Manufacturers Must Use Organic Ingredients When They Are Available

Urge the NOSB to Remove Soy Lecithin from the National List

Public Comments due Monday, April 20th
UPDATE:

Last fall, we urged members of the organic community to write to the National Organic Standards Board (NOSB) in support of the first
petition in the history of the USDA’s Organic Program to remove a substance from the National List of Approved and Prohibited
Substances (conventional soy lecithin).
Our action alert, thanks to you, was a success. The NOSB Handling Committee received more
comments on this topic—in favor of this petition—than all other comments combined. And they heard you!

The Committee, which reviewed the petition this past winter, unanimously recommended that the removal of conventional lecithin be
approved at the vote of the full NOSB, at their meeting next month.
We must show the NOSB that organic stakeholders are still
engaged—tell them we expect them to cast their final vote in the interest of organic consumers and innovative organic
companies.

Our action alert below outlines why this precedent-setting vote is so important for the future of organics. If you submitted a comment last fall,
thank you, and we hope that you will take the time again to reiterate your support of this petition. If you did not comment last fall, please take
a moment now to submit your comment (instructions and sample message below): “I expect the highest percentage possible of organic
ingredients in my organic foods, which is why I support the petition to remove soy lecithin from the National List.”

Since this petition is opposed by a number of large corporations that would like to continue using solvent-extracted, conventional soy
lecithin in organic foods (which is cheaper than the organic version), it is crucial that the NOSB hear our voices again as it prepares to cast
its final vote on this important issue.


Taking Action is Easy:

Submit your comment to the National Organic Standards Board members.

Comments may be submitted via the internet at www.regulations.gov until April 20, 2009. The process is less complicated than it seems at
first; simply follow the steps below.

1. To submit a comment, go to
www.regulations.gov. In the middle of the screen, you will see "Search Documents." Type in "AMS-TM-09-
0014" and click "Go."

2. Next, you will see "Narrow Search" on the left side of the screen. Click on "Notices" under "Document Type."

3. You may now click on "Send a Comment or Submission" underneath the search result.

Sample message—(cut, edit and paste):

    Dear NOSB Members,

    As a consumer/farmer/processor/retailer (choose one or more), I want the highest percentage possible of organic ingredients in my
    organic foods.

    When a substance becomes available in organic form, I support a change in the standards which requires manufacturers to use only
    the organic version. This is consistent with both the spirit and letter of the laws governing organic food production.

    Specifically, I understand that organic soy lecithin has become available, which is why I urge the Board to recommend to the USDA
    that they remove non-organic soy lecithin from the National List (7 CFR 205.605 and 7 CFR 205.606) of approved non-organic
    materials.

    As an organic stakeholder, I wish to avoid conventionally grown and hexane-extracted ingredients whenever possible. Since organic
    soy lecithin is never hexane-extracted and sourced from organically grown soybeans, I strongly urge the Board to vote for removing
    conventional soy lecithin from the National List.

    Second, companies that invest time and money in the development of an organic version of commonly used food ingredients should
    be rewarded for their efforts in the marketplace. If the rules do not change with the times and continue to allow food manufacturers to
    purchase the non-organic version, why should anyone ever make the investments in the research and development of organic food
    ingredients in the future?

    Voting to remove lecithin from the National List will ensure that processed organic foods contain organic soy lecithin. Just as
    importantly, it will send a strong message to organic companies that their efforts at developing organic versions of common food
    ingredients will not be in vain.

The Cornucopia Institute      P.O. Box 126, Cornucopia, WI 54827      608-625-2042      www.cornucopia.org

Background:

Take a look at the bar of organic chocolate in your desk drawer or the carton of organic ice cream in your freezer, and you'll likely see a little-known but
very common food ingredient: lecithin.

Lecithin is an important minor ingredient in many processed foods. It is used as an emulsifier to prevent separation of oil and water, and is especially
common in chocolate to improve its texture and increase its shelf life.

Unless the ingredients list specifically states "organic soy lecithin," the lecithin was processed from hexane-extracted soybeans, which were grown
conventionally and likely sprayed with pesticides in the fields—in organic food??? Hexane is a neurotoxic chemical byproduct of gasoline refinement.

Currently, food manufacturers can legally add conventional soy lecithin to organic foods because, in the past, an organic version was not available.

To be labeled "ORGANIC," and to carry the USDA organic seal, food has to be made up of at least 95% organic ingredients. The only non-organic
ingredients are ones that are unavailable organically and cannot make up more than 5% of the product.

When the organic standards were developed in 1995, organic soy lecithin was not commercially available. But times have changed.

Over the years, one pioneering organic company has not only developed a truly organic soy lecithin, but has invested in the manufacturing capability
to supply the organic version to every food manufacturer that needs it. Organic soy lecithin is not extracted with the use of hexane, a toxic and polluting
solvent prohibited in organic production. And the organic version comes from organically grown, non-GMO soybeans (genetically engineered
ingredients are also banned in organics).

Now that organic lecithin is commercially available, the National Organic Standards Board (NOSB), the expert citizen panel that Congress set up to
decide these issues, needs to determine whether to recommend removing lecithin from this list of conventional substances that are allowed in organic
foods. This is the first time in organic regulatory history that an ingredient has been petitioned to be removed from the National List.

The Cornucopia Institute urges members of the organic community to tell the NOSB members that you support the removal of lecithin from 205.605 and
205.606. If lecithin remains on the list, food manufacturers have no incentive to opt for the truly organic lecithin, and many will continue to put hexane-
extracted, conventional lecithin in your organic foods—it's cheaper.

There is more at stake than simply the type of lecithin you can expect to find in your organic foods in the future. If the regulations do not change when
companies innovate and develop new organic ingredients, why should anyone bother investing in the expensive research and development that gives
rise to the availability of new organic ingredients?

We need to send a strong message to the NOSB members and the USDA that we stakeholders in the organic industry expect the regulations to evolve
with the times. And change should be in the interest of organic consumers and innovative organic companies.

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Manufacturers Must Use Organic Ingredients
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