Which Nonagricultural Ingredients Are Allowed in Organic Processed Products?

1What § 205.605 actually says

The chapeau:

The list then splits into two sublists: (a) Nonsynthetics allowed — naturally sourced nonagricultural substances (citric and lactic acids, agar-agar, bentonite, calcium carbonate, diatomaceous earth, food-grade microorganisms, sodium bicarbonate, yeast, and more) — and (b) Synthetics allowed (ascorbic acid, calcium hydroxide, carbon dioxide, hydrogen peroxide, ozone, xanthan gum, and more). This section pairs with §205.606, which covers agricultural ingredients you can't source organically — together they're the handling half of the National List, referenced by §205.105(c) and (d).

2The annotations are binding — examples from the list

Same rule as the crop lists: the em-dash text is the legal boundary of the allowance. Quoted examples:

• Acids (nonsynthetic): "Acids (Citric—produced by microbial fermentation of carbohydrate substances; and Lactic)." — citric acid is allowed by its production method, not generically.
• Flavors: "Flavors—nonsynthetic flavors may be used when organic flavors are not commercially available. All flavors must be derived from organic or nonsynthetic sources only and must not be produced using synthetic solvents and carrier systems or any artificial preservative." — a commercial-availability test inside an annotation.
• Yeast: "Yeast—When used as food or a fermentation agent in products labeled as “organic,” yeast must be organic if its end use is for human consumption; nonorganic yeast may be used when organic yeast is not commercially available. Growth on petrochemical substrate and sulfite waste liquor is prohibited. For smoked yeast, nonsynthetic smoke flavoring process must be documented."
• Cellulose (synthetic): "Cellulose (CAS #9004-34-6)—for use in regenerative casings, powdered cellulose as an anti-caking agent (non-chlorine bleached) and filtering aid. Microcrystalline cellulose is prohibited." — the same substance name can be allowed in one form and prohibited in another.
• Label-category splits: some entries are allowed only in "made with organic" products and prohibited in "organic"-labeled ones — e.g. "Magnesium stearate—for use only in agricultural products labeled “made with organic (specified ingredients or food group(s)),” prohibited in agricultural products labeled “organic”."

3This list works with the labeling categories

§205.605 doesn't stand alone: what a product may contain also depends on which labeling category it claims. A product labeled "organic" still needs at least 95 percent organic ingredients; §205.605 substances live in the remaining slice, and some entries (like magnesium stearate above) are only allowed at the "made with organic" tier. Handlers also need §205.605's sanitizer entries (chlorine materials, peracetic acid) for food-contact surfaces — with their own use limits.

4The list changes — check the current text

Handling substances are among the most actively petitioned and sunset-reviewed entries on the National List. Formulators get caught when an ingredient that was listed at product-design time is later removed or re-annotated. Verify against the current official text1 — the review date on this page is your staleness check.

5How to document this in your operation

For a handling operation, every nonagricultural ingredient and processing aid in a certified product needs to trace to a §205.605 entry, within its annotation, in your OSP's ingredient and supplier records — including commercial-availability searches where an annotation demands one (flavors, yeast). OrganicAssistant keeps your ingredient list connected to the current National List data, so an entry that changes under you surfaces as a flag instead of an inspection finding.

6The bottom line

§205.605 is the gate for everything nonagricultural in an organic processed product: two sublists, annotation-bound, label-category-aware, and revised through ongoing rulemaking. Check the entry, honor the annotation, match the label tier — and confirm the final formulation with your certifier.

This explainer summarizes federal regulation in plain language; it is not legal advice or a compliance determination. Your certifier makes the final call on your operation. Reviewed against the eCFR text of 7 CFR § 205.605 current as of 2026-07-02.