Ascorbyl Palmitate
According to the OCA lawsuit against Honest Co.:
Ascorbyl palmitate is a chemical preservative. 21 C.F.R. § 182.3149. It is not permitted in organic products. 7 C.F.R. §§ 205.105(c), 205.605; Cal. Health & Safety Code § 110820. Ascorbyl palmitate is prepared by condensing palmitoyl chloride and ascorbic acid in the presence of a dehydrochlorinating agent such as pyridine. It can also be produced by esterifying ascorbic acid with sulfuric acid, and then with palmitic acid. Other patented processes use dimethylformamide, dimethyl sulfoxide, or hydrogen fluoride instead of sulfuric acid.
Ascorbyl palmitate is a synthetic form of vitamin C, so it has currently been allowed in organic products under the vitamins and nutrients clause. It may, however, not be actually being used as a nutrient in the product, but as an antioxidant to keep unstable oils (like omega-3s) from turning rancid. So, you may find it more in formulas with DHA and AHA added. (Source)
L-ascorbic acid is the most natural form of vitamin C, however, it can be unstable and not oil-soluble like ascorbyl palmitate. While ascorbyl palmitate is created synthetically, the finished product isn’t harmful and is actually sold on its own as a vitamin C supplement as vitamin C ester. Ascorbyl palmitate has been found to be as bioavailable form of vitamin C as l-ascorbic acid. (Source)
Bottom line:
If it’s being used as an antioxidant and not truly as a nutrient, it probably doesn’t have a place legally in an organic product. There are organic substances that formulators could use to keep their oils from turning rancid, like organic rosemary extract. However, ascorbyl palmitate doesn’t appear to pose any significant health risks and can actually be nutritive.
Calcium pantothenate
The OCA complaint against the Honest Company says:
Calcium pantothenate is synthetically prepared from isobutyraldehyde, a synthetic flavoring substance and toxic chemical, 21 C.F.R. § 184.1212, 40 C.F.R. § 372.65, and formaldehyde, a hazardous substance, 40 C.F.R. § 116.4, via 1,1-dimethyl-2-hydroxypropionaldehyde and pantolactone, 21 C.F.R. § 184.1212.
Calcium pantothenate is the calcium salt of vitamin B5, pantothenic acid. While it is manufactured with some pretty harsh synthetics, the finished product isn’t harmful. Vitamin B5 is an essential nutrient for growth and metabolism. It helps the body maintain and transport co-enzyme Q10.
There are no known adverse side effects of calcium pantothenate other than gastrointestinal effects when taken in extremely high amounts (way higher than what’s used in the formulas). (Source)
Bottom Line:
Calcium pantothenate as a finished product isn’t harmful and adds nutritive value to the baby formula. However, it may not be needed if cow or goat milk is in the formula, as both milks naturally contain more B5 than breast milk. (Source) However, the FDA requires that baby formulas contain a minimum content of B5, so formulators add calcium pantothenate to make sure the product meets the legal requirements. (Source)
Choline bitartrate and Choline chloride
According to the OCA lawsuit against the Honest Company:
Choline bitartrate is a synthetic substance produced by the reaction of trimethylamine with ethylene oxide followed by treatment with tartaric acid. Trimethylamine and tartaric acid are both hazardous substances. 40 C.F.R. § 116.4. Choline bitartrate is not the same substance as choline, an ingredient permitted in organic non-milk-based infant formulas. Choline bitartrate (C9H19NO7) is a synthetic variation of choline (C5H14NO), a nutrient naturally found in grains, nuts, and beans.
Similarly, choline chloride is a synthetic substance produced by reacting trimethylamine and concentrated hydrochloric acid (both hazardous substances), followed by treatment with ethylene oxide under pressure.
The FDA requires that any infant formula *not* containing cow’s milk is supplemented with some form of choline, which would be either choline bitartrate or choline chloride. It is not required in a cow’s milk-based formula. There is some concern that because they are both processed with ethylene oxide and potentially contain traces of 1,4-dioxane. (Source)
Bottom line:
Organic soy lecithin could be used in a cow milk formula to boost choline levels. While the lecithin itself doesn’t contain choline, lecithin is able to boost the body’s choline levels as much as added choline can. (Source) If it’s a goat milk or soy based formula, any product sold in the US is legally required to add some form of choline.
Cholecalciferol
According to the OCA complaint against Honest Company:
Cholecalciferol can be produced from fish liver oils, but Honest’s labels do not indicate that any ingredient was derived from seafood. The other method of production requires ultraviolet irradiation of ergosterol isolated from yeast and related fungi and purified by crystallization, or ultraviolet irradiation of 7-dehydrocholesterol produced from cholesterol.
The problem that OCA has with cholicalciferol is that UV “irradiation” is used, and “irradiation” is not allowed in organic foods. However, I believe that there is some confusion–ionizing radiation is not allowed in organic production, but “ultraviolet irradiation” can simply mean shining light on something. It is unclear which frequencies are used in D3 production, which would indicate whether it’s ionizing radiation or not.
Bottom Line:
Cholecalciferol is an essential nutrient that is legally required to be present in an infant formula. Using D3 from fish liver oil poses challenges with rancidity stability as well as complications from potential seafood allergies. No matter how it’s produced, cholecalciferol is an essential and safe nutrient addition to baby formula.