Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

Date: December 2, 2011

Subject: Petition to remove/amend silicon dioxide from the National List 

 § 205.605

Chair: Tracy Miedema

 

The NOSB hereby recommends to the NOP the following: Rulemaking Action

Statement of the Recommendation 

Motion to amend the annotation of the following substance:

§ 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)).” (b) Synthetics allowed—Silicon dioxide—providing 

sufficient evidence showing non-synthetic alternatives are not commercially 

available for a specific product/process is presented.

Correction made by NOP on 4/12/12: The motion as stated in the meeting 

transcript is: “Move to change the annotation of Silicon Dioxide on §205.605 nonagricultural substances be synthetics allowed for use as a defoamer. May be used 

in other applications when non-synthetic alternatives are not commercially 

available.” 

The motion passed with a vote of 11 yes and 3 no.

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

While an extensive review has been completed by the Handling Committee 

concerning the environmental, health, and applicability concerns of synthetic 

dioxide from the TAP reviews, previous petitions, prior NOSB discussions; the 

primary consideration/debate for whether or not synthetic silicon dioxide should 

remain on § 205.605(b) is rooted in consideration of § 205.600(b)(1) which states:

The following criteria will be utilized in the evaluation of substances or 

ingredients for the organic production and handling sections of the National 

List:

(b) In addition to the criteria set forth in the Act, any synthetic substance 

used as a processing aid or adjuvant will be evaluated against the following 
criteria:

(1) The substance cannot be produced from a natural source and there are 

no organic substitutes

Given this section of the regulation, and the charge of the NOSB to make 

decisions consistent with the overall intent of the regulation, the committee agreed 

that silicon dioxide was previously listed because of its unique properties, 

historically safe use in food, relatively broad utility in food processing, and limited 

environmental concerns. The petition attempts to demonstrate that the rice-hull 

based alternative described in the 2010 petition to remove silicon dioxide has been 

available since 2007 and has undergone reformulation in 2009 such that it now 

can be substituted for silicon dioxide nearly 1:1 ratios. While the new data does 

address concerns noted by the Handling Committee during the Sunset review 

process; the Handling Committee feels that it is still limited, not published from a 

third party source, and does not conclusively demonstrate its applicability in all 

products and processes. However, while the data presented in this petition is not 

sufficient to completely remove silicon dioxide, the Handling Committee feels that 

the availability of a natural alternative must be acknowledged. 

Therefore, with respect to the change in NOSB Policy and Procedures Manual, the 

Handling Committee did not vote to remove silicon dioxide in its entirety but 

recommends a change to the annotation to silicon dioxide as noted above.

NOSB Vote:

Moved: John Foster Second: Steve DeMuri.

Yes: 11 No: 3 Abstain: 0 Absent: 0 Recusal: 0
National Organic Standards Board

Handling Committee

Proposed Recommendation

Silicon Dioxide

December 2, 2011

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 group(s)).”

(b) Synthetics allowed--Silicon dioxide.

Committee Summary

Silicon dioxide is a naturally occurring substance that is generated following oxidation 

reactions involving silicon in the Earth’s crust. Silicon dioxide is a major component in sand, 

quartz, diatomaceous materials, and is found as biogenic silica in organisms. Silicon dioxide’s 

(chemical formula is SiO2) exists both as a amorphous and crystalline structures and is 

frequently found in a three-dimensional polytetrahydral structure where the two oxygen atoms 

of one SiO2 molecule are associated with a silicon atom of another SiO2 molecule. This 

molecular association generates structures exhibiting unique properties such as immiscibility in 

both water and oil and an extremely large surface area. These characteristics have been 

capitalized upon for their functionally in a diverse set of applications and industries including 

(but not limited to): glass production, ceramics, optical cable fiber production, food processing, 

food packaging, pharmaceutical production/packaging, soil amendments, and as inert 

compounds/carrier systems within pesticides. While silicon dioxide is found in natural sources, 

most industrial applications use silicon dioxide generated from synthetic sources/processes. 

The food industry frequently uses a silicon dioxide as its properties allow for enhanced 

process-ability and functionality in food products and manufacturing practices. Some common 

applications of silicon dioxide in the food industry are: as an anti-caking agent (most common 

application), an anti-foam agent, a stabilizer in beer production, an adsorbent in foods 

prepared as tablets for special dietary use, as carriers (such as a component of microcapsules 

for flavoring oils), and for various other uses allowed under jurisdiction of the FDA. Silicon 

dioxide is also allowed internationally for various uses in food products (in both conventional 

and organic foods) by the European Union, Codex, Canada, Japan, and by IFOAM for organic 

processing.

In 2010 the NOSB voted to relist silicon dioxide despite knowing that an application to remove 

silicon dioxide was at the NOP. During the relisting process, the Handling Committee 

produced the following concerns based upon debate and information presented during the 

sunset review process:

1. The Handling Committee has discussed and collectively agrees that there is the need 

to encourage the growth of agricultural--and preferably organic--alternatives to 

nonagricultural substances presently allowed on the National List for use in organic 

handling operations, and considers this to be just such an opportunity. 
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December 2, 2011

Petition to Remove Silicon Dioxide

2. Public comment indicates that while organic alternatives exist that may replace silicon 

dioxide as currently listed, the Handling Committee is concerned that applicable

alternatives do not exist for sufficient uses and applications of silicon dioxide in organic 

handling. 

Given the above concerns, the NOSB voted to relist silicon dioxide and publically note that 

additional information, data, and clarification of processors’ needs regarding silicon dioxide 

would be needed for future deliberation during the upcoming discussion on silicon dioxide’s 

removal from § 205.605(b).

As such, § 205.605(b) today allows silicon dioxide to be utilized in organic foods labeled in the 

“organic” and “made with organic” categories. The petition currently under consideration is to 

remove its listing on § 205. 605(b), stating there now exists a viable, non-synthetic, certified 

organic substitute to silicon dioxide available from a rice-hull based material. This alternative 

substance exhibits similar functional properties as silicon dioxide since it is produced from rice 

hulls which naturally contain a high concentration of silica. In addition, the current petition 

claims that the rice-hull product’s applicability should not be in question as:

“The proposed rice concentrate has been produced and sold in commercial quantities 

(domestically and internationally) to organic and natural food / feed producers for many 

of the exact same uses as SiO2.”

While an extensive review has been completed by the Handling Committee concerning the 

environmental, health, and applicability concerns of synthetic dioxide from the TAP reviews, 

previous petitions, prior NOSB discussions; the primary consideration/debate for whether or 

not synthetic silicon dioxide should remain on § 205.605(b) is rooted in consideration of §

205.600(b)(1) which states:

The following criteria will be utilized in the evaluation of substances or ingredients for 

the organic production and handling sections of the National List:

(b) In addition to the criteria set forth in the Act, any synthetic substance used as a 

processing aid or adjuvant will be evaluated against the following criteria:

(1) The substance cannot be produced from a natural source and there are no organic 

substitutes

Given this section of the regulation, and the charge of the NOSB to make decisions consistent 

with the overall intent of the regulation, the NOSB has considered the current petition to 

remove silicon dioxide by analyzing the previous information as to why synthetic silicon dioxide 

was originally listed on § 205.605(b). Resultant of this analysis, it has been concluded that 

silicon dioxide was previously listed due its unique properties and its overall safety and limited 

environmental concerns. However, since the initial listing, the following new information 

regarding a new agricultural substitute has been presented: 
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December 2, 2011

Petition to Remove Silicon Dioxide

Table 1. Use Rates of Organic Rice Concentrate vs. SiO2

2007-2008* 2009-Present*

Spice Blends 1:1 or 1.2:1 1:1

Dry Beverages Did not work 1:1

Dried Fruit Did not work 1:1

Tablets 1.1 or 1.2:1 1:1

Sauce Mixes 1.1 or 1.2:1 1:1

Flavor Carrier (oil & water) 1.2:1 0.8:1 or 1:1

*Ratios are expresses as rice concentrate: SiO2

The above table from the petition attempts to demonstrate that the rice-hull based alternative 

described in the 2010 petition to remove silicon dioxide has been available since 2007 and has 

undergone reformulation in 2009 such that it now can be substituted for silicon dioxide nearly 

1:1 ratios. Given this new information, the NOSB must determine whether sufficient evidence 

has been presented by the petitioner as to whether this natural organic alternative is sufficient 

in all applications to remove silicon dioxide from § 205.605(b). 

While the new data does address concerns noted by the Handling Committee during the 

Sunset review process; the Handling Committee feels that it is still limited, not published from a 

third party source, and does not conclusively demonstrate its applicability in all products and 

processes. However, while the data presented in this petition is not sufficient to completely 

remove silicon dioxide, the Handling Committee feels that the availability of a natural 

alternative must be acknowledged. 

Therefore, with respect to the change in NOSB Policy and Procedures Manual, the Handling 

Committee did not vote to remove silicon dioxide in its entirety but recommends a change to 

the annotation to silicon dioxide as noted below to be consistent with the intent of §

205.600(b)(1).

Committee Recommendations

1. Motion to remove the following substance:

§ 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)).” 

(b) Synthetics allowed—Silicon dioxide
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December 2, 2011

Petition to Remove Silicon Dioxide

Committee Vote

Motion: John Foster Second: Steve DeMuri

Yes: 0 No: 5 Abstain: 0 Absent: 2

2. Committee Vote

Motion: John Foster Second: Steve DeMuri Motion to amend the annotation of the 

following substance:

§ 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)).” 

(b) Synthetics allowed—Silicon dioxide—providing sufficient evidence showing non-synthetic 

alternatives are not commercially available for a specific product/process is presented.

Yes: 5 No: 1 Abstain: 0 Absent: 1