Report from Josyline C. Javellosa
Agriculture Attache, Washington D.C.
The United States Department of Agriculture (USDA) has officially announced today the renewal of carrageenan as among the “allowed substances” in its National List of Allowed and Prohibited Substances (National List) regulated by the USDA National Organic Program.
The substances in the National List are used in organic crop and livestock production and organic handling/processing.
US’ Organic standards allow most natural substances in organic farming while prohibiting most synthetic substances. The National List of Allowed and Prohibited Substances—part of the USDA organic regulations—lists the exceptions to this basic rule, as well as the non-organic substances allowed in processed organic products.
Specifically, carrageenan is listed as a nonagricultural (non-organic) substance allowed as ingredient of processed products labeled as “organic” or made with organic specified ingredients or food groups. Other non-synthetics in this category that have been allowed/renewed are agar-agar, animal enzymes, calcium sulfate, glucono delta-lactone and tartaric acid.
USDA’s Agricultural Marketing Service (AMS) has reviewed the National Organic Standards Board’s (NOSB’s) sunset review document and decided to renew all 17 substances, including carrageenan, despite the recommendation of the NOSB not to renew carrageenan.
For reference, attached is the USDA notification published in the Federal Register on April 4, 2018 with regard to this decision. We may note that:
– AMS found sufficient evidence in public comments to the NOSB that carrageenan continues to be necessary for handling agricultural products because of the unavailability of wholly natural substitutes.
– Carrageenan has specific uses in an array of agricultural products, and public comments reported that potential substitutes do not adequately replicate the functions of carrageenan across the broad scope of use. Therefore, carrageenan continues to meet the OFPA (Organic Foods Production Act) criteria for inclusion on the National List.
– The renewal of these 17 substances will avoid potential disruptions to the organic industry and the public that may otherwise result from their removal from the National List.
This USDA announcement concludes the 2018 Sunset Review. The new sunset date for these substances in the National List is May 29, 2023.
The National Organic Standards Board (NOSB) must review every substance on the National List of Allowed and Prohibited Substances every five years to confirm that it continues to meet all required criteria. This review is called “sunset review.”
During this 5-year review, the NOSB reviews the substance, public comments, and any new information concerning the substance. This could include reviewing any new information about the substance’s impact to human health or the environment, any new proven, natural alternatives, or other criteria under the Organic Foods Production Act.
Comments:
Over the past 5 years, the value of Philippine carrageenan exports to the US catering to both the organic and non-organic markets was as follows:
2013 – $36.8 million
2014- $43.2 million
2015 – $44.2 million
2016 – $32.7 million
2017 – $28.1 million
Source: USDA-Global Agricultural Trade System (GATS)
The Philippines is the top exporter of carrageenan to the United States.
The contribution of all concerned to the advocacy effort towards renewal of carrageenan in the National List of Allowed Ingredients in Organic Products, especially the development of the paper contracted out by the Bureau of Fisheries and Aquatic Resources (BFAR) that formed part of the public comments during the 2018 sunset review, is duly recognized.
The paper, which the Philippine Agriculture Secretary endorsed to USDA Secretary Sonny Perdue through this post, put together science-based information providing evidence that no alternative could replicate the distinct physico-chemical and functional properties of carrageenan in its current product applications — addressing the issue raised by the NOSB on availability of substitutes as the basis of its recommendation to remove carrageenan from the National List of Allowed Ingredients in Organic Products.
Representations with USDA in Washington, D.C. were part of collaborative advocacy efforts with US private sector (e.g. FMC Corporation, Dupont, Cargill), the Seaweed Industry Association of the Philippines, ASEAN Ministers of Agriculture and Forestry and also supported by discussions at the PH-US Trade and Investment Framework Agreement meetings jointly chaired by PH-DTI and USTR.
Based on the current sunset review process, it is likely that the next USDA call for public comments to review the status of carrageenan in the National List will be in three years i.e., year 2021.
(First photo was taken by @Anicia Hurtado in Sitangkai while the other attached photos showing Filipino seaweed farmers were downloaded from public websites.)
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