Certified Organic Flavors Requirements: What You Need To Know

In December 2019, The National Organic Program finalized their ruling that amends the National List of Allowed and Prohibited Substances. The rule now dictates that certified organic flavors must be used in organic products when commercially available. What does that mean for manufacturers? Here’s a breakdown of the terminology, the ruling, its requirements and how those can be met:

What’s the history behind the ruling?

• 1995: The National Organic Standards Board recommends the use of natural flavors in organic foods. This created an expectation that organic flavors would continue to develop over time and would be increasingly incorporated into organic products.
• Nov. 6, 2014: The Organic Trade Association submits a petition to encourage the use of organic flavors instead of natural flavors.
• Oct. 29, 2015: In response to the OTA’s petition, the NOSB announces a recommendation to revise the annotation on the National List of Allowed and Prohibited Substances for flavors to require organic when commercially available.
• Dec. 27, 2018: The NOP approves the NOSB recommendation and issues a final rule amending the National List of Allowed and Prohibited Substances.
• Dec. 27, 2019: The organic-flavors-only rule is implemented.

What are organic flavors vs. natural flavors?

To be considered organic, a flavor must comprise at least 95 percent organically produced ingredients. The remaining 5 percent need to be on the National List of Allowed Substances, and organic if commercially available.

What is considered a natural flavor?

The FDA defines natural flavors as “the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional.”

When did organic products have to move away from natural flavors?

Until 2019, natural flavors were permitted in certified organic products, largely due to the lack of available organic alternatives. Guidelines were in place to ensure the natural flavors did not compromise the overall quality of organic products — for example, they could not contain synthetic solvents or artificial preservatives.

Why are organic flavors now required?

The NOP’s ruling is a follow-up to a petition submitted by the Organic Trade Association in 2014 to broaden the commercial availability and use of organic flavors. At that time, the OTA found that the organic flavor sector had grown so significantly that the use of non-organic flavors could no longer be justified. (There are currently more than 3,000 certified organic flavors available.)

Who benefits most from this action?

This is great news for farmers, as it will help build markets for their organic ingredients. Consumers also are big winners because this will increase the number and variety of organic components in the products they buy.

When must manufacturers be compliant?

Compliance is evaluated on an ongoing basis. A manufacturer will be compliant when they can provide documentation that they have sourced and obtained organic flavors to replace natural flavors in their products. If they are not already doing so, manufacturers should begin making efforts to transition their flavors and create a plan to work regularly with their certifiers. The OTA has published a guidance document to assist brands with this change, which will be managed through existing Organic Handling Plans. (The use of natural flavors is still permitted if the equivalent certified organic flavor is not commercially available in the quantity needed.)

How can Global Organics help?

“We are very excited for the farmers and manufacturers we work with who create organic flavors. They have gone to great effort to produce some of the finest flavors available, and we are looking forward to helping our customers find the perfect match for their applications,” says Dave Alexander, president of Global Organics.

Global Organics offers many certified organic flavors to enhance your brand’s organic products, including:

Organic vanilla powder: Our organic vanilla powder is sourced from a farmer-owned vanilla processor and exporter in Madagascar. It’s made from finely ground Madagascar Bourbon vanilla beans with no alcohol, fillers or flow agents. Not an extract, it works especially well in baked goods as the flavor will not ‘flash’ off at higher temperatures.

Organic caramel flavors: Our organic liquid caramels are crafted by a fifth-generation, family-owned company in France. With distinctive “fruity” notes from the organic sugar cane, they provide rich flavor enhancement to a wide variety of applications, from sauces to frozen desserts.

Organic freeze-dried coffee: Our specialty grade organic coffee comes from Eastern Minas Gerais, Brazil, and offers notes of caramel and chocolate alongside a fruity acidity.

To learn more about our organic flavors and obtain a sample, please contact your Global Organics account manager or email info@global-organics.com.

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