FORMAL RECOMMENDATION BY THE

NATIONAL ORGANIC STANDARDS BOARD (NOSB) 

TO THE NATIONAL ORGANIC PROGRAM (NOP) 

Date: __March 18, 2005_______

Subject: ___Status of Bitter Orange_________________________ 

Chair: ___Jim Riddle_______________________________________ 

 (sign) 

Recommendation

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action: ________ 

Guidance Statement: ________ 

Other: ____X____ 

Statement of the Recommendation (including Recount of Vote):

The NOSB recommends that the ingredient, bitter orange, needs to be petitioned. A certified 

organic source of bitter orange would be allowed under the regulations. 

Adopted March 2, 2005 by NOSB vote: 9 yes, 0 no, 4 abstain, 1 absent 

Rationale Supporting Recommendation (including consistency with OFPA and NOP):

Not enough information has been provided to determine if bitter orange is agricultural or 

nonagricultural, or, if agricultural, if it might be commercially available in an organic form. In 

addition, the claim has been made that the substance is "solvent-free." The substance needs to be 

reviewed to determine, among other things, if solvents are used in its manufacture and then 

burned off, leaving it "solvent-free", or if the manufacturing process does not use solvents. 

Section 205.105(c) prohibits the use of “nonagricultural substances used in or on processed 

products, except as otherwise provided in 205.605, and 205.105.” Section 205.105(d) prohibits 

the use of “nonorganic agricultural substances used in or on processed products, except as 

otherwise provided in 205.606.” Because "bitter orange" does not appear on the National List, it 

must be petitioned. 

Response by the NOP:

Updated 2/25/05 
NOSB Recommendation 

Bitter Orange Q&A 

Adopted March 2, 2005 

Introduction 

The USDA National Organic Program (NOP) has requested the NOSB to provide recommended 

guidance concerning a question of what needs to be petitioned in a specific formulated product. 

The NOP can review and distribute this recommendation to accredited certifying agents and post 

on the NOP website. 

Background 

The following scenario has been presented to the National Organic Program (NOP) for 

clarification: 

A manufacturer of a formulated product has asked whether his product has to be petitioned for 

inclusion on the National List of Allowed and Prohibited Substances in order to be used in 

organic processing. His product is comprised of Bitter orange (flower and peel, water extracted, 

solvent-free) which is listed under the Food and Drug Administration’s 21 CFR 182.20, Citric 

acid (listed under 205.605), Malic acid (will be listed under 205.605 once rulemaking is 

finalized), Ascorbic acid (listed under 205.605), Glycerin (listed under 205.605), and demineralized water (excluded under 205.302(a)). The intended use for his product is to serve as an 

anti-microbial wash for fresh fruit, vegetables and seafood as either a raw agricultural commodity 

or fresh cut. Raw product is dipped, sprayed or fogged with his solution. 

Specific Questions 

(1) Considering that the product in question is formulated with a number of ingredients (some are 

allowed on the National List, others are not), the NOP requests the NOSB to provide input on 

which of the following substances must be petitioned under the NOP regulations? Please provide 

your rationale with your response. 

• Bitter Orange 

• Citric Acid 

• Malic Acid 

• Ascorbic Acid 

• Glycerin 

• De-mineralized Water 

Recommendation 

The NOSB recommends that the ingredient, bitter orange, needs to be petitioned. A certified 

organic source of bitter orange would be allowed under the regulations. 

Rationale 

Not enough information has been provided to determine if bitter orange is agricultural or 

nonagricultural, or, if agricultural, if it might be commercially available in an organic form. In 

addition, the claim has been made that the substance is "solvent-free." The substance needs to be 

reviewed to determine, among other things, if solvents are used in its manufacture and then 

burned off, leaving it "solvent-free", or if the manufacturing process does not use solvents. 
Section 205.105(c) prohibits the use of “nonagricultural substances used in or on processed 

products, except as otherwise provided in 205.605, and 205.105.” Section 205.105(d) prohibits 

the use of “nonorganic agricultural substances used in or on processed products, except as 

otherwise provided in 205.606.” Because "bitter orange" does not appear on the National List, it 

must be petitioned. 

NOSB Vote: 9 yes, 0 no, 4 abstain, 1 absent