Flavourings in Organic Products
Please read if you use flavours in your organic products
The European Commission have issued an explanatory note on the use of flavourings in organic products – this is in relation to the new EC organic regulation 2018/848. We’ve linked the full document provided by Defra below and urge you to read it if you use flavours in your products.
These requirements will be in force from January 2021, when the new EC organic regulation 2018/848 is applied. However, the new restrictions on types of natural flavour permitted, and the requirement to include flavours within the percentage calculations, will mean that some companies will have to reformulate products in order to comply. We are aware that for some flavours, meeting the new requirements will be very challenging. We advise that if you use flavours in your products, you discuss with your flavour supplier whether the flavours they supply to you will meet the regulation requirements or if changes will need to be made to the flavour.
1. Non-organic natural flavours may be used, but only those which are natural flavouring substances or natural flavouring preparations labelled in accordance with Flavour Regulation (EC) No 1334/2008, Article 16(2) (flavouring preparations and/or natural flavouring substances), Article 16(3) (natural substances) and Article 16(4) (flavouring obtained exclusively, by at least 95%, from the source material referred to) may be used.
Flavourings labelled according to Article 16(4) must be obtained, by at least 95%, from the source material referred to (e.g. for an orange flavour, 95% of the flavour must come from oranges). The remaining 5% could include natural substances that are labelled according to Article 16(3) (e.g for an orange flavour, the remaining 5% does not have to come from oranges).
We’ve been made aware that for some flavours, this restriction will be very challenging in terms of being able to produce a product with an acceptable flavour profile, e.g. some fruit teas or sweet flavours.
2. Flavourings are to be included in the product calculations as agricultural ingredients. If you use non-organic flavourings, you will need to ensure the total non-organic agricultural ingredients used in your product do not exceed 5% by weight of the product. If you are unsure how to work this out, please see Soil Association standard 40.10.4 for guidance (standard 6.3.2 in the new Soil Association standards).
3. For organic flavours, the same restrictions on types of natural flavours apply, as outlined in point 1 above, and in addition:
- The flavouring components must be organic, although up to 5% non-organic flavouring may be used, provided it complies with the restrictions outlined in point 1 above.
- The carriers used must be organic, although up to 5% non-organic carriers may be used, provided they are listed in the organic regulation as permitted non-organic (Note: the list of permitted non-organic ingredients, additives and processing aids for the new regulation has not yet been published).
- Only additives or processing aids listed in the organic regulation may be used.
In terms of selling product produced before 1 January 2021, products produced to the current organic regulation before this date, may be placed on the market until stocks are exhausted.
You can find a copy of the new organic regulation 2018/848 on the EC website.
If you have any questions or concerns about this, please contact your Certification Officer.