From the Rav’s Desk: Kashrus of essential oils for Pesach

Question: [Tuesday, 11^th Nissan, 5782]

Must essential oils be Kosher for Pesach?

Answer:

If plan to consume: If you would like to consume the essential oil and add them to a recipe, then they are to be certified or verified as Kosher for Pesach. This certainly applies to not 100% essential oils, and even to 100% essential oils, being that some are produced using ethyl alcohol.

External use [i.e. smell, smear on skin]-nonedible essential oils: If you simply want to use it as part of aromatherapy, such as to smell or apply topically to the skin, then if it is not an edible oil [i.e. not safe to consume even in small amounts such as amphor, eucalyptus oil, tea tree oil, or pine oil, lavender oil], it does not need to be certified as kosher for Pesach, and all such 100% essential oils are valid for use, so long as they do not derive from any of the five grains [i.e. this would exclude wheat germ essential oil, barley oil, oat oil, rye oil, spell toil].

External use [i.e. smell, smear on skin]-edible 100% essential oils: If the essential oil is edible, then one should write to the company and verify as to whether it was produced using solvent extraction, and if yes, then as to whether chametz grain ethyl alcohol was used. If the answer is no, then it may be used. If the answer is yes, or one could not verify, then it should not be used, and should be sold for Pesach, even though there remains possibility of leniency even in such a case.

Not 100% essential oils: Not 100% essential oils that contain other ingredients may or may not be Kosher for Passover use for smell or application onto skin, and this depends on their ingredients, as well as whether the mixture is toxic or edible for humans. If it is toxic and not edible, then it may be used even if it contains Chametz ingredients, although some are stringent not to do so. [An example of some non-100% essential oils which contain other ingredients are 1) synthetic essential oils, 2) natural essential oils. Only if the bottle states on it “100% pure essential oil” should it be trusted to not contain other ingredients.]

Explanation:

100% pure essential oils do not contain any other additives, other than the plant from which they are produced from. Their production is most commonly through steam distillation, and other methods, which is a grain and chametz free process. [There are six methods in which essential oils are produced: 1) Hydro Distillation; 2) Steam distillation; 3) solvent extraction 4) co2 extraction; 5) expression; 6) enfleurage.] However, some are produced using a solvent extraction [number 3 above] which may contain ethyl alcohol that is Chametz grain derived. Nonetheless, even by those essential oils produced through solvent extraction, it is not clear that they are produced using ethyl alcohol. Furthermore, even if they are produced using ethyl alcohol, not all ethyl alcohol is Chametz derived. [Ethyl alcohol is produced from grains such as corn, wheat, barley and rye. In the USA, almost all ethyl alcohol is produced from corn and not from other grains, although some may use wheat in production, and so is common in Europe to also use some other grains together with corn in their ethyl alcohol production.]

Accordingly, the question is raised as to whether one can assume that his 100% essential oil has not been produced through a solvent extraction using a Chametz grain ethyl alcohol, and as to what the law would be if it was produced through this method. So, even if it were to be ascertained that a specific type of 100% essential oil was produced through the solvent extraction method using Chametz grain ethyl alcohol, this would not necessarily mean that it is automatically invalid for use during Pesach and must be sold to the Gentile. If the essential oil is not considered edible to humans, and is not considered a food product or a product that is commonly used with foods, then it would be no different than all other cosmetic products which are permitted to be used on Pesach even if they contain a Chametz ingredient [i.e. shampoo soap conditioner etc.], being that they are not an edible mixture, and it would be only a stringency to avoid using it. In the case of 100% essential oils, there would seemingly not even be a reason to be stringent being that most likely it was not even produced through solvent extraction, and even if it was, it is highly possible that a non-Chametz grain ethyl alcohol was used. Furthermore, even if used, perhaps it is nullified in 60x and does not have the Chumra of a Mamaid.  It is thus considered a Sfek Sfeika of which majority points to a non-Chametz process that would anyways be nullified in 60x, and hence it would be a real Chumra to be Machmir to not use essential oils.

However, what about those 100% essential oils that are edible and can be added as ingredients to food? What would be there law if indeed they were produced using the solvent extraction method of Chametz grain ethyl alcohol. By such oils, seemingly they would need to be treated as a food item that was created using Chametz as its catalyst, of which the law is that not only is it rabbinically forbidden to be eaten on Pesach but it is rabbinically forbidden to even be owned, even if the ratio of the Chametz catalyst is more than 1 to 60, as a catalyst is not nullified even in a thousand times. Accordingly, it should be forbidden to even own such essential oils and let alone benefit from them being that their catalyst for production is Chametz. However, even so an argument can still be placed to allow such oils as:

1. It is a mere doubt as to whether indeed a Chametz grain ethyl alcohol was used and in a majority of cases it is not used, as we explained above.
2. Even if one knows for certain that it was used, when producing essential oils it is often first mixed with Hexane which is a toxic compound that would rend the ethyl alcohol as inedible, and hence invalidate its Chametz status.
3. Even if one were to argue that the hexane does not rend it inedible, at the very least, we would consider the final oil solution to have been produced through a pair of two catalysts, one being the ethyl alcohol, and the second being the hexane, and the rule is that whenever the Chametz ingredient alone could not catalyze the product by itself and had to be used together with the second catalyst that is not Chametz, then it is nullified in 60 times. [However, depending on how it is produced, it is possible that there is not 60 times in the product versus the ethyl alcohol, and this would need to be verified. Likewise, one would need to verify if in truth the ethyl alcohol could not do the job on its own.]
4. Whenever alcohol is used in the production process of the oils, it is later removed and evaporated from the product [hence giving them the ability to list it as 100% essential oil without any ethyl alcohol in its ingredients], and perhaps it would therefore be more lenient than the law by a typical catalyst discussed in Halacha, which refers to a catalyst that its substance still remains within the ingredients and has not been evaporated, as opposed to here where its substance has been evaporated and only its effects have remained. We find such a leniency recorded in some Poskim regarding Chelev that fell into a food and was later extracted and does not need 60 times. However, in truth this argument can be negated as a) Most Poskim rule that even if the Cheilev has been extracted we still require sixty times versus the taste and b) we rule that if one used a non-kosher stomach catalyst to make cheese that the cheese is forbidden even though the stomach is removed afterwards. Whatever the case, the previous reasons of leniency would still apply. Accordingly, there exist reasons to argue that it is not necessary for 100% essential oils to be verified as kosher for Pesach even if they are edible. Nonetheless, since this matter verification can be achieved and we are stringent in all matters that relate to Chametz on Pesach, therefore, we concluded that all edible essential oils should be verified through their company as to whether they were produced using solvent extraction, and as to whether a Chametz grain ethyl alcohol was used for this purpose. If the company replies that they did not use solvent extraction or ethyl alcohol, then you can treat it as kosher for Pesach. If they reply that they use it, then one is to use a different brand.

Sources: See here regarding how essential oils are produced: https://613tube.com/watch/?v=ONSw77LMSyI; See here regarding their consumption: https://www.nebraskamed.com/primary-care/essential-oils-do-they-work-are-they-safe; See regarding the law if a Chametzs catalyst was used to produce a food product: Admur 442:10; 447:48; Michaber 442:5; Michaber and Rama Y.D. 87:11; Shach 87:34; Peri Chadash 87:29; Kreisi 87:23; P”M 87 S.D. 34; Zivcheiy Tzedek 87:67; Kaf Hachaim 87:93; Forbidden to even own: Admur ibid and Kuntrus Achron 9; M”A 442:9; Peri Chadash 442:5; Chok Yaakov 442:16; Is nullified in 60x if another catalyst was used with it and could not catalyze on own: Admur 442:11; M”A 442:9; Rama Y.D. 87:11; Taz 442:4; Y.D. 87:13; Shach Y.D. 87:36; Beis Lechem Yehuda 87:38, brought in Kaf Hachaim 87:98 See regarding if the Issur was removed from the food: Rama 98:4; Shach 98:16; Taz 98:7; Bach in his Sefer Bayis Chadash, brought in Shach and Taz ibid; See regarding the status of inedible products that contain Chametz: Owning: Admur 442:22; Michaber 442:1 and 4; Rambam 4:12; Benefiting: Admur 442:24; M”A 442:7 regarding the Tiraka; Chok Yaakov 447:13 and 18; Implication of Terumos Hadeshen 113; See regarding inedible Chametz: Admur 445:11 and 442:24 “Any item that is permitted to be owned on Pesach may likewise be benefited from”; Michaber 445:2; Pesachim 21b; See that it is nevertheless Rabbinically forbidden to eat it intentionally: Admur 442:21-22 and 32-34; 433:25 and 445:4 and 11 and 466:3; Michaber 442:9 and 445:2 and 4; Pesachim 21b; Rif Pesachim 13b; Taz 442:8; Bach 442; Tur 442 in name of Rosh and Riy Abartzelona; Rabbeinu Yerucham 5:13; Terumos Hadeshen 129; Erech Hashulchan 442:5; Kaf Hachaim 442:99; See regarding smearing on body and if we say Sicha Keshtiyah: Admur 326:10; Nekudas Hakesef Y.D. 117:4 that from letter of law is Mutar; Peri Chadash 117:4; Machazik Bracha 614; Tosafos Nidda 32a; Tosafos Yuma 77a and Rashba, Ritva, Tosafos Rosh and Meiri on Nidda ibid; Rashbatz; Beis Yosef 123 in name of Rashba; Beis Yosef 117 in name of Orchos Chaim p. 312; Bach 117; Taz 117:4; Issur Viheter 39:34; Semag; Semak; Zivcheiy Tzedek 117:45; Gr”a O.C. 326:10; Aruch Hashulchan 117:29; Kaf Hachaim 117:15; Shoel Umeishiv Mahadura Gimel 2:148 regarding soap; Chazon Nachum 46; Yalkut Yosef p. 360; Piskeiy Teshuvos 442:2