1 reply to this topic

[FSNewbie25]

Hi,

What are the requirements for if an ingredient reaches its best by and is added to the recipe the day of the best by date however the recipe will not be approved for manufacture until a later date? Is this product still sellable in the eyes of USDA Organic?

 

Can someone link the NOP Guidelines for Alcoholic Beverage Manufacturing as well? 

[Brothbro]

Hi FSNewbie25 and welcome to the forum.

 

Organic Alcoholic beverages follow the normal organic beverage manufacturing rules outlined by the USDA NOP. The additional rules for alcohol come from those outlined by the TTB. Below are some links from USDA and TTB.

 

https://www.ams.usda...organic-alcohol

https://www.ttb.gov/...-organic-claims

 

The NOP does not list specific guidance for beverages in the CFR, instead there are general requirements that would apply to all organic handlers. (See specifically 205.270-272, these list requirements for processing facilities).

https://www.ecfr.gov...t-205/subpart-C

 

For beverages, I would think a tricky point would be what classifies as an "ingredient" in your recipe. Water and Salt are not considered ingredients, but nitrogen and CO2 are, these gasses can alter what degree of "organic" you can claim on your finished label. The best source of information on organic rules as they apply to your process will likely come from your organic certifier.

 

To answer your "best by date" question, I would think you should follow your company's own procedures with regards to shelf-life extensions for ingredients. If you deviate from the procedures that you have established and submitted to your organic certifier, they would take issue with that. To my knowledge the NOP does not have specific provisions related to expiration dates, I think they defer to the regulations listed in the FDA codes for all food processors. 

Edited by Brothbro, 20 April 2023 - 06:38 PM.