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  • From: "Miranda Smith" <mirandaconstance@gmail.com>
  • To: gardenwriters-on-gardening <gwl-g@lists.ibiblio.org>
  • Subject: Re: [gwl-g] Hmmm, this is helpful re organic and the usda
  • Date: Sun, 1 Jul 2007 18:59:26 -0400

Yes--that is reassuring. Sorry that I misinformed people about the weakening of standards--that was my understanding and I'm happy to be corrected.

Miranda

On 7/1/07, Jeff Lowenfels <jeff@gardener.com> wrote:
Well, this surely makes me fell better. I am assuming this is a legit
open letter. Will do some research.... Go to the bottom and see that
the USDA has three catagories...100% Organic.....Organic .....Made
from Organic....

Cheers,

Jeff



To: An Open Letter to the Organic Food Community
From: Accredited Certifiers Association, Inc.

Dear Friends,

The Accredited Certifiers Association (ACA) is pleased to
see that the USDA has published an interim final rule regarding
additions to the National List (for nonorganic agricultural
ingredients), and also extended the comment period for another
60 days. This will provide an opportunity for further review
by the public and consideration of additional information by
USDA.

We have become concerned that recent media coverage about
the changes to the USDA organic regulations is missing
the point that these changes are a tightening of the
regulations. Although it would appear that the listing
of 38 non-organic, agricultural "minor" ingredients to
the National List is an expansion of what is allowed,
it actually reduces the number of such ingredients that
may be allowed. Section 205.606 of the National List
provides a list of non-organic ingredients that may
comprise up to 5% of the content of a product. These
ingredients are permitted only when the organic equivalent
is unavailable commercially.

Prior to the new interim rules publication, organic processors
could use ANY nonorganic agricultural ingredient they needed,
at less than 5% of an organic product, provided they could
document that it was not commercially available in organic
form. These new rules actually greatly restrict the possible
use of non-organic ingredients in processed organic food.
While 38 new items on the list may sound like a lot, it is
a very short list compared to the thousands of possible
ingredients that are now prohibited.

The new limitations on non-organic ingredients occurred as
a result of a court order issued in January 2005. Since this
time, certifiers, organic farmers, organic food processors,
and other organic community members have worked hard to meet
the strong consumer demand for organic products. Perhaps the
most formidable challenge facing the organic community
involves increasing the supply of organic agricultural
commodities. Does listing of an ingredient under 205.606
give organic food manufacturers a green light to use
nonorganic ingredients? – absolutely not! As certifying
agents accountable to the public, we require manufacturers
to document their efforts to source organic ingredients when
using the non-organic forms that are approved, and
monitor their progress in obtaining organic sources as they
become available. The ACA is currently working on a project
to standardize the criteria for determining commercial non-
availability, to assure that the commercial-availability
requirement is strictly upheld, and to develop a system
of notification that provides incentive for development
of organic sources.

We are concerned that only having part of the story of the
proposed changes to the National List may create doubt about
the integrity of the organic label and, in turn, reduce
the demand for organic products, and ultimately damage the
livelihood of all organic producers, surely not a outcome
that benefits organic consumers or the environment. Clearly
all of us in the organic community are vitally interested
in preserving the prestige of organic labeling, which is
why we stress the need to share full and accurate information
when discussing organic standards. This latest change in the
regulations should not be cast as a basic "weakening" of
the standards, but rather explained as what it is, a new
limitation that actually strengthens the standards for
processed organic food.

Although segments of the organic community involved in the
production and certification of organic products have been
working on the changes to 205.606 since January of 2005,
it is clear from the recent comments that many consumers
were not aware of the impending changes. The ACA is
pleased that the USDA is expected to address concerns over
the proposed regulatory changes prior to their final
implementation. To date, those concerns have come from
a diverse group of interests in the form of comments to
the USDA, numbering over 1225 even in the short 7 day
comment period for the proposed changes. It is inspiring
and encouraging to see such attentiveness, concern, and
care expressed for the organic standards that we daily
work to protect and properly interpret. It is good that
the USDA has allowed another 60 day comment period from
the date the interim final rule change was published on
June 27, 2007.

Each of us has an important role to play in upholding the
credibility of the organic standard. An informed public
is one that can participate fully in the inevitable debates
that arise. These are a healthy and integral part of the
acceptance and continuing success of organically certified
food.

We believe that it is important to review the organic
labeling requirements as established by the USDA. These
regulations permit organic food products to be sold and
labeled in three distinct categories:

* As "100% Organic" – which means just that, all
ingredients in the product must be certified organic.

* As "Organic" – which means that at least 95% of the
ingredients must be certified organic. The remaining
ingredients must be included on the National List (part
of the USDA regulations) either as a food additive or
as a non-organic food ingredient. All non-organic
ingredients must be produced without the use of genetic
engineering, sewage sludge or irradiation.

* As "Made with Organic Ingredients" – which means that
at least 70% of the ingredients must be certified organic,
only additives that appear on the National List may be
used, but may contain other non-organic food ingredients.
All non-organic ingredients must be produced without
the use of genetic engineering, sewage sludge or
irradiation.

Only products that are "100% Organic" or "Organic" may carry
the USDA green and white organic seal. All organic ingredients
must be identified in the ingredients list for each product.
Consumers concerned about use of non-organic ingredients have
the option to search for, and reward producers with their
purchase of 100% Organic products.

The Accredited Certifiers Association (ACA) is a non-profit
organization founded in 2004 that is dedicated to ensuring
the integrity of organic products. The ACA counts 31 USDA
accredited certification agencies as members. The ACA plays
a key role in fostering communication among certifiers, which
is a crucial element in the ongoing effort to maintain our
high standards – as ell as the public's respect for the
certifications we provide.

We have a keen interest in ensuring the accurate, complete,
and responsible exchange of viewpoints, among ourselves and
with the community at large. As accredited certification
agents, our primary responsibility is to protect and ensure
the legitimacy of the organic label. Our professional standing,
which rests on USDA accreditation, incurs immense privilege and
responsibility; and we take our role extremely seriously.
Chief among our obligations is maintaining the public trust
and, in the course of fulfilling our commitments, we strive
to consider the public's interests, rights, and wishes.

Patricia Kane, Coordinator
Accredited Certifiers Association, Inc.
Port Crane, NY 13833
http://www.accreditedcertifiers.org

USDA-accredited certifying agents working together to ensure
the integrity of organic certification in the United States.
A nonprofit tax exempt educational organization.


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