National Organic Standards Board

Handling Committee

Sunset 2013 Proposal

Carrageenan on 205.605(a)

February 21, 2012

List: 205.605 Nonagricultural (non-organic) substances allowed as ingredients in 

or on processed products labeled as “organic” or “made with organic (specified 

ingredients or food group(s)).”

(a) Non-synthetics allowed

Committee Summary:

Federal register notice of the sunset of this material elicited several public comments in 

favor of its re-listing. There were no comments against the re-listing of it.

Review of the Technical Evaluation Report of October 3, 2011 showed that while new 

uses are being explored for Carrageenan in the food industry as protective coatings, the 

food uses of it have not changed substantially since the original TAP review was 

conducted in 1995.

The FDA says that carrageenan may be safely used as a food additive for human 

consumption as long as its use is in accordance with 21 CFR 172.620. This regulation 

specifies that carrageenan should be prepared by aqueous extraction from any of the 

following eight species of Rodophyceae seaweeds: Chondrus crispus, Chondrus 

ocellatus, Eucheuma cottonii, Gigartina acicularis, Gigartina pistillata, Gigartina radula, 

and Gigartina stellata.

There are three primary extraction methods used to produce Carrageenan from its 

seaweed source: alcohol preparation (which is the most traditional method), gel press, 

and semi-refined or PES extraction. While Carrageenan is a naturally occurring 

polysaccharide extracted from seaweed and considered non-synthetic, the extraction 

process used, may in most instances, alter it. The Technical Evaluation Report of 

October 3, 2011 makes point of the fact that when industrial extraction methods using

alcohol or alkali are used that modifications of the chemical structure of the 

polysaccharides occur. The predominant carrageenan present (i.e., kappa, iota, or 

lamda) and the resulting properties of the final product, are determined by the amount of 

time and the type of alkali used for the alkali treatment (all three extraction processes 

use a form of alkali as part of the aqueous extraction process). Examples: kappa 

carrangeenans are modified in a way that allows adjacent chains to form helical 

structures, resulting in firm, brittle gels. Iota carrageenans are modified to form weak, 

elastic gels and lamda carrageenans do not gel but rather form high viscosity liquids. 

This would appear to show that alkali treatments are used to promote structural 

HC 1 Sunset 2013 Carageenan
changes to carrageenan to acquire the specifically desired gel strength or textures.

Thus, Carrageenan produced using these types of methods should be considered to be 

synthetic rather than non-synthetic, according to the information provided in the TR. 

This would be true for all three types of commercial extraction, currently being used by 

the industry to produce Carrageenan.

The Technical Evaluation Report of October 3, 2011 states that there were no other 

means of extraction currently being used.

Carrageenan continues to be an important material used by the organic community. 

Recommendations: 

At this time we would recommend the relisting of Carrageenan on the National List: 

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)). We are going to make the following recommendations to allow the 

current listing to sunset 605(a) and then move to relist it under 605(b). We are hoping 

that there will not be any disruption in the current use of Carrageenan, since this should 

hopefully occur at the same time.

We recommend allowing this current listing to sunset 605(a)

(a) Nonsynthetics allowed

We recommend then relisting under 605(b)

(b) Synthetics allowed

These recommendations are based from information presented in the October 3, 2011 

Technical Evaluation Report. The NOSB Classification “draft” Guidance of 11/05/2009 

was also considered for the making of this recommendation.

We would also recommend that this listing be revisited once the NOP has finalized the 

Draft Guidance submitted by the NOSB on November 5, 2009. Re-evaluation of the 

materials classification (agricultural, nonagricultural substances) should be considered 

to ensure that the listed materials have been properly classified and thus remove any 

further confusion from their status and help during future reviews.

Committee Vote:

5 – yes 0 – no 1 – absent 0-resused 0- abstain

HC 2 Sunset 2013 Carageenan