Now’s the time for evaluating and enhancing organic compliance & flavor profiles

September 12, 2019
September 12, 2019 Roger Lane

Now’s the time for evaluating and enhancing organic compliance & flavor profiles

In just a few years, the “organic” label has spread from specialty food stores, to first a corner of mainstream grocery stores, and now several aisles. And with the continued rise of consumer demand for clean labels and transparent ingredient labeling, there’s a bigger push than ever for all things organic.

On December 27, 2019, the NOP will require the use of organically certified flavors whenever commercially available.

Getting to organic in the world of flavor delivery is sometimes easier said than done. It can get tricky for consumers and manufacturers alike, thanks to lingual subtleties such as “organic” vs. “made with organic” claims, for instance. What constitutes “natural,” and how do those terms all play together?

So, what is a “natural” flavor, then? Here’s a breakdown according to USDA National Organic Program:

  • Natural flavors authorized for use in NOP “organic” or “made with organic” (70 percent to 95 percent) products must not be produced using synthetic extraction solvents and must not contain any synthetic carrier systems or any artificial preservatives.
  • Natural flavors, including any solvents, carriers, preservatives or other processing aids used or contained therein, must not be produced and handled with the use of excluded (GMO) methods.
  • Ionizing radiation must not be used in the production or handling of the flavor.
  • If the natural flavor contains organic ingredients that count toward a finished product’s organic content, the manufacturer of that flavor must be certified organic, and the flavor in question must be certified or verified by an accredited certifying agent.
  • The material must legally be able to be identified as a “natural flavor” per the FDA on the ingredient panel of a final product; the only exceptions being


  1. Where the flavor is a single-ingredient material, such as bergamot oil. In such cases, the flavors should be labeled by its common name; e.g., “bergamot oil”; and
  2. Where the flavor is a natural smoke flavor. In such cases, it must either be listed as “natural smoke flavoring” on the ingredient panel or the product name/description must identify the product or ingredient therein, as “smoked,” “smoky,” or a similar description.


Sorting this all out is the job of the National Organic Standards Board, or NOSB. Its members regularly review substances included on the National List of Allowed and Prohibited Substances, and then make recommendations to the USDA. Those are then forwarded to the National Organic Program (NOP), a regulatory program housed under the USDA’s Agricultural Marketing Service. Eventually the USDA uses all the data collected by the various bodies tasked with research and evaluation to codify NOP regulations, which are then placed in the code of Federal Regulations.

It is important to note that there is a slight difference in interpretation of “natural” or “non-synthetic” between the FDA and NOP.

The Food and Drug Administration (FDA) defines the term natural on whether the flavoring substance is derived from a natural source (e.g., spice, fruit, etc.). The FDA definition does not consider whether it has been chemically transformed during the manufacturing process. According to the FDA, a flavor from a naturally occurring source is always “natural”, regardless of a chemical transformation process occurring further along the manufacturing process.

Meanwhile, according to the NOP definitions, the source of a non-synthetic substance has to be natural, but certain chemical transformations occurring during the manufacturing process can switch the classification of the substance from non-synthetic to synthetic.

Therefore, there are materials that may be considered “natural” (by FDA and FEMA) but “synthetic” by NOP. Essentially, for flavor chemicals (the ingredients that impart flavor), QAI accepts those that qualify as natural flavors under FDA. But, for carriers, preservatives, solvents, QAI applies the NOP Classification of Materials guidance/decision tree to determine the synthetic or non-synthetic status of the material. Only those carriers, preservatives, solvents deemed to be non-synthetic according to the NOP guidance/decision trees, are permitted in natural flavors used in organic products.

We’re here to help you work out the details, and support your efforts toward organic flavor compliance. Please contact us to learn more.