Features

Certified Organic Flavors Now Required for Certification

By Scott Svihula Jan 22, 2019 1:18pm
Tea organic Organic Trade Association National Organic Standards Board
Scott Svihula
Scott Svihula, Owner of Hula Consulting, shares his opinion below on the National Organic Program's final rule to require organic flavors when they are available. here

Bergamot fruit (Getty Images/NakornChaiyajina)
Commercially available. The ability to obtain a production input in an appropriate form, quality, or quantity to fulfill an essential function in a system of organic production or handling, as determined by the certifying agent in the course of reviewing the organic plan.”

  1. To keep your organic certification, change the application of your 95% certified organic flavored teas to the 70%/30% category. The new ruling does not affect this category; though you will not be able to use the USDA seal. (see chart below for more details)
  2. Drop the 95% certified organic flavored teas from your organic certification; though you would only be able to mark the ingredients as organic in the ingredient statement. This could cause confusion with your customers, and if you are not certifying these, does it make sense to certify any of your teas?
  3. Work with your flavor supplier (and most likely other flavor suppliers) to create the same tasting flavor but in a certified organic form; knowing this will drive up the cost of goods. Once approved, you will wait 3-12 weeks to get the certification from the flavor company and then another 3-12 weeks to get your flavored tea certified. With a December 27th deadline, you will need to start working on this change over now and have the new flavors approved by the end of the second quarter.
 
FINAL RULE - FLAVORS
Peppermint (Getty Images/Amy_Lv)
“Flavors The final rule amends the National List to revise the annotation of flavors in § 205.605(a) to change the allowance for nonorganic flavors to require the use of organic flavors when they are commercially available. The listing of flavors in paragraph (a) reads as follows: Flavors—non-synthetic flavors may be used when organic flavors are not commercially available. All flavors must be derived from organic or nonsynthetic sources only and must not be produced using synthetic solvents and carrier systems or any artificial preservative. This rule retains requirements that all flavors must be derived from organic or nonsynthetic sources only and must not be produced using synthetic solvents and carrier systems or any artificial preservative. This rule applies to products in the ‘‘organic’’ and ‘‘made with organic (specified ingredients or food group(s))’’ categories. This rule change does not apply to nonorganic ingredients that may be used in up to 30 percent of ‘‘made with organic’’ products. Due to the number of distinctly different natural flavors and the pace of new product development in flavors, AMS has determined it would be impractical to list individual flavors on the National List to indicate which are commercially available in organic form. AMS has reviewed and agrees with the NOSB recommendation that the annotation for flavors be amended to clarify its use in organic handling. AMS received comments on the proposed rule for amending the annotation.”

  ORGANIC CATEGORIES
100% Organic •       All organic ingredients •       Any processing aids must be organic •       Flavors must be certified organic •       No non-organic ingredients are used •       USDA seal allowed •       Must list organic certification agency •       List ingredients as organic in ingredient statement
Organic 95% Rule •       At least 95% organic ingredients •       Remaining 5% can be non-organic allowed ingredients •       Flavors must be certified organic when commercially available •       All agricultural ingredients must be organic unless not available •       USDA seal allowed •       Must list certification agency •       List ingredients as organic in ingredient statement
Made with Organic Ingredients 70%/30% Rule •       At least 70% organic ingredients •       Remaining 30% can be non-organic allowed ingredients or non-organic agricultural ingredients •       Flavors must be natural non-gmo organic compliant •       USDA seal prohibited •       Must list certification agency •       List ingredients as organic in ingredient statement
Products with less than 70% Organic Ingredients •       Any level of organic ingredients •       No restriction on remaining ingredients •       No certification claims can be made •       USDA seal PROHIBITED •       Only mention organic in ingredient listing
Tea organic Organic Trade Association National Organic Standards Board flavors certified organic Industry Analysis Tea Nerdery Features