request a technical report by a third-party expert. When review- ing the petition, the standards board must consider criteria such as the toxicity of the substance and potential health and envi- ronmental impacts.

Synthetic substances proposed for use in organic packaged foods must not have an adverse impact on the environment or reduce the nutritional quality of the food. Petitioners must also demonstrate that the substance cannot be produced from a natural source and demonstrate that the substance is not being used as a preservative or to enhance flavor, color or textures. Synthetic ingredients allowed in organic food include ingre- dients that act as leavening agents, such as ammonium carbon- ate or potassium carbonate; help thicken food, like sodium phosphate or xanthan gum; or are used to clean food equipment. Many of these synthetic substances are further limited by spe- cific manufacturing criteria or use in certain foods. Once the National Organic Standards Board has submitted recommendations, the USDA makes a final determination about whether to add the substance to the list of synthetic substances allowed as ingredients in organic packaged food. The standards board must review every substance on the National List every five years to confirm that it continues to meet all required crite- ria. During this review, the board considers any new information, including potential impacts on human health and the environ- ment, and any new natural alternatives. In contrast, none of the substances added to conventional

packaged foods –grandfathered chemicals, chemicals subject to formal FDA review, or substances deemed “safe” by the food and chemical companies – are subject to periodic reviews to reflect changes in science. And there is no requirement that the indus- try scientists conducting reviews of chemicals added to conven- tional foods be free from conflicts of interest.

Table 3

Substances Allowed in Conventional that are Not Allowed in Organic Foods Due to Environmental Concern

Mandatory pre-market reviews? Mandatory post-market reviews?

Conventional No No

Are reviews by independent experts? No Chemical preservatives prohibited? Chemical flavors prohibited? Chemical colors prohibited?

No No No

Organic Yes Yes Yes Yes Yes Yes

The Environmental Working Group’s mission is to empower people to live healthier lives in a healthier environment. With breakthrough research and education, we drive consumer choice and civic action. EWG is a non-profit, non-partisan organization dedicated to protecting human health and the environment. Visit


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