# Is this additive allowed in organic food? How to check

> An additive or processing aid may only be used in certified organic food if it appears on the permitted list for the standard you are certified to, and only for the purposes and under the conditions that list specifies. Being outside the organic percentage calculation does not make a substance allowable — permitted status is a separate test, and it differs between New Zealand, the EU and the USDA.

Source: https://anzoc.co.nz/resources/organic-additives-processing-aids-list
Published: 2026-09-28 · Last updated: 2026-09-28 · Author: Fliss Roberts, ANZOC

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## Two separate tests, often confused

Every non-agricultural input faces two independent questions, and passing one says nothing about the other.

| Question | What it decides | Where the answer lives |
| --- | --- | --- |
| Does it count in the organic percentage? | Whether it affects your 95% or 70% tier | The calculation rules — additives and processing aids are **excluded** |
| Is it permitted at all? | Whether the product can be certified organic at any tier | The permitted substances list for your standard |

A non-permitted processing aid disqualifies the product even though it contributed nothing to the percentage. This is the failure mode that catches technically-minded teams who have done the arithmetic carefully and never checked the list.

## Where the authoritative lists are

| Standard | What to consult | Notes |
| --- | --- | --- |
| New Zealand | The National Organic Standard issued under the Organic Products and Production Act 2023, and the organic notices made under it | Mandatory from 31 March 2028; your certifier applies it now |
| European Union | Regulation (EU) 2018/848 and its implementing regulations, Annex V | Strictest of the three for additives; also no "made with organic" tier |
| United States | USDA NOP National List, 7 CFR 205.605 (non-agricultural substances) and 205.606 (non-organic agricultural substances) | Entries are frequently annotated with conditions of use |
| Australia | Your certifier's standard, e.g. the Australian Certified Organic Standard | Australia has no single mandatory domestic standard |
| Your certifier | The certifier's own input approval process | **This is the decisive one.** Certifiers may be stricter than the standard and their approval is what your audit checks |

> **Why this page has no substance-by-substance table yet** — A permitted-substances table is only useful if it is exactly right and kept current, and a wrong entry here would cost somebody a production run. We are compiling one from the New Zealand standard for review by a certifier before publication. Until it is signed off, use the primary lists above and your certifier.

## The categories that cause the most trouble

- **Acidity regulators.** Widely used, widely assumed to be fine, and treated differently between standards depending on how the substance is produced.
- **Raising agents.** Some forms are permitted, some are not, and the permitted form is often the more expensive one.
- **Carriers and anti-caking agents in other ingredients.** These arrive inside a bought-in ingredient and never appear on your own batch sheet. Ask suppliers for the full composition, not the marketing sheet.
- **Enzymes and fermentation aids.** Permitted status can turn on the production organism and whether it is genetically modified.
- **Filtration media and release agents.** Classic processing aids: they do not appear in the finished product, they do not affect the percentage, and they can still fail an audit.
- **Flavourings.** Composition is often proprietary, which is exactly why certifiers ask for a full declaration before approval.

## What to record for each input

Your input register is the document an auditor will ask for first. For every non-agricultural input, record:

1. Substance name, INS or E number where one exists, and the supplier.
2. Function in your process, described in the same terms the permitted list uses.
3. Source and production method, including whether any GM organism is involved.
4. The list entry it relies on, by standard, for every market you sell into.
5. Any conditions or limits attached to that entry.
6. Date your certifier approved it, and the approval reference.

## How to check whether an additive or processing aid is permitted in organic food

1. **Identify the substance precisely.** Chemical name, INS or E number, and the specific form and source. "Citric acid" is not one substance for this purpose: fermentation-derived and synthetic forms can be treated differently.
2. **Identify its function.** Permitted lists are organised by function — preservative, acidity regulator, carrier, processing aid. The same substance can be permitted for one function and not another.
3. **Check the list for every standard you certify to.** NZ National Organic Standard, EU 2018/848 Annex V, USDA NOP National List at 7 CFR 205.605 and 205.606. A substance permitted in one is not automatically permitted in the others.
4. **Check the conditions attached.** Many entries carry limits: only for a named product category, only where no organic alternative exists, only up to a stated level.
5. **Get it approved and record it.** Add the substance, its function, its source and the list entry to your input register, and have your certifier approve it before first use.

## Questions people ask

**Do additives count towards the organic percentage?**

No. Non-agricultural additives and processing aids are excluded from both sides of the calculation. They still have to be individually permitted under the standard you are certified to, which is a separate test.

**Is citric acid allowed in organic food?**

It depends on the standard, the production method and the function it performs. Fermentation-derived and synthetic forms are not always treated the same way. Check the permitted list for each market you sell into, and confirm with your certifier before use.

**If a processing aid does not end up in the finished product, does it matter?**

Yes. Processing aids are assessed on use, not on residue. A non-permitted aid is a non-compliance even if none of it remains in the product.

**Can my certifier approve something that is not on the list?**

No. Certifiers apply the standard; they cannot extend it. They can be stricter than the standard, and sometimes are, but they cannot permit what the standard does not.

**What if an ingredient contains an additive I did not add?**

It still counts as used in your product. Ask every supplier for the full composition of what they sell you, including carriers and anti-caking agents, and record it in your input register.

## Sources

- [USDA NOP National List — 7 CFR 205.605](https://www.ecfr.gov/current/title-7/subtitle-B/chapter-I/subchapter-M/part-205/subpart-G/section-205.605)
- [USDA NOP National List — 7 CFR 205.606](https://www.ecfr.gov/current/title-7/subtitle-B/chapter-I/subchapter-M/part-205/subpart-G/section-205.606)
- [Regulation (EU) 2018/848 on organic production and labelling](https://eur-lex.europa.eu/eli/reg/2018/848/oj)
- [MPI — Organic product requirements in NZ](https://www.mpi.govt.nz/agriculture/organic-product-requirements-in-nz)
- [Organic Standards Regulations 2025 — New Zealand Legislation](https://www.legislation.govt.nz/secondary-legislation/pco-drafted/2025/197/en/latest/)

## Related

- [Which ingredients count towards your organic percentage](https://anzoc.co.nz/resources/organic-ingredient-rules-what-counts)
- [What may go in the non-organic 5%](https://anzoc.co.nz/resources/non-organic-5-percent-allowance)
- [How to make a certified organic product](https://anzoc.co.nz/resources/how-to-make-a-certified-organic-product)

This page is general guidance, not certification advice. Your certifier makes the final decision.