Nonorganic Ingredients in "Made with Organic"

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Nonorganic Ingredients in "Made with Organic"

Started by dimreh, Today, 07:56 AM

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dimreh

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Today, 07:56 AM

A product will have the claim "made with organic [ingredient x"], and ingredient x is >70% of the product.

There are some spices included in this product, which make up <5%. I understand these spices don't need to be certified organic, can they be treated with ethylene oxide (eto) or propylene oxide (ppo)?

From what I understand, USDA NOP says that synthetic substances aren't allowed in these nonorganic ingredients. Since eto and ppo are synthetic, and not on the National List of allowed substances, these spices cannot be used in this product. It makes sense in my head, but is it accurate?

Thanks for your help.

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SHQuality IFSQN Senior · Answer 1 · 2026-02-10T17:15:52+00:00

The US legislation is a maze! I hope my line of reasoning still makes sense. CFR 205.301 regarding product composition says "© Products sold, labeled, or represented as “made with organic (specified ingredients or food group(s)).” Multiingredient agricultural product sold, labeled, or represented as “made with organic (specified ingredients or food group(s))” must contain (by weight or fluid volume, excluding water and salt) at least 70 percent organically produced ingredients which are produced and handled pursuant to requirements in subpart C of this part. No ingredients may be produced using prohibited practices specified in paragraphs (f)(1), (2), and (3) of § 205.301. Nonorganic ingredients may be produced without regard to paragraphs (f)(4), (5), (6), and (7) of § 205.301. If labeled as containing organically produced ingredients or food groups, such product must be labeled pursuant to § 205.304."

Section f point 1 states "(f) All products labeled as “100 percent organic” or “organic” and all ingredients identified as “organic” in the ingredient statement of any product must not: (1) Be produced using excluded methods, pursuant to § 205.105(e);"

Eventually I ended up at CFR 205.105, which specifically states:

"§ 205.105 Allowed and prohibited substances, methods, and ingredients in organic production and handling.

To be sold or labeled as “100 percent organic,” “organic,” or “made with organic (specified ingredients or food group(s)),” the product must be produced and handled without the use of:

(a) Synthetic substances and ingredients, except as provided in § 205.601 or § 205.603;

(b) Nonsynthetic substances prohibited in § 205.602 or § 205.604;

(d) Nonorganic agricultural substances used in or on processed products, except as otherwise provided in § 205.606;

(e) Excluded methods, except for vaccines: Provided, That, the vaccines are approved in accordance with § 205.600(a);

(f) Ionizing radiation, as described in Food and Drug Administration regulation, 21 CFR 179.26; and

(g) Sewage sludge."

Since ethylene oxide is not on the list of allowed substances in CFR 205.601, your understanding is correct. It can not be part of the > 70% organic ingredient (or any other organic or partially organic product intended for market in the USA).

I'm not sure why you would want to produce a partially "organic" product. It causes a whole lot of extra work on your part without any benefit. Why not go all in and sell a fully organic product.

Here are the limits for non-organic products:

CFR 180.151 lists tolerances for ethylene oxide residues and 2-chloroethanol (an ethylene oxide reaction product)

ethylene oxide residues in herbs and spices, group 19, dried, except basil should not exceed 7 ppm.

2-chloroethanol residues in herbs and spices, group 19, dried, except basil should not exceed 940 ppm.

Nonorganic Ingredients in "Made with Organic"

dimreh

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