While the number of food manufacturers claiming to offer wholesome, healthy packaged foods is growing, there is no clear understanding of what constitutes healthy, “raw” and ”clean” foods. Also, more and more people are incorporating what they believe to be raw foods into their diets principally for health and taste reasons. But there is debate and confusion over what actually constitutes “raw” and what the characteristics should be to maintain a food’s ”raw” quality at point of sale and also protect consumers from food borne diseases. Leaders of the Raw Food community since the Fancy Food Show in 2014 have been working hard to define what is “raw” and “clean” and to create a certification program for the community to ensure compliance to move our rapidly growing industry forward.
We are pleased to announce that RawFoodCertified.Org, a 501(c) project of International Center for Integrative Systems, will be the home of this certification program. A series of meetings and public hearings have been held with Dr. Shiva Ayyadurai, PhD., an MIT-trained scientist and systems biologist, leading the discussion and sharing our results and the steps that we can follow to gain certification for our products. We have been fortunate to get feedback from various parties including Go Raw, Raw One Food, Living Intentions, Alive and Radiant, Living Brands, Hail Merry, Whole Foods, Wonderfully Raw Gourmet, and Rhythm Superfoods, and many other scientists and health care practitioners, in developing this program.
This consensus-based standard’s criteria incorporate the inputs from the food stakeholder community of consumers, public interest groups, growers/farmers, food processors, trade associations, food retail stores, restaurants, regulatory agencies and academicians. The criteria focus on three categories – Safety, Minimal Processing and Bioavailability of nutrients, and defines two imprimaturs – Certified R.A.W. and Certified C.L.E.A.N.
Certified C.L.E.A.N./Certified R.A.W. are consensus-based Standards that have been developed by the community of stakeholders in the food manufacturing industry to support the raw and clean food movement, reflecting a diverse range of perspectives. Beginning with the first public hearing on February 2, 2015, ongoing public hearings and Standards Committee meetings have been established as an important mechanism for keeping the standard current, transparent and adaptive. The most recent public hearing was held on Nov 29, 2018, and the most recent Standards Committee meeting was held on Dec 18, 2018.
Version 1.5 of the Certified C.L.E.A.N. and Certified R.A.W. Standards were published on February 15, 2019.
Critical Updates to the Standards
C.L.E.A.N. & R.A.W. Standards were made compliant with FDA’s FSMA Final Rule for Preventive Controls for Human Food.
- Per this rule, domestic and foreign food facilities that are required to register with section 415 of the Food, Drug, & Cosmetic Act must comply with the requirements for risk-based preventive controls mandated by the FDA Food Safety Modernization Act (FSMA) as well as the modernized Current Good Manufacturing Practices (CGMPs) of this rule (unless an exemption applies). It is important to note that applicability of the CGMPs is not dependent upon whether a facility is required to register. This rule requires food facilities to have a food safety plan in place that includes an analysis of hazards and risk-based preventive controls to minimize or prevent the identified hazards.
On feedback from the US Department of Agriculture (USDA,) relevant sections of the Certified C.L.E.A.N. and Certified R.A.W. Standards were modified to reflect the below:
- FSIS not part of FDA
- USDA does not audit manufacturing facilities which is done only by Certifiers
Version 1.4 of the Standards that includes the above changes was published on Jan 22, 2018.
Subsequent to Public Hearing IV on January 19, 2017, the following updates to the the Certified C.L.E.A.N. and Certified R.A.W. Standards were published on March 22, 2017:
- Separate documentation for C.L.E.A.N. and R.A.W.
- To help the community clearly identify eligibility for Certified C.L.E.A.N. and Certified R.A.W., the documentation for the Standards was split into two – one for Certified C.L.E.A.N. and another for Certified R.A.W.
- Exclude non-certifiable ingredients from Organic criteria
- Change incorporated in Section 5.1 of C.L.E.A.N. and R.A.W. Standards: Natural aquatic ingredients, like seaweed, or those developed using aquaculture, are exempt from being required to be certified as Organic.
- Remove 212° Fahrenheit restriction; consider bioavailability of nutrients
- Restriction removed from requirement and documentation of C.L.E.A.N. certification
We encourage you to read through the new Standard and if you would like to submit any comments about the changes made in v1.3, please use this form.
Key Elements of the Standards
The three unique core concepts defining this food certification are: (1) Safety, (2) Minimally Processed and (3) Bioavailable Nutrients.
• HACCP – Hazard Analysis and Critical Control Points
• GMP – Good Manufacturing Practices
• COA – Certificate of Analysis
• Registered with the US Food and Drug Administration (FDA)
• Post Packaging Product Shelf-Life Testing
• Organic Certified
• Below 212º Fahrenheit (for Certified R.A.W. only)
• Analyzed by CytoSolve (CS® Tested™) on a score ranging from 0 to 20 for enzymatic activity