We are sharing the answers to some of the questions we receive most frequently from handlers.

My boiler additives are allowed for food contact substances as defined in 21 CFR 173.310, so why can’t I use them?

Any non-agricultural ingredient, processing aid or other substance (such as a sanitizer or boiler chemical) that contacts organic ingredients must be listed on the National List of Allowed and Prohibited Substances, 7 CFR Part 205.605, and must meet the specific annotation as applicable, regardless of whether it qualifies as a food contact substance as defined in 21 CFR 173.310. In the case of boiler additives, the National Organic Standards Board (NOSB) and NOP have specifically reviewed and approved or prohibited these types of substances in and on organic products.

The QAI application asks for the legal entity to be listed; is that the physical location or parent corporation of the location being inspected?

The location producing or handling organic products needs to be listed on the QAI organic certificate by its legal business name. This is typically the name as listed on the business license issued by a state agency or on tax documents. It is not uncommon for a corporate entity to own multiple locations. The corporate company would be listed on the application and certificate as the owner in addition to the legal entity being certified. If the business being inspected is operating out of a leased facility, the registered business is the legal entity QAI certifies, not the owner of the physical location being leased. QAI may request a copy of the lease agreement if necessary to ensure the correct company is being certified.