lecithin was unimaginable because of conventional lecithin’s synthetic
processing method. Thus, currently nonorganic bleached lecithin is
on the List under allowed synthetics.
However, organic lecithin has been developed and the manufacturer recently petitioned to have the nonorganic, synthetic version removed from the List. This is the first time that a petition has been
received for removal of a material based on commercial availability of
an organic version. There is also a petition to remove unbleached
lecithin from 205.606, citing the prevalence of genetically modified
soy used to make unbleached lecithin, and the fact that the GMOs are
“B“Because the EU recognizes yeast as agricultural,
and thus certifiable, organic products made with
conventional yeast will not be saleable in the EU
as organic.”
undetectable in the finished product. At the very least, an annotation
requiring non-GMO verification would seem to be in order (if unbleached lecithin is not removed). A recommendation on these petitions is not expected until the Spring 2009 NOSB meeting.
As with flavors, there are commendable companies, such as Lake
Champlain Chocolates and Dagoba, who are already using organic
versions of this product even though bleached lecithin remains on
205.605(b). If the NOSB approves the reccomendation this spring as
expected, everyone else will have to follow in their footsteps. The EU
already requires that certified organic soy lecithin be used(except in
certain milk products), so this will make export easier in the long run.
It would seem that the manufacturer should now petition to have
glycerin removed from 205.605, since
it can be made as organic. However,
the glycerin from this particular
process is only a byproduct, possibly
from production of organic soaps or
ethanol (biodiesel). Until the manufacturer finds an outlet for these primary organic products, there will not
be enough organic glycerin to qualify
it as commercially viable.
Draco Natural Products, however,
has found a way to process organic
vegetables (that’s whole vegetable
mass, not just oils) into glycerin via a
biological process, and to do so as a
primary process. Once the glycerin is
certified and commercially available
as organic, it should be feasible to petition glycerin off 205.605, and onto
205.606. Thus, the organic version
would have to be used whenever available. Given that the EU considers
glycerin certifiable, having the NOP
make this change will ease export that
much more.
Glycerin: The Road from
Synthetic to Agricultural
Most of the 42 synthetics that appear on 205.605(b) are elemental
(mined substances, or chemical recreations of such) to begin with. A
few, including lecithin and the alginates, are agricultural to begin
with, then chemically altered. This description could be applied to
glycerin, which has traditionally been made by the hydrolysis of fats or
oils. Hydrolysis is defined as the decomposition of a compound with water,
such as the dissociation of a dissolved salt or the catalytic conversion of starch
to glucose. Hydrolysis as a process always creates a new molecule, so anything that is subjected to hydrolysis would be a synthetic. For this reason glycerin, which is very useful as a carrier and completely harmless
as a food ingredient, finds itself on 205.605(b), with only the annotation “produced by hydrolysis of fats and oils.”
So, when Oregon Tilth certified one of its clients for glycerin production, there was a bit of an outcry, something to the effect that “you
can’t make an organic synthetic.” What the outraged parties did not
realize was that the manufacturer had devised a way to make glycerin
by a biological—and therefore, allowed—process, starting with certified organic vegetable oil.
Yeast: A Huge Potential Problem
with Export
Yeast may also cause complications
for those who wish to export. The
new EU regulations view yeast as agricultural, and thus certifiable. But the
NOP has yet to see it the way our
friends overseas do. In the United
States, yeast still remains on the
205.605(a) list of nonagricultural materials. Because of this, processors are
allowed to use nonorganic autolyzed,
baker’s, brewer’s, nutritional and
smoked (nonsynthetic smoke only)
yeasts in certified organic foods even
though organic certified versions are
available.
Due to this fact, many processors
may soon have a rude awakening
when they go to export their product.
Because the EU recognizes yeast as
agricultural and certifiable, organic
products made with conventional
yeast will not be saleable in the EU as
