The permitted uses of sulphur dioxide and sulphites in organic production are narrower than in conventional production. Organic processing may only use additives that are specifically authorised for organic use, and the authorised list under Regulation (EU) 2018/848 and its implementing acts is restricted and has been amended.
That means three things in practice.
- **Do not assume.** Whether a specific sulphite use is permitted for a specific organic commodity is a question for your control body, answered in writing, with the date recorded. It is not answered by the conventional additive maximum.
- **Keep the lines separate.** A treatment that is routine on the conventional line is a certification incident on the organic one. Physical and documentary separation from intake through to dispatch is what defends the status.
- **The labelling obligation is unchanged.** Where sulphur dioxide is present above the declaration threshold, it must be declared under Regulation (EU) No 1169/2011 regardless of whether the product is organic.
Commercially, most organic dried fruit is sold unsulphited, and buyers of organic ranges usually expect it. Unsulphited light-coloured fruit browns, which is its natural appearance, and the shelf life then has to be achieved by drying to a lower water activity and by better packaging rather than by a preservative.