Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

 

Date: October 28 , 2010 

Subject: Response to Pectin Petition 

Chair: Daniel G. Giacomini 

 

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action X 

 

Statement of the Recommendation (Including Recount of Vote): 

 

The NOSB recommends that Pectin (low methoxy) be moved to 205.606 and 

united with Pectin (high methoxy) under 1 listing with a new annotation: “Pectin 

(non-amidated forms only)”. The Handling committee voted 6 yes and 1 absent 

in its recommendation to the full board. The NOSB voted the material as nonsynthetic; 13 yes 1 no, and voted for this recommendation 13 yes, 0 no, 1 

abstention, 0 absent, and 0 recusals. 

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

 

Both high and low methoxy pectin result from the same origin and process 

which is an extraction and hence non-synthetic. The amidation process creates 

a synthetic. The placement of pectin on 205.606 is consistent with OFPA and 

the NOP. 

 

NOSB Vote: 

Moved: Joe Smillie Second: Tracy Miedema 

Yes: 13 No: 0 Abstain: 1 Absent: 0 Recusal: 0 
NOSB COMMITTEE RECOMMENDATION 

Form NOPLIST1. Committee Transmittal to NOSB 

For NOSB Meeting: ____October 2010 __________ Substance: __Pectin (low-methoxy) _____

Committee: Crops  Livestock  Handling X Petition is for:__ Moving Pectin (low-methoxy) from National List § 205.605 to 

205.606_________________ 

A. Evaluation Criteria (Applicability noted for each category; Documentation attached) Criteria Satisfied? (see B below) 

1. Impact on Humans and Environment Yes  No  N/A X

2. Essential & Availability Criteria for moving 605 to 606 Yes X No  N/A 

3. Compatibility & Consistency Yes  No  N/A X

4. Commercial Supply is Fragile or Potentially Unavailable as Organic (only for 606) Yes  No  N/A X 

B. Substance Fails Criteria Category: ___n/a______ Comments: 

C. Proposed Annotation (if any): __n/a 

 Basis for annotation: To meet criteria above: _______ Other regulatory criteria: _______ Citation:______________________ 

D. Recommended Committee Action & Vote (State Actual Motion): _ 

 Motion: Moved that Pectin (low-methoxy, non-amidated) is non-synthetic, agricultural: 

Motion by: Smilie Seconded: Demuri Yes: 6 No: 0 Absent: 1 Abstain: 0 

 Motion: Moved that the following changes be made to the NL listings for pectin: 

o Pectin (low-methoxy) be removed from listing on 205.605(b) 

o Pectin (high-methoxy) be removed from listing on 205.606 

o Pectin (non-amidated forms only) be added to 205.606 

Motion by: Smilie Seconded: Demuri Yes: 6 No: 0 Absent: 1 Abstain: 0

Crops Agricultural X Allowed1

 X 

Livestock Non-Synthetic X Prohibited2 

Handling X Synthetic Rejected3

No restriction Commercially UnAvailable as Organic1

 X Deferred4 

________________________________________________________________________________________________________ 

1) Substance voted to be added as “allowed” on National List to § 205.606 with Annotation (if any) ______________________ 

________________________________________________________________________________________________________ 

2) Substance to be added as “prohibited” on National List to § 205. with Annotation (if any) _________________________ 

________________________________________________________________________________________________________ 

Describe why a prohibited substance:__________________________________________________________________________ 

________________________________________________________________________________________________________ 

 

3) Substance was rejected by vote for amending National List to § 205. _____ Describe why material was rejected:___________ 

________________________________________________________________________________________________________ 

4) Substance was recommended to be deferred because 

E. Approved by Committee Chair to transmit to NOSB: 

______________________________________ _________________________ 

 Committee Chair Date
NOSB EVALUATION CRITERIA FOR SUBSTANCES ADDED TO THE NATIONAL LIST

Category 1. Adverse impacts on humans or the environment? Substance - _Pectin (lowmethoxy)___

Question Ye

s 

No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Are there adverse effects on 

environment from manufacture, 

use, or disposal? 

[§205.600 b.2] 

 X Reviewed in original 1995material review; no 

changes 

2. Is there environmental 

contamination during 

manufacture, use, misuse, or 

disposal? [§6518 m.3] 

 X 

3. Is the substance harmful to 

the environment? 

[§6517c(1)(A)(i);6517(c)(2)(A)i] 

 X 

4. Does the substance contain 

List 1, 2, or 3 inerts? 

[§6517 c (1)(B)(ii); 

205.601(m)2] 

 X 

5. Is there potential for 

detrimental chemical 

interaction with other materials 

used? 

[§6518 m.1] 

 X 

6. Are there adverse biological 

and chemical interactions in 

agro-ecosystem? [§6518 m.5] 

 X 

7. Are there detrimental 

physiological effects on soil 

organisms, crops, or livestock? 

[§6518 m.5] 

 X 

8. Is there a toxic or other 

adverse action of the material 

or its breakdown products? 

[§6518 m.2] 

 X 

9. Is there undesirable 

persistence or concentration of 

the material or breakdown 

products in 

environment?[§6518 m.2] 

 X 

10. Is there any harmful effect 

on human health? 

[§6517 c (1)(A)(i) ; 6517 

c(2)(A)i; §6518 m.4] 

 X 

11. Is there an adverse effect 

on human health as defined by 

applicable Federal regulations? 

[205.600 b.3] 

 X 

12. Is the substance GRAS 

when used according to FDA’s 

good manufacturing practices? 

[§205.600 b.5] 

 X 

13. Does the substance 

contain residues of heavy 

metals or other contaminants 

in excess of FDA tolerances? 

[§205.600 b.5] 

 X 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable. 
Category 2. Is the Substance Essential for Organic Production? Substance - _Pectin (lowmethoxy)___

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Is the substance 

formulated or manufactured 

by a chemical process? 

[6502 (21)] 

X See attached Committee Summary included 

after Category 4 Checklist 

2. Is the substance 

formulated or manufactured 

by a process that chemically 

changes a substance 

extracted from naturally 

occurring plant, animal, or 

mineral, sources? [6502 (21)] 

 X See attached Committee Summary included 

after Category 4 Checklist 

3. Is the substance created 

by naturally occurring 

biological processes? [6502 

(21)] 

 X See attached Committee Summary included 

after Category 4 Checklist 

4. Is there a natural source of 

the substance? [§205.600 

b.1] 

X See attached Committee Summary included 

after Category 4 Checklist 

5. Is there an organic 

substitute? [§205.600 b.1] 

 X See attached Committee Summary included 

after Category 4 Checklist 

6. Is the substance essential 

for handling of organically 

produced agricultural 

products? [§205.600 b.6] 

X 

 

Jams & jellies cannot be made without pectin 

7. Is there a wholly natural 

substitute product? 

[§6517 c (1)(A)(ii)] 

X The non-amidated forms of pectin are nonsynthetic 

8. Is the substance used in 

handling, not synthetic, but 

not organically produced? 

[§6517 c (1)(B)(iii)] 

X See attached Committee Summary included 

after Category 4 Checklist 

9. Is there any alternative 

substances? [§6518 m.6] 

 X See attached Committee Summary included 

after Category 4 Checklist 

10. Is there another practice 

that would make the 

substance unnecessary? 

[§6518 m.6] 

 X 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable. 
Category 3. Is the substance compatible with organic production practices? SubstancePectin (low-methoxy)

Question Yes No N/A1 Documentation 

(TAP; petition; regulatory agency; other) 

1. Is the substance 

compatible with organic 

handling? [§205.600 b.2] 

 X Reviewed in original material review; no 

changes 

2. Is the substance consistent 

with organic farming and 

handling? [§6517 c (1)(A)(iii); 

6517 c (2)(A)(ii)] 

 X 

3. Is the substance 

compatible with a system of 

sustainable agriculture? 

[§6518 m.7] 

 X 

4. Is the nutritional quality of 

the food maintained with the 

substance? [§205.600 b.3] 

 X 

5. Is the primary use as a 

preservative? [§205.600 b.4] 

 X 

6. Is the primary use to 

recreate or improve flavors, 

colors, textures, or nutritive 

values lost in processing 

(except when required by law, 

e.g., vitamin D in milk)? 

[205.600 b.4] 

 X 

7. Is the substance used in 

production, and does it 

contain an active synthetic 

ingredient in the following 

categories: 

a. copper and sulfur 

compounds; 

 X 

b. toxins derived from 

bacteria; 

 X 

c. pheromones, soaps, 

horticultural oils, fish 

emulsions, treated seed, 

vitamins and minerals? 

 X 

d. livestock parasiticides and 

medicines? 

 X 

e. production aids including 

netting, tree wraps and seals, 

insect traps, sticky barriers, 

row covers, and equipment 

cleaners? 

 X 

1

If the substance under review is for crops or livestock production, all of the questions from 205.600 (b) are N/A—not applicable. 
Category 4. Is the commercial supply of an agricultural substance as organic, fragile or 

potentially unavailable? [§6610, 6518, 6519, 205.2, 205.105 (d), 205.600 (c) 205.2, 205.105 (d), 205.600 (c)] 

Substance - __ Pectin (low-methoxy)

Question Yes No N/A Comments on Information 

Provided (sufficient, plausible, 

reasonable, thorough, complete, 

unknown) 

1. Is the comparative description provided 

as to why the non-organic form of the 

material /substance is necessary for use in 

organic handling? 

 X Reviewed in 1995 original material 

review; no changes 

2. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained organically 

in the appropriate form to fulfill an 

essential function in a system of organic 

handling? 

 X 

3. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained organically 

in the appropriate quality to fulfill an 

essential function in a system of organic 

handling? 

 X 

4. Does the current and historical industry 

information, research, or evidence 

provided explain how or why the material 

/substance cannot be obtained organically 

in the appropriate quantity to fulfill an 

essential function in a system of organic 

handling? 

 X 

5. Does the industry information provided 

on material / substance non-availability as 

organic, include ( but not limited to) the 

following: 

a. Regions of production (including factors 

such as climate and number of regions); 

 X 

b. Number of suppliers and amount 

produced; 

 X 

c. Current and historical supplies related to 

weather events such as hurricanes, floods, 

and droughts that may temporarily halt 

production or destroy crops or supplies; 

 X 

d. Trade-related issues such as evidence 

of hoarding, war, trade barriers, or civil 

unrest that may temporarily restrict 

supplies; or 

 X 

e. Are there other issues which may 

present a challenge to a consistent 

supply? 

 X 
Committee Summary: 

The petitioner requested that pectin (low-methoxy) be moved from 205.605 to 205.606 

so that organic production methodology would be required and the material would be 

subject to commercial availability requirements. Pectin (high-methoxy) is already listed 

on 205.606. These two pectins have different food processing uses (i.e., low methoxy 

pectin binds with sugar at a lower brix level), but are manufactured using essentially the 

same process. The petitioner presented documentation that stated that the main 

difference between high and low methoxy is the degree of esterification that results only 

from a longer extraction period. This longer extraction process does not result in 

chemical change and hence the material is not synthetic. The origin of the raw material 

and the extraction process used are identical for both low and high methoxy pectins. 

The real difference in pectin products is whether they are amidated (chemically modified 

with ammonia after the extraction process) or not. In investigating the original NOSB 

analysis of low-methoxy pectin, it seems that they either thought it was always amidated 

or that it went through a second process, which may be why it was placed on 

205.605(b). The EU organic regulation allows pectin, does not distinguish between high 

and low methoxy forms and prohibits amidated forms. The original technical review 

dated August 17th, 2009, and the subsequent supplemental technical review requested 

by the Handling Committee and dated July 30th 2010 supported the petitioners position. 

Therefore we think that Pectin (low-methoxy) be moved to 205.606 and combined with 

Pectin (high-methoxy) into one listing with a new annotation to read Pectin (nonamidated forms only).