People often don’t realize that organic rules do not stop at the farm level but go all the way through to the finished product. In this article we will answer some of the common questions about organic food processing.

Q: What is organic processing?

A: According to the Organic Trade Association, “Organic foods are minimally processed without artificial ingredients or synthetic preservatives to maintain the integrity of the product that began with organic practices on the farm.” On or off farm, certified organic products can never use GMOs, irradiation, sewerage sludge, artificial flavors, colors or preservatives.

Also certain processes are not allowed in organic processing. These are typically processes that involve the use of artificial chemicals. For example, protein extraction with artificial solvents is not allowed and artificial hydrogenation of oil is not allowed.

Authorized organic processes are simple processes such as: cooking, baking, curing, heating, drying, mixing, grinding, churning, separating, extracting, slaughtering, cutting, fermenting, distilling, preserving, dehydrating, freezing, chilling or otherwise manufacturing food products. A food processor or manufacturer has to be certified as an organic operation by certifiers accredited by the USDA National Organic Program (NOP) and they have to follow strict guidelines set by the NOP for organic food handlers*.

(*In NOP terminology, processors are called handlers)

Q: What additives/substances are allowed in organic processing?

A: When it comes to additives, food processors refer to the National List of Allowed and Prohibited Substances (DRF205.605) to know what they can use for minor ingredients in their organic products. Certified organic products can contain non-organic ingredients, not to exceed 5% of total weight or fluid volume, as long as they are allowed and used according to the list. See our article on organic food labeling for the rules for “made with organic” products.

Common non-organic and non-agricultural substances, including processing aids, on the “allowed” list include vitamins and minerals, carbon dioxide (fizz in soda), pH adjusters such as calcium carbonate, dairy cultures and sodium bicarbonate or baking soda. In organic processing less than 100 non-agricultural minor ingredients are allowed for use, in conventional products that number can be well over 3,000.

A quick refresher, a processing aid is an agent used as a technical aid to make a product, but does not remain in the finished product (it is fully removed or only presents "as traces” so it is not quantifiable in the final product). Of course all ingredients need to be in the ingredient list, however, processing aids do not have to be declared as theoretically they are not present in the end product. But any substance added and detectable above trace amounts in the end product is considered an ingredient and has to be declared – and for organic, this substance has to be on the allowed list.

Included in the regulations (DRF205.606) is a list of agricultural products that are non-organic that can be used only if an organic version is not available commercially. This list includes substances like fruit and vegetable colors, cornstarch (native) and whey protein concentrate.

Here’s an example of how this all works. For a typical organic fruit yogurt, 95% of the yogurt’s ingredients are made up of cultured organic milk, organic fruit and organic sugar. In the remaining 5%, the yogurt can have pectin (a natural gelling agent found in fruits) that is not available commercially as organic and Vitamin D3 (non-agricultural, non-organic, synthetic) as both of these items are on the “allowed” list.

Q: Does the processing of organic foods need to be documented?

A: Oh yes! A certified organic processor/handler is required to protect the organic integrity of organic products and ingredients while they are under their control. A processor must complete a Handler Organic System Plan that describes their handling and processing activities-including information about the type of business, ingredient purchases, transportation of raw ingredients, storage, cleaning and sanitation, processing, pest management, sales and records. This Handler Organic System Plan is then assessed and approved annually, at a minimum, by an Organic Certification Agency in order for the processor to have and maintain their organic certification.

Q: How do handlers/processors maintain organic integrity?

A: Integrity can be compromised in two main ways, through contamination or unintentional or intentional comingling. If ingredients or products come in contact with prohibited chemicals such as a cleanser or a pesticide it is contaminated. If organic ingredients or products come in contact with non-organic ingredients or products while in production, transport or storage, they are considered mixed or comingled. Certified organic processing facilities must document how they prevent contamination and comingling, for example, outlining clean out procedures. Annually, organic certifying agents conduct inspections and audits to verify all records. This must be done in order for a handler to maintain organic certification.

Certification agencies also verify that non-organic products have not been intentionally mixed with organic products and sold as ‘organic.” For this, auditors verify processing records but also company’s financial records such as invoices, purchasing order, financial transactions, etc. This is called ”mass balance” verification. It is a check to verify that the quantity of raw materials bought or used as organic corresponds to the quantity of finished products produced and/or sold as certified organic.

Being organic certified, Global Organics is audited every year by ICS and ECOCERT and has to demonstrate accurate mass balance for the ingredients we source and sell in the North America and in the EU.

For more information, watch this video from the USDA Agricultural Marketing Service (AMS) National Organic Program (NOP) titled Organic Integrity in the Supply Chain: Overview for Certified Organic Handlers.

Q: Are the organic processing rules different for imported products or ingredients?

A: There are slight differences between different countries’ standards but to import certified organic products or ingredients they must be accepted and approved by the U.S. NOP to be in compliance with NOP requirements.

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Bonus Question: Who needs to be certified organic to make or sell organic certified products?

Answer:

• Farms
• Processors
• Handlers - only if they are repacking the product or labeling/re-labeling and selling it under their own brand This includes handlers who sell products online.
• Businesses (such as brokers, warehouses, etc.) that don't repackage still need to comply with specific sections of the USDA organic regulations about preventing contamination and comingling.

Companies, which sell less than $5,000 per year, are exempt from carrying a certification and its associated costs. However these companies still have to demonstrate to organic certification agencies that good organic practices are followed and product organic integrity is achieved.

Technically, Global Organics' warehouses are not required to be certified handlers as our products are not repackaged or re-labeled. We typically ask our warehouses to be certified to provide extra assurance of organic integrity.

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