Update on organic legislation: the use of flavours in organic food is newly regulated and stricter than before

How the combination of the European flavour regulation and the organic regulation succeeds in practice

Apr 2021. In February 2021, the German Research Institute for Organic Agriculture, FIBL Deutschland e.V., published a new guideline that defines the use of conventional flavourings in organic food (in German). The guide contains information on the changing legal situation resulting from the new EU Organic Regulation (Regulation (EU) No. 2018/848) from 1 January 2022. Read here what the key contents of the guide are and what producers should pay attention to when using flavours in organic food

How is the guide to the use of conventional flavours in organic foods structured and what information is included?

The project "Development of a concept for the evaluation of flavors for use in organic food" (in German: „Entwicklung eines Konzeptes zur Evaluierung von Aromen für den Einsatz in Bio-Lebensmitteln“) was funded by various national and international research institutes and public institutions. The results were presented for the first time at this year's BIOFACH, the world's leading trade fair for organic food.

The main contents at a glance:

information on legal requirements: Organic Regulation (EU) No. 2018/848 in conjunction with Flavour Regulation (EC) No. 1334/2008
specifications on the composition of conventional flavours
regulations on the labelling of flavours
calculation and quantity restriction of flavours in organic foods
exclusion of genetically modified organisms (GMOs), nanomaterials and irradiation
challenges in the production of conventional flavours in organic foods

What does this mean in everyday practice?

The four most important hints summarised for you:

According to the new organic law, only the following may be used in organic food:
- natural flavours, in the flavouring part, obtained at least 95% by weight from the named source material (food, food category, of plant or animal origin
  and/or
- flavour extracts from food

Flavourings count as ingredients of agricultural origin with the entry into force of the new organic regulation (chapter 6.1)
Conventional flavours, as ingredients of agricultural origin, can only be used in organic food up to a proportion of 5% by weight (chapter 6.2)
Conventional flavours may be used if:
- the flavours, their components and their production are free from genetically modified organisms (GMOs) (chapter 7.1)
- they do not contain nanomaterials (chapter 7.2)
- they have not been treated by ionising irradiation

Useful assistance for the implementation of the flavouring and organic regulations

In the appendix of the guide (see chapter 10.2) you will find a checklist that can be used as an aid in checking the plausibility and conformity of your supplier documents. We make it available to you here as a detached working document in English. In this way, you can ensure that all the necessary criteria are met in order to market your products in accordance with the new organic legislation.

We are happy to support you in further questions regarding GMO analysis, (international) declaration/labelling of food products as well as contaminant and residue analysis. Feel free to contact us!