Organic Handling Requirements & Approved Processing Aids

Under 7 CFR § 205.270, certified organic handling operations must:

1. Use only approved substances:

• All processing aids must be on the National List of allowed substances (§ 205.605)

• All non-organic agricultural ingredients must either be certified organic or appear on the allowed non-organic ingredients list (§ 205.606) and not be commercially available in organic form

• No synthetic substances may be used unless specifically listed as allowed

2. Prevent prohibited substance contact:

• No prohibited substance may contact organic products during processing, packaging, transportation, or storage

• Equipment, facilities, and packaging materials must be free of prohibited substance contamination

3. Prevent commingling:

• Organic products must not be mixed with non-organic products at any stage of handling

• Physical separation, scheduling controls, and sanitation protocols are required to prevent commingling

4. Maintain records:

• Complete audit trail from incoming organic ingredient receipt through finished product shipment

• Records must be maintained for 5 years and be available for inspection

5. Comply with labelling rules:

• All organic label claims must comply with NOP labelling standards (see Organic Labelling page)

These requirements apply to every operation in the handling chain — processors, co-packers, storage facilities, and (under SOE) certain distributors and brokers.

A processing aid is any substance used during the processing of an organic product that either: (1) is added to a food but is removed from the finished product in any form, (2) is converted into a constituent normally present in the food and does not significantly increase the amount of that constituent, or (3) is added to a food for a technical or functional effect during processing but is present at an insignificant level and has no technical or functional effect in the finished product.

Under NOP regulations (§ 205.605), only processing aids that appear on the National List are permitted in certified organic handling operations. The National List distinguishes between:

• Nonsynthetic (natural) substances: Generally allowed unless specifically prohibited

• Synthetic substances: Allowed only if specifically listed with any applicable conditions

Examples of commonly used allowed processing aids:

• Acids: Citric acid (allowed), phosphoric acid (allowed for specific equipment cleaning uses)

• Gases: Carbon dioxide, nitrogen (for modified atmosphere packaging)

• Leavening agents: Baking soda (sodium bicarbonate)

• pH adjusters: Potassium hydroxide (soap making), calcium hydroxide

• Sanitizers: Chlorine materials (with strict residue-level restrictions), hydrogen peroxide, ozone

• Yeast: Non-organic commercial yeast is allowed when organic yeast is not commercially available

For any processing aid not clearly on the National List, contact your certifier for an input review before use — the same process used for farm inputs.

Products labelled 'USDA Organic' must contain at least 95% organic ingredients (by weight or fluid volume, excluding water and salt). The remaining up to 5% of ingredients may be non-organic, but only under strict conditions:

The non-organic ingredients must:

1. Appear on the National List (§ 205.606) as non-organically produced agricultural products allowed in organic handling

2. Not be commercially available in certified organic form — the handler must document their search for an organic equivalent

3. Not be produced using excluded methods (GMOs), ionising radiation, or sewage sludge

National List § 205.606 lists specific non-organic agricultural ingredients that are conditionally allowed — including certain spices, hops, casings, and celery powder. The list is updated periodically by USDA based on NOSB recommendations.

Key rule: If a certified organic version of an ingredient is commercially available, you must use the organic version — even if it costs more or is less convenient. Commercial unavailability must be documented in your OSP and renewed annually.

For products labelled 'Made With Organic [Ingredients]' (the 70% tier), non-organic ingredients can be used more broadly but must still comply with the prohibition on GMOs, ionizing radiation, and sewage sludge.

The process for getting a new processing aid approved for use in your organic handling operation mirrors the input approval process on the farm side:

Step 1 — Check the National List first:

Review 7 CFR § 205.605 (the National List for handling processing aids) to determine whether the substance is: (a) explicitly listed as allowed, (b) not listed (and therefore subject to the synthetic/nonsynthetic determination), or (c) explicitly prohibited.

Step 2 — Gather documentation:

• Full product name and manufacturer

• Product ingredient list / specification sheet

• Safety Data Sheet (SDS)

• Intended use: what function does this processing aid perform, at what stage of processing, and at what level?

Step 3 — Contact your certifier before use:

Submit your documentation to your certifier with a written request for input review. Ask explicitly: 'Is this processing aid approved for use in our certified organic handling operation?'

Step 4 — Receive written approval:

Get your certifier's determination in writing and retain it in your OSP records. Update your OSP to include the approved processing aid.

Step 5 — Never use before approval:

Using an unapproved processing aid — even one that seems clearly natural or food-grade — can result in a Notice of Noncompliance and potential loss of certification for affected products.

The ACA's ACAdemy training resources include guidance on processing aid compliance that is useful for both handler compliance teams and certifier staff.