AHPA supports USDA’s proposal to allow pullulan in products labeled organic

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The American Herbal Products Association (AHPA; Washington, D.C.) sent a letter to the U.S. Department of Agriculture's (USDA's) Agricultural Marketing Service (AMS) to support adding pullulan to the National List at 7 CFR § 205.605 as a nonagricultural (nonorganic) ingredient that can be used only in tablets and capsules for dietary supplements labeled, “Made with organic (specified ingredients or food group(s)).” AHPA membership includes numerous companies that grow herbal crops or market herbal products certified as organic under USDA’s National Organic Program (NOP), including capsuled dietary supplements that include pullulan as an ingredient.

On June 8, 2020, USDA’s AMS issued a proposed rule to amend the National List of Allowed and Prohibited Substances within USDA’s organic regulations by adding several substances to implement recommendations submitted to the Secretary of Agriculture by the National Organic Standards Board (NOSB), which included the proposal to add pullulan. AHPA explains in its comments that pullulan has a history of use in encapsulated supplement products classified as organic by the NOP because pullulan was previously classified as agricultural. This was until December of 2016, when pullulan was classified as a nonagricultural substance. 

Pullulan’s inclusion to the National List would maintain the status quo by allowing dietary supplements in tablets and capsules that include pullulan to continue to be labeled, “Made with organic (specified ingredients or food group(s)).” Pullulan is currently a key ingredient in non-animal-sourced capsules, as a vegetarian alternative to gelatin.

“The addition of pullulan to the National List at 7 CFR § 205.605 will ensure that the option of vegetarian herbal supplement capsules continues to be available, thus supporting both the farmers who grow organic herbs and the consumers who choose to include supplements in this form in their personal health care choices,” said AHPA in its letter.

AHPA also expressed support for comments submitted by the Organic Trade Association (OTA), which go into greater detail on the issue of adding pullulan to the National List.