Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

Date: May 25, 2012

Subject: Carrageenan: Listing at § 205.605(a) for Sunset 2013 

Chair: Barry Flamm

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action ___X_______

Guidance Statement __________

Other ___ _____

Statement of the Recommendation 

The Board recommends the relisting of carrageenan on the National List under section 

205.605(a) 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))” with the following annotations: 

1. Only carrageenan with the following CAS numbers are permitted for use as a food 

processing ingredient (additive): 9000-07-1 (general), 9062-07-1 (iota), 11114-20-8 

(kappa), and 9064-57-7 (lambda).

2. Carrageenan will not be allowed for use in infant formulas. Its use in foods for older 

infants (older than six months) and weaning foods for young children will be allowed.

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

It has been demonstrated that there is a continued need for carrageenan to be used in 

handling. There is still no organic substitute for some uses available at this time. 

While there have been concerns raised in some studies regarding adverse health effects 

caused by the use of carrageenan, most scientific reports tend to support the idea that the 

CAS numbers listed are for use as food ingredients and have been approved as such by 

the FDA. Carrageenan listed under other CAS numbers is not recommended for use in 

food production, as ingredients or otherwise.

The second annotation, regarding infants, is based on concerns that have been raised by 

the EU Scientific Committee on Food (SCF). Specifically the use of carrageenan in infant 

formulas for newborns. The SCF’s concern is based on facts from the Pediatric Nutrition 

Handbook, which explains that in new born infants the neonatal intestine is uniquely 

capable of absorbing macromolecules via endocytosis. This is the basis for the

recommendation by pediatricians to not feed infants solid foods until they are four to six 

months old, which also helps prevent food allergies. The SCF had no objections for its use 

for older infants or in weaning foods for young children. The Subcommittee feels that the 

addition of these two annotations to the recommendation addresses the concerns.

Committee Vote:
Moved: Harold Austin Second: Jean Richardson

Yes: 10 No: 5 Abstain: 0 Absent: 0 Recusal: 0

Committee Backup Vote:

Moved: Harold Austin Seconded: Zea Sonnabend

Yes: 11 No: 4 Abstain: 0 Absent: 0 Recusal: 0
National Organic Standards Board

Handling Committee

Sunset 2013 Proposed Recommendation

Carrageenan on 205.605(a)

May 22, 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

Subcommittee Summary:

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

and against its re-listing. 

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.

Carrageenan is used as a food additive in the production of many processed foods. It can be used to help 

bind water, as a thickening agent, emulsifier, gelling agent, glazing agent, as a bulking agent, binder, etc.

The FDA states 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. The 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 ocellatus, Eucheuma cottonii, Gigartina acicularis, 

Gigartina pistillata, Gigartina radula, and Gigartina stellata. The following CAS numbers list the types of 

Carrageenan considered as, food safe: 9000-07-1 (general), 9062-07-1 (iota), 11114-20-8 (kappa), and 

9064-57-7 (lambda).

While Carrageenan is a naturally occurring polysaccharide extracted from seaweed and considered nonsynthetic, the extraction process used may in some instances alter it. There are differing points of view 

as to whether or not the extraction process actually changes the physical nature of the material to the 

point where it should be considered a synthetic or not.

During public comment there were several concerns raised regarding the possible health risks from the 

use of Carrageenan. We feel that those risks can be addressed by allowing only Carrageenan with one of 

the four CAS numbers mentioned above to be recommended for use as a food processing ingredient or 

additive.
Further concerns were raised about its potential risk to new born infants. The recommendation by the 

EU Scientific Committee on Food (SCF) suffices to cover this area of concern. The SCF’s concern with 

Carrageenan and new born infants is based on facts from the Pediatric Nutrition Handbook that explains 

that in new born infants the neonatal intestine is uniquely capable of absorbing macromolecules via 

endocytosis. For this reason it is recommended by pediatricians to not feed infants solid foods until they 

are four to six months old, which helps prevent food allergies (as printed in the Pediatric Nutrition 

Handbook). The use of carrageenan in foods for older infants or weaning foods for young children does 

not appear to pose a concern, therefore uses in foods for older infants and young children should be ok.

The Handling Committee feels that that we have addressed the concerns that have been raised by 

adding annotations to the recommendation.

Based on public comment, carrageenan continues to be an important material used by the organic 

community and its stakeholders.

Recommendation:

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 group (s)). 

We recommend relisting under 605 (a)

(a) Non-synthetics allowed

We would also include the following two annotations:

Annotations:

The first annotation: only carrageenan that is in one of the following four CAS Numbers will be allowed 

for use as a food additive – 9000-07-1 (general), 9062-07-1 (iota), 11114-20-8 (kappa), and 9064-57-7 

(lambda). All other CAS numbers would not be recommended for use in food production, as an 

ingredient or otherwise.

The second annotation: carrageenan would not be allowed for use in infant formulas.

We 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 materials classification (agricultural, 

non-agricultural)(synthetic, non-synthetic) should be considered to ensure that the listed material has 

been properly classified and thus remove any further confusion from their status thus helping during 

future reviews.

Committee Vote:

6-Yes 0-No 0-Absent 0-Recused