Understanding Non-Agricultural Substances and Non-Organically Produced Agricultural Products in USDA NOP Regulations
Anil Mathew Varghese
Organil Services (Registered Organic Regulatory Certification Consultancy/Training/Advisory/Assessment/ Accreditation Consultancy) Mobi # +91 8606551335
?? (Written by Anil M V, 24 years experience, {Bsc. Agric, MBA, CTP}Founder, * Organil Services)
In the USDA National Organic Program (NOP) regulations, two categories of substances can be used under specific conditions in the production of organic foods: non-agricultural substances and non-organically produced agricultural products. Understanding the distinction between these two categories is crucial for food business operators to ensure compliance with organic standards while maintaining the integrity of their products.
§205.270 Organic handling requirements >(b) Nonagricultural substances allowed under §205.605 and nonorganically produced agricultural products allowed under §205.606 may be used. (1) In or on a processed agricultural product intended to be sold, labeled, or represented as “organic,” pursuant to §205.301(b), if not commercially available in organic form. (2) In or on a processed agricultural product intended to be sold, labeled, or represented as “made with organic (specified ingredients or food group(s)),” pursuant to §205.301(c).
A. Non-Agricultural Substances
Non-agricultural substances, as the name suggests, are materials that are not derived from agricultural products. These substances are typically synthetic or naturally occurring minerals and compounds that can be used in the processing of organic foods. The NOP has a specific list of allowed non-agricultural substances under §205.605, which includes both synthetic and non-synthetic substances that are deemed safe and necessary for organic production.
For example, citric acid is a non-synthetic substance commonly used in organic food processing. It is derived from the fermentation with microorganisms and serves as a natural preservative and flavor enhancer in various organic products. Another example is sodium bicarbonate, a synthetic substance that is widely used as a leavening agent in organic baking.
These substances are included in the organic standards because they meet the stringent criteria set by the NOP, which include considerations of their impact on human health and the environment. The use of non-agricultural substances must be justified by their necessity in processing and the lack of suitable organic alternatives.
B. Non-Organically Produced Agricultural Products
Non-organically produced agricultural products, allowed under §205.606, are ingredients that are agricultural in nature but have not been produced according to organic standards. These products can only be used in organic processing when organic versions are not commercially available in sufficient quantities or quality. The NOP maintains a specific list of these allowable non-organic agricultural ingredients, ensuring that their use is strictly regulated and monitored.
A common example of a non-organically produced agricultural product that might be allowed under certain conditions is cornstarch. If an organic processor cannot source enough organic cornstarch to meet their production needs, they may use non-organic cornstarch, provided it is included on the NOP's list of acceptable non-organic agricultural products.
Another example is certain colors derived from agricultural products, such as annatto extract, which is used for coloring in organic foods. If organic annatto extract is not available, a non-organic version may be used under the specific conditions outlined by the NOP.
The inclusion of these non-organic agricultural products ensures that organic processors have the flexibility to maintain production without compromising the organic integrity of their final products. However, the use of these ingredients is carefully controlled to ensure that the overall organic content and quality of the product remain high.
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For food business operators, understanding the distinction between non-agricultural substances and non-organically produced agricultural products is essential for maintaining compliance with USDA NOP regulations. Non-agricultural substances include certain synthetic and non-synthetic materials that are allowed in organic processing for their functional benefits, such as citric acid and sodium bicarbonate. Non-organically produced agricultural products are specific agricultural ingredients that can be used when organic alternatives are not available, such as cornstarch and annatto extract.
By adhering to these guidelines, food processors can ensure that their products meet organic standards while addressing practical challenges in sourcing and production. This balance helps to uphold the integrity and trust in organic labels, benefiting both producers and consumers in the organic food market.
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?? (Written by Anil M V, 24 years experience, {Bsc. Agric, MBA, CTP}Founder, * Organil Services)
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Implications for Food Business Operators Understanding the distinction between these two categories is essential for food business operators striving for organic certification. Nonagricultural substances allowed under §205.605 are typically used for their functional properties, such as preservatives or processing aids, and must be included on the National List. Nonorganically produced agricultural products permitted under §205.606 can only be used when organic alternatives are not available, and their use must be justified and documented.