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IMPORTANT: Synthetic Ingredients in Organic Food?

One of the reasons that most of us buy organic food is because we are told that they are free from synthetic ingredients.

There is a dangerous loophole, however, in USDA organic regulations which allows companies to use synthetic ingredients in organic food products, and it must be closed immediately.

But we need your help to do this.

The loophole says that “Nutrients allowed [on the National List of Approved Substances] are not limited to the nutrients listed in section 104.20(d)(3), because section 104.20(f) provides that nutrients may be added to foods as permitted or required by applicable regulations elsewhere by FDA.”

In plain English, it means the following.

There is a list of allowed synthetic ingredients in organic foods because they are deemed essential for organic production, are unavailable from natural/organic sources, etc.

For the most part, they are “essential nutrients” for which the FDA has determined a Recommended Daily Intake (RDI): Vitamin A, Vitamin C, Calcium, Iron, Vitamin D, Vitamin E, Vitamin K, Thiamin, Riboflavin, Niacin, Vitamin B6, Folate, Vitamin B12, Biotin, Pantothenic acid, Phosphorus, Iodine, Magnesium, Zinc, Selenium, Copper, Manganese, Chromium, Molybdenum and Chloride.

Yet, the organic regulations are written in a way that says as long as a specific nutrient is allowed by the FDA, it can be used in organic foods. So, all an ingredient needs to do is to get approval from the FDA for it to go into an organic product.

This is simply ridiculous and completely precludes the need to meet any type of organic standard.

Of course, major food companies have exploited this and have added nutrients such as synthetic forms of DHA and ARA into organic products. (Here is a list of organic food products that use this very questionable ingredient – I would NEVER buy these organic products for my family.)

What is even more shocking is that USDA Deputy Secretary of Agriculture Kathleen Merrigan apologized for this loophole, but her administration is unwilling to close it or cease allowing synthetic ingredients into organic foods.

Fortunately, The Cornucopia Institute, one of the most important non-profit organizations in the organic food world and a staunch defender of organic standards, has been fighting tooth and nail with the USDA and its National Organic Standards Board (NOSB) over this loophole.

In the past six months alone, organic stakeholders won a string of victories at the NOSB meetings, which upheld organic integrity and rejected corporate petitions for eight synthetic nutrients.

Even though we got these wins at the NOSB meetings, it shouldn’t be the case that we have to struggle to keep synthetic ingredients out of organic food. It should be the rule, not the exception.

Furthermore, even though the NOSB rejected these eight synthetic ingredients, they are found in organic products on store shelves right now, including organic baby food and infant formula.

Unapproved ingredients MUST be removed from organic products right away.

Yet, the USDA has declined to take any action on this so far.

For the full story and complete background on this issue, please HERE to read Cornucopia’s excellent and comprehensive position paper.


It is essential that we get your help and tell the USDA that:

– All loopholes and incorrect interpretations of the organic standards must end now.

– The agency must take immediate enforcement against any and all synthetic nutrients that are not on the National List of Approved Substances and that have been rejected by the NOSB.

– Synthetic ingredients must be individually reviewed by the NOSB and and if approved, then listed on the National List of Approved Substances before they may be added to organic foods.

Please take action, let your voice be heard, and leave a comment on the USDA’s website HERE.



Below is a Sample Letter, as provided by The Cornucopia Institute, which could be used as a framework for your comment.

Sample Letter

(Please personalize to increase its impact)

To the USDA:

Synthetic nutrients have no place in organic foods. As an organic stakeholder, I expect nutrients in my food to be either naturally occurring or from organic sources.

This expectation is backed by federal law, which requires that synthetic ingredients may be added to organic foods only if they are essential to making organic products, and only after each one has been carefully reviewed and approved by the National Organic Standards Board.

The National Organic Standards Board (the expert panel set up by Congress) has rightfully upheld organic integrity and followed the law by recently rejecting numerous petitions for synthetic nutrients in organic foods. Rather than remove their synthetics from organic foods, corporations have instead turned to the USDA, asking that the agency keep open a loophole and delay any enforcement action.

Please end these violations now. As an organic stakeholder, I ask that you take immediate enforcement action against any food manufacturer adding a synthetic nutrient that is not considered essential by the Food and Drug Administration and/or has been explicitly rejected, after review, by the National Organic Standards Board.

I also ask that you close the loophole in the organic standards—the reference to FDA regulations (21 CFR 104.20) that allow any synthetic nutrient—and start the process of reviewing and listing each individual synthetic nutrient, as required by federal law.


[Your Name]


I’ve sent my comment in. Will you?

Also, please share this post with your network — it is essential that as many of us as possible tell the USDA that organic standards must be protected.

Thank you for concern.

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