Lecithin is my nemesis
In prepping for next month’s Month Without Monsanto (starting Monday, and I am so not ready to do this), I’ve reviewed April’s original posts and realized this is going to be harder than I thought. I already have given myself a pass on things in my home (and no, I’m not going to go buy a ton of junk food on Saturday, although the thought did cross my mind). I’ve got decent amounts of non-GMO meat and eggs, my CSA came through and confirmed they don’t use Monsanto-sourced seeds, and I still have some tomatoes, lettuce, cilantro, and cucumbers hanging around outside that are homegrown with non-Monsanto sources. So far, so good, right?
Then I started thinking about organics and the USDA certification. As April pointed out near the end of her original MWM, just because it’s organic doesn’t mean it’s not Monsanto. UGH. Plus – organic is different than 100% organic. Don’t believe me? Here it is straight from the horse’s mouth (the horse in this case being 7 CFR Part 205, the federal regulation defining the organic certification process).
7 CFR §205.301(b)
Products sold, labeled, or represented as “organic.” A raw or processed agricultural product sold, labeled, or represented as “organic” must contain (by weight or fluid volume, excluding water and salt) not less than 95 percent organically produced raw or processed agricultural products. Any remaining product ingredients must be organically produced, unless not commercially available in organic form, or must be nonagricultural substances or nonorganically produced agricultural products produced consistent with the National List in subpart G of this part. If labeled as organically produced, such product must be labeled pursuant to §205.303.
And if you’re really geeky like me, you want to see the National List referenced in this document – that is, The National List of Allowed and Prohibited Substances.
7 CFR §205.606
Nonorganically produced agricultural products allowed as ingredients in or on processed products labeled as “organic.”
Only the following nonorganically produced agricultural products may be used as ingredients in or on processed products labeled as “organic,” only in accordance with any restrictions specified in this section, and only when the product is not commercially available in organic form.
(a) Casings, from processed intestines.
(b) Celery powder.
(c) Chia ( Salvia hispanica L. ).
(d) Colors derived from agricultural products—Must not be produced using synthetic solvents and carrier systems or any artificial preservative.
(1) Annatto extract color (pigment CAS #1393–63–1)—water and oil soluble.
(2) Beet juice extract color (pigment CAS #7659–95–2).
(3) Beta-carotene extract color, derived from carrots (CAS #1393–63–1).
(4) Black currant juice color (pigment CAS #'s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
(5) Black/Purple carrot juice color (pigment CAS #'s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
(6) Blueberry juice color (pigment CAS #'s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
(7) Carrot juice color (pigment CAS #1393–63–1).
(8) Cherry juice color (pigment CAS #'s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
(9) Chokeberry—Aronia juice color (pigment CAS #'s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
(10) Elderberry juice color (pigment CAS #'s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
(11) Grape juice color (pigment CAS #'s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
(12) Grape skin extract color (pigment CAS #'s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
(13) Paprika color (CAS #68917–78–2)—dried, and oil extracted.
(14) Pumpkin juice color (pigment CAS #127–40–2).
(15) Purple potato juice (pigment CAS #'s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
(16) Red cabbage extract color (pigment CAS #'s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
(17) Red radish extract color (pigment CAS #'s: 528–58–5, 528–53–0, 643–84–5, 134–01–0, 1429–30–7, and 134–04–3).
(18) Saffron extract color (pigment CAS #1393–63–1).
(19) Turmeric extract color (CAS #458–37–7).
(e) Dillweed oil (CAS # 8006–75–5).
(f) Fish oil (Fatty acid CAS #'s: 10417–94–4, and 25167–62–8)—stabilized with organic ingredients or only with ingredients on the National List, §§205.605 and 205.606.
(g) Fortified cooking wines.
(1) Marsala.
(2) Sherry.
(h) Fructooligosaccharides (CAS # 308066–66–2).
(i) Galangal, frozen.
(j) Gelatin (CAS # 9000–70–8).
(k) Gums—water extracted only (Arabic; Guar; Locust bean; and Carob bean).
(l) Hops ( Humulus lupulus ) until January 1, 2013.
(m) Inulin-oligofructose enriched (CAS # 9005–80–5).
(n) Kelp—for use only as a thickener and dietary supplement.
(o) Konjac flour (CAS # 37220–17–0).
(p) Lecithin—de-oiled.
(q) Lemongrass—frozen.
(r) Orange pulp, dried.
(s) Orange shellac-unbleached (CAS # 9000–59–3).
(t) Pectin (non-amidated forms only).
(u) Peppers (Chipotle chile).
(v) Seaweed, Pacific kombu.
(w) Starches.
(1) Cornstarch (native).
(2) Rice starch, unmodified (CAS # 977000–08–0)—for use in organic handling until June 21, 2009.
(3) Sweet potato starch—for bean thread production only.
(x) Tragacanth gum (CAS #–9000–65–1).
(y) Turkish bay leaves.
(z) Wakame seaweed ( Undaria pinnatifida ).
(aa) Whey protein concentrate.
(I have no ideas what those CAS #s are – but didn’t want to delete them from the list since they may delineate a certain type of product from another.)
So – twenty-seven nonorganically produced agricultural products may be used in products labeled as organic if the product is not commercially available in organic form (plus a whole subset of coloring agents under (d) of this list). Some of these sound familiar, some of these you may never have heard of. But there’s at least one that I’ve been looking for recently that pops up in a lot more ingredient lists than I anticipated.
Yep, Mr. (p) – Lecithin, de-oiled. I first noticed this on a chocolate bar that my son was writing about for a science project (he had to write the ingredient list out). The only chocolate we happened to have in the house was an organic bar, so silly me, I didn’t realize it wouldn’t have all organic ingredients in it. He was chugging right along with organic cane sugar, organic cocoa, etc. The only ingredient not listed as organic was soy lecithin. Not having such a substance in my spice rack, I didn’t know what it was for, so we had to look it up. Turns out, it’s an emulsifier (a binding agent) and is ubiquitous in processed foods. It’s even in the organic peanut butter crackers my kids had for a snack yesterday. And since it’s on the official list up there, it and its 26 other friends are probably hanging out in a certified organic food product near you.
However, there is hope. USDA’s National Organic Program has a Q&A posted specifically about the types of lecithin allowed in organic processed products, where fluid lecithin must be organic, and nonorganic de-oiled lecithin may only be used if organic is not commercially available. So the lecithin issue, at least, is inching closer towards organic.
And the last question on the Q&A is helpful, at least:
Can non-organic, de-oiled lecithin be used if it is produced from genetically modified sources?
No. All ingredients used in products labeled “organic”, “100% organic”, or “made with organic (specified) ingredients or food group(s))” must be produced without the use of excluded methods as per § 205.105(e).
Just for additional geekery, here’s the definition of excluded methods:
Excluded methods. A variety of methods used to genetically modify organisms or influence their growth and development by means that are not possible under natural conditions or processes and are not considered compatible with organic production. Such methods include cell fusion, microencapsulation and macroencapsulation, and recombinant DNA technology (including gene deletion, gene doubling, introducing a foreign gene, and changing the positions of genes when achieved by recombinant DNA technology). Such methods do not include the use of traditional breeding, conjugation, fermentation, hybridization, in vitro fertilization, or tissue culture.
So, what I learned is this: Organic doesn’t automatically equal Nonsanto. But not because of the non-organic ingredients in certified organic products. Check with the company to make sure they’re not a subsidiary of Monsanto, and if it’s USDA organic, you should be safe. I think. Man, my brain hurts.
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