Fruit and Vegetable Coatings

I see that OMRI has multiple Generic Materials List (GML) categories for fruit coatings. Can you explain these categories? Specifically, can I use nonorganic orange shellac to process apples?

By Doug Currier

Fruit and vegetable coatings, sometimes called edible films, are applied directly to the outside of produce in order to preserve freshness and maintain quality standards often associated with appearances that consumers have come to expect. Besides orange shellac, other common materials used for these purposes include starch, carrageenan, alginates, wood rosin and various waxes. 

Since these coating materials come into direct contact with produce, their use on organic foods is regulated by the USDA organic standards, specifically §205.605 and §205.606. Nonagricultural materials such as carrageenan, waxes (carnauba and wood rosin), and alginates are identified as “Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as ‘organic’ or ‘made with organic (specified ingredients or food groups))’ as listed at §205.605. Orange shellac-unbleached (CAS# 9000-59-3) is a common agricultural material used as a fruit and vegetable coating and is identified with other allowed “Nonorganically produced agricultural products allowed as ingredients in or on processed products labeled as ‘organic’” at §205.606. Beeswax, another common agricultural edible film, is not included at §205.606 and therefore must be certified organic if used on food that is labeled “organic.” Nonorganic forms of beeswax can only be used in products labeled as “Made with Organic (specified ingredients or food group(s))." 

The standards for the use of orange shellac-unbleached, which is listed at §205.606, differ from the other materials listed at §205.605due to the classification of shellac as agricultural. There is a commercial availability restriction imposed on agricultural substance listed §205.606. In other words, nonorganic orange shellac can only be used when an organic form is not commercially available. So, if organic orange shellac is not available in the form, quality, or quantity needed, nonorganic forms may be used to coat those organic apples. 

OMRI differentiates “allowed” fruit coatings from “restricted” by listing products in specific GML categories. For example, OMRI lists products in an allowed category when they incorporate §205.605 materials and organic agricultural materials. Conversely, OMRI lists products in a restricted category when they contain one or more restricted materials. An example of a restricted material is a nonorganic agricultural material identified at §205.606 that must meet any restriction as outlined in an annotation at 205.606 and may not be used if commercially available in organic form. It is up to a processor’s certifying agent to confirm a 606 material is not available in organic form. Nonorganic beeswax is also a restricted material and, since it is an agricultural product not included at §205.606, limited to use in products labeled as ‘Made with Organic [specified ingredients]’. 

Revised and updated in October 2017 by OMRI Technical Director Johanna Mirenda. This article was originally published in the Fall 2015 edition of the OMRI Materials Review newsletter.