Liquid Fish Products

What are the recent regulatory updates that impact synthetic acid stabilization for fish products?

By Jennifer Christie

Growers have used fish products throughout history to provide essential plant nutrients to their crops, and organic producers rely on liquid fish products for this same purpose. However, these products’ proteins degrade rapidly under normal environmental conditions, so modern manufacturers employ acid-stabilization to delay putrefaction and extend the products’ viability. 

When it comes to organics, not all fish products are created equally. In OMRI’s spring 2011 newsletter, we outlined the allowance for acid-stabilized liquid fish products in detail. As mentioned in that article, unprocessed and/or nonsynthetic fish products are allowed in organic production. The National List allows for the use of synthetic sulfuric, citric or phosphoric acid to pH adjust liquid fish products—and now liquid squid by-products—to a pH value of 3.5 or greater (§205.601(j)). (Nonsynthetic acids may be used without this restriction.) Manufacturers of blended fertilizers must document the pH of the acidified portion prior to the addition of other ingredients.

Since 2011, OMRI precedent regarding acid-stabilized liquid fish products has advanced. Variations in how liquid fish products are produced have become evident during OMRI review. Examples of these variations include the acid stabilization of rehydrated fish meal, and the use of enzymes added prior to acid stabilization. OMRI has determined that products made from dry fish meal—which is then rehydrated and acid stabilized—can be used compliantly with the same restrictions on pH value previously mentioned. In addition, OMRI has determined that small amounts of nonsynthetic enzymes may also be used to extract fish waste nutrients prior to stabilization with synthetic acid, provided that no other ingredients are added prior to acid stabilization and pH measurement.

In January 2019, the NOP added an allowance for the use of squid by-products stabilized with synthetic acids as crop fertilizers (untreated squid by-products, as nonsynthetic substances, were allowed prior to this update). OMRI reviews these products in a manner similar to acid-stabilized liquid fish, confirming that the acid has been added to the squid by-products prior to the addition of any other ingredients (with the exception of nonsynthetic enzymes), and confirming that the pH has been adjusted to no lower than 3.5. The new allowance specifies that synthetic sulfuric, citric or phosphoric acids may be used. OMRI will also verify the source of the squid by-products, as the regulations at §205.601(j)(10) specify that they must be derived from food-processing waste.

This article was originally published in the summer 2019 edition of the OMRI Materials Review newsletter, and was revised in July 2024 by Research and Education Manager Peter Bungum.