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IN THE KNOW ABOUT THE “O”
www.ota.com
CERTIFIED ORGANIC FLAVORS NOW REQUIRED IN ORGANIC PRODUCTS
to help certified operators develop a sound and sensible organic flavor search plan that can be submitted to and agreed upon by the accredited certifier.
The intent of the final rule is continuous improvement
to increase the growth and use of organic flavors over time. The intent is not to hand down non-compliances
to companies unable to secure organic flavors when
they do not meet the specifications needed to make a product that organic shoppers will buy. Instead, the goal is for companies to start the process, make a search and evaluation process, and work with their certifiers on an annual basis to determine when and what organic flavors are commercially available.
Commercial availability is defined as the ability to obtain an ingredient or substance in an appropriate form, quality or quantify to fulfill an essential function in an organic product as determined by a certifying agent in the course of reviewing a company’s organic plan. An organic handling system plan must include a list of each substance to be used, including its composition, source, location where it will be used, and documentation of commercial availability. Price cannot be a consideration in determining commercial availability.
In addition to its practical guide, the Organic Trade Association has created a webinar entitled New Rules: Requirement for Using Organic Flavors in Processed Organic Products. The webinar provides a first look
at the new industry guidance on use of organic flavors developed by the Organic Trade Association. Although the webinar was originally presented in late January, it will still be available on demand by contact Libby Mucciarone at the Organic Trade Association.
A final rule published by the U.S. Department of Agriculture’s National Organic Program (NOP) now requires the use of certified organic flavors in certified organic products when they are commercially available. The rule was implemented and went into effect on December 27, 2019.
“It is now time that the regulations catch up with the marketplace,” says Laura Batcha, CEO and Executive Director of the Organic Trade Association. “Our position is that the organic flavor supply has grown to a size where it is no longer appropriate to allow the use of non-organic natural flavors in certified organic products.”
The Organic Trade Association submitted a petition to help grow the availability and use of organic flavors in 2014. Natural flavors have been included on the National List since it was first implemented in 2002. Since that time, however, many organic flavors have been developed, and are being successfully used by many companies.
“When we filed the petition, we realized the number of available certified organic flavors was not adequate to meet the current total needs of the organic marketplace. However, given the tremendous growth of organic flavors, we took this proactive step to push the needle in the direction of continuous improvement by requiring the use of organic flavors when they are available in the quality, quantity and form needed,” says Gwendolyn Wyard, Vice President of Regulatory and Technical Affairs.
Guide to apply new rule
Currently there is no formal guidance from the National Organic Program on the commercial search and use of natural and organic flavors for NOP certified products. However, the Organic Trade Association has developed a practical guide for its members and others in the sector to comply with the new requirements for flavors that reflects the National Organic Standards Board recommendations concerning commercial availability searches for ingredients and related instruction from NOP on filing a petition.
According to the Guide, companies using natural flavors in certified organic products do not need to panic about the change. The trade association has drawn up information
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