“Natural flavors” in organic

To whom it may concern:

We want you to know how pleased we are to see OTA’s proposed petition to revise or remove two items from the National List. To be clear, PCC supports OTA’s proposal to revise the current listing of natural flavors to require organic flavors when commercially available in the necessary quality, quantity or form. We approve of the revised language as proposed: “Flavors: Non-synthetic flavors may be used when organic flavors are not commercially available. All flavors must be derived from organic or non-synthetic sources only, and must not be produced using synthetic solvents and carrier systems or any artificial preservative.”

We also support the plan to petition for removal of lignin sulfonate from the National List as a post-harvest floating agent. We understand lignin sulfonate also has been allowed as a chelating agent and dust suppressant [7 CFR 205.601(j)(4)] and is seen as an ingredient in “prilled” fertilizing materials, such as gypsum and lime. We understand OTA’s petition would prohibit only use as a post-harvest floating agent and that use as a chelating agent or dust suppressant would remain compliant in organic production.

We understand also that as the pear industry modernizes equipment, floating agents are becoming obsolete and new “float-less” packing lines are being installed, and that any equipment requiring a floating agent can use another floating agent, sodium silicate, already approved for organic production. We agree with your argument that while floating agents are still used by some organic pear packers, the use of lignin sulfonate is no longer essential to organic production. We support OTA’s proposal to petition for removal of lignin sulfonate from 205.601(l)(1) as a floating agent in post-harvest handling.


Trudy Bialic
Director, Public Affairs
PCC Natural Markets

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