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Understanding Organic Flavor Regulations and Compliance Requirements

Consumer demand for organic food is growing, especially outside of the established fresh food and produce categories.  From pancake mix to potato chips and hard seltzer to hummus, consumers want their prepared food and beverages to be certified organic, too!  Organic is a hot category for new product introductions and innovation, with category opportunities maturing as rapidly as they are introduced.  Understanding and abiding by organic flavor regulations in a fast-paced, competitive market poses challenges for both new and seasoned product developers. 

Basic organic flavor regulations

To protect the integrity of the organic food industry, certification requirements are naturally strict.  Organic regulations also change frequently, making it difficult to keep pace.  One year a product may be in compliance, and the next year…it’s not.  No food or beverage processor wants to find themselves in that situation!  However, there are a few consistent production and labeling requirements that a certified organic product must comply with, including1

  • Produced without excluded methods (non-approved pesticides and herbicides, genetic engineering, ionizing radiation, sewage sludge)
  • Produced per the National List of Allowed and Prohibited Substances (National List)
  • Overseen by a USDA National Organic Program authorized certifying agent, following all USDA organic regulations 

Regulations also prohibit organically processed foods from containing artificial preservatives, colors, or flavors and require that their ingredients are organic (with some minor exceptions).

Vanilla Organic Flavors, organic flavor regulations
Organic means trust and transparency, and forges more meaningful connections between consumers and the land+hands that cultivate our food

Organic flavor classifications

At Blue Pacific, we have a solid understanding of organic flavor regulations because we’ve been offering organic flavors for over 20 years.  We have three main classes of organic flavors: 100% Certified Organic Flavor, 95% Certified Organic Flavor, and “Made With” Organic Flavor.  The class you use depends on how you intend to label and market your finished product.

100% Certified Organic Flavor

  • Any product that contains 100% organic ingredients (excluding salt and water)
  • Most raw, unprocessed farm products can be designated “100 percent organic” 
  • Processing aids must also be organic
  • Product labels state the name of the certifying agent on the information panel and identifies organic ingredients
  • Can be labeled with USDA organic seal and be represented as organic

95% Certified Organic Flavor

  • All agricultural ingredients are certified organic, except when commercially unavailable
  • Up to a combined total of 5%* of non-organic content is used (excluding salt and water)
  • Product labels state the name of the certifying agent on the information panel and identifies organic ingredients
  • Can be labeled with USDA organic seal and be represented as organic

*Regarding the remaining 5% that may be nonorganic, very few substances are allowed and must be approved for use as per 7 Code of Federal Regulations (CFR) 205.605 and 205.606, the National List of Allowed and Prohibited Substances2.

“Made With” Organic Flavor

  • The product must have at least 70% organic certified ingredients (excluding salt and water) 
  • Cannot be labeled with USDA organic seal or be represented as organic

Staying current with regulatory changes

On December 27, 2018 the Agricultural Marketing Service (AMS) published a Federal Register notice amending the USDA National Organic Program’s National List of Allowed and Prohibited Substances in organic production.  The new annotation requires the use of organic flavors when they are commercially available in place of nonorganic natural flavors.  This revision is not applicable to nonorganic flavors that may be used in up to 30% of “made with organic” products.  This rule was fully implemented on December 27, 20193.  In response, Blue Pacific Flavor’s R&D and Regulatory and Compliance teams have been working constantly to source organic raw materials and offer certified organic versions of our organic compliant flavors.

Child Eating Organic Apple
Organic Apples Basket
With an orchard fresh, Farm to FlavorTM taste, our organic apple flavors are some of our favorites!  

Our commitment to compliance

When it comes to organic food and beverage, we’re all-in.  We believe and invest in organic because we’re invested in a healthier, more sustainable world for all of us.  When you buy organic flavor from Blue Pacific, you’re not just buying a fuzzy peach or juicy strawberry flavor – you’re buying peace of mind.  Our Regulatory and Compliance team fully evaluates each flavor from supply chain to finished product, ensuring that our Certified Organic Flavors meet or exceed USDA requirements. Flawless understanding of organic flavor regulations ensures we provide our customers flavors they can trust.

Bottom line: You don’t need to navigate organic product regulations in the dark!  Contact us with your labeling questions, we’re happy to help shine a light on this confusing area.  

We welcome you to taste the difference! Request a sample of our organic flavors today.

We’re passionate about providing the highest level of customer service. Let our flavor business help you build your food or beverage business.

Organic Blueberries In Basket
Organic Lemons On Tree
Organic Straberries In Basket, organic flavor regulations

References

  1. Electronic Code of Federal Regulations (eCFR). Electronic Code of Federal Regulations (eCFR). (2020). Retrieved 10 December 2020, from https://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=9874504b6f1025eb0e6b67cadf9d3b40&rgn=div6&view=text&node=7:3.1.1.9.32.7&idno=7
  1. National Organic Program; Amendments to the National List of Allowed and Prohibited Substances (Crops, Livestock and Handling). (2018, December 27). Federal Register. Retrieved 10 December 2020, from https://www.federalregister.gov/documents/2018/12/27/2018-27792/national-organic-program-amendments-to-the-national-list-of-allowed-and-prohibited-substances-crops
  1. Organic Labeling Standards | Agricultural Marketing Service. (n.d.). Www.Ams.Usda.Gov. Retrieved December 10, 2020, from https://www.ams.usda.gov/grades-standards/organic-labeling-standards#:~:text=%E2%80%9C100%20percent%20organic%E2%80%9D%20can%20be
  1. USDA National Organic Program | Agricultural Marketing Service. (2012). Labeling Organic Products Fact Sheet [PDF]. Retrieved 10 December 2020, from https://www.ams.usda.gov/sites/default/files/media/Labeling%20Organic%20Products%20Fact%20Sheet.pdf. 

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