations are allowed as soil nutrients 

and amendments. Agar is also permitted a medium for mushroom spawn production. 

CODEX Alimentarius Commission, Guidelines for the Production, Processing, Labelling and Marketing of 

Organically Produced Foods (GL 32-1999) - A proposal to amend the Codex guidelines to include organic 

aquaculture, including algae and products of algae, has been under consideration. Due to consensus 

issues, it is unclear whether this proposal will be adopted in the future (CAC, 2016). The Codex 

guidelines for organic also allow: 1) seaweed and seaweed products as a soil conditioner, 2) seaweed, 

seaweed meal, seaweed extracts, sea salts and salty water for pest control, 3) Carrageenan, 4) Alginic 

acid/sodium alginate/potassium alginate and 5) agar. 

European Economic Community (EEC) Council Regulation, EC No. 834/2007 and 889/2008. Aquaculture 

is defined by the EEC as the rearing or cultivation of aquatic organisms including marine plants and algae 

using techniques designed to increase the production of the organisms in question beyond the natural 

capacity of the environment; the organisms remain the property of a natural or legal person throughout 

the rearing or culture stage, up to and including harvesting. Algae, including seaweed, can be used in the 

processing of organic food. Aquaculture production must be based on the maintenance of the 

biodiversity of natural aquatic ecosystems, the continuing health of the aquatic environment and the 

quality of surrounding aquatic and terrestrial ecosystems.

Japan Agricultural Standard (JAS) for Organic Production— The Japanese Agricultural Standard for 

Organic Plants (Notification 1065 of the Ministry of Agriculture, Forestry and Fisheries of October 27, 

2005) allows the use of dried algae as fertilizer for terrestrial plants. 

International Federation of Organic Agriculture Movements (IFOAM) – IFOAM is developing a standard 

for marine algae in its aquaculture expert forum. Seaweed is allowed as a soil input in appendix 2 of the 

IFOAM norms (IFOAM, 2014). In addition, several hydrocolloids derived from algae such as carrageenan 

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and alginates are allowed as food additives (IFOAM, 2014).

Ancillary substances: 

It does not appear that any ancillary substances such as anti-caking agents, preservatives or colorings 

are used in the manufacture of Pacific Kombu products.

Discussion: 

This material is discussed in the larger discussion document about marine algae and related materials.

Additional information requested by Subcommittee: 

1. Are there any ancillary ingredients contained in Pacific Kombu seaweed when sold 

commercially?

2. Are there any organic seaweeds commercially available?

Wakame seaweed 

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

products labeled as “organic.”

Reference: 205.606(u) Wakame seaweed (Undaria pinnatifida).

Technical Report: 2016 TR (Marine Plants & Algae)

Petition(s): 2007 Petition

Past NOSB Actions: 04/2007 NOSB recommendation; 04/2010 NOSB sunset recommendation; 10/2015 

NOSB Final Review

Recent Regulatory Background: Sunset renewal notice published 06/06/12 (77 FR 33290); Renewed 

03/15/2017 (82 FR 14420)

Sunset Date: 3/15/2022

Background from subcommittee: 

Use: 

Acidulant, pH control, flavoring agent, sequestrant, and buffering agent. Used as an emulsifier in dairy. 

Marine plants (seaweed) and algae are included in the National List in several sections and allowed for 

use in organic production and handling: 

1) At §205.601(j)(1), Aquatic plant extracts are synthetic substances allowed in organic crop production, 

as plant or soil amendments, from other than hydrolyzed extracts where the 46-extraction process is 

limited to the use of potassium hydroxide or sodium hydroxide; the solvent amount used is limited to 

that amount necessary for extraction. 

2) At §205.605 (a) and (b), products from marine plants and algae including non-synthetic substances: 

alginic acid, agar and carrageenan, and the alginates are nonagricultural (nonorganic) substances 

allowed as ingredients in or on processed products labeled as ‘‘organic’’ or ‘‘made with organic 

(specified ingredients or food group(s))’’ and may be used as ingredients in or on processed products 

labeled as ‘‘organic’’ or ‘‘made with organic (specified ingredients or food group(s)).” In addition, some 

minerals used for nutrient fortification, such as calcium, may be derived from marine plants. 

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3) In §205.606(d), four substances from marine plants and algae are specifically identified as 

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

labeled as ‘‘organic’’ when the specific product is not commercially available in “organic” form: (d)(2) 

beta-carotene extract color, derived from algae (Dunaliella salina), not produced using synthetic 

solvents and carrier systems or any artificial preservative; (k) Kelp used only as a thickener and dietary 

supplement; (q) Pacific kombu; and (u) Wakame seaweed (Undaria pinnatifida). 

4) In addition, calcium used for fortification may be derived from marine plants

In 2012, about 23.8 million metric tons worldwide of seaweed and other algae were harvested from 

aquaculture. Capture production or wildcrafting produced about 1.1 million metric tons. Seaweed was 

used as food, in cosmetics and fertilizers, processed to extract thickening agents, and as an additive to 

animal feed (FAO, 2014).

Wakame seaweed is a traditional accompaniment to Miso Soup in Japanese cuisine. 

Manufacture:

Wakame is naturally occurring in the ocean. It is harvested and sun dried. It is often cut into smaller 

pieces and salted for shelf life. 

International: 

Canada - Canadian General Standards Board Permitted Substances List. This list was updated in 

November 2015. Although there is a Canadian organic aquaculture standard and accredited certifying 

bodies can certify to it, the standard itself is not referenced in government regulations and organic 

aquaculture products may not carry the Canada Organic logo. Aquatic plants and aquatic plant products 

not containing synthetic preservatives, such as formaldehyde, either extracted naturally (non-synthetic) 

or with potassium hydroxide or sodium hydroxide in approved situations are allowed as soil nutrients 

and amendments. Agar is also permitted a medium for mushroom spawn production. 

CODEX Alimentarius Commission, Guidelines for the Production, Processing, Labelling and Marketing of 

Organically Produced Foods (GL 32-1999) - A proposal to amend the Codex guidelines to include organic 

aquaculture, including algae and products of algae, has been under consideration. Due to consensus 

issues, it is unclear whether this proposal will be adopted in the future (CAC, 2016). The Codex 

guidelines for organic also allow: 1) seaweed and seaweed products as a soil conditioner, 2) seaweed, 

seaweed meal, seaweed extracts, sea salts and salty water for pest control, 3) Carrageenan, 4) Alginic 

acid/sodium alginate/potassium alginate and 5) agar. 

European Economic Community (EEC) Council Regulation, EC No. 834/2007 and 889/2008. Aquaculture 

is defined by the EEC as the rearing or cultivation of aquatic organisms including marine plants and algae 

using techniques designed to increase the production of the organisms in question beyond the natural 

capacity of the environment; the organisms remain the property of a natural or legal person throughout 

the rearing or culture stage, up to and including harvesting. Algae, including seaweed, can be used in the 

processing of organic food. Aquaculture production must be based on the maintenance of the 

biodiversity of natural aquatic ecosystems, the continuing health of the aquatic environment and the 

quality of surrounding aquatic and terrestrial ecosystems.

Japan Agricultural Standard (JAS) for Organic Production— The Japanese Agricultural Standard for 

Organic Plants (Notification 1065 of the Ministry of Agriculture, Forestry and Fisheries of October 27, 

2005) allows the use of dried algae as fertilizer for terrestrial plants. 

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International Federation of Organic Agriculture Movements (IFOAM) – IFOAM is developing a standard 

for marine algae in its aquaculture expert forum. Seaweed is allowed as a soil input in appendix 2 of the 

IFOAM norms (IFOAM, 2014). In addition, several hydrocolloids derived from algae such as carrageenan 

and alginates are allowed as additives (IFOAM, 2014).

Ancillary substances: 

It does not appear that any ancillary substances such as anti-caking agents, preservatives or colorings 

are used in the manufacture of wakame products, other than salt.

Discussion: 

This material is discussed in the larger discussion document about marine algae and related materials.

Additional information requested by Subcommittee: 

1) Are there any ancillary ingredients contained in wakame seaweed when sold commercially?

2) Are there any organic seaweeds commercially available?

NOSB April 2019 proposals and discussion documents Page 169 of 239