Is fermented cod liver oil really rancid?

Is Green Pastures Fermented Cod Liver Oil really rancid?

Green Pastures Report

Green Pastures fermented cod liver oil (FCLO) has been considered the gold standard amongst cod liver oil supplements for a long time, but independent research by Dr. Kaayla T. Daniel on the oil has gotten a lot of heads turning and people thinking. The report has some quite shocking and worrying results and as someone who has been recommending and selling FCLO for years I was understandably very concerned. I’ve given the report plenty of thought and done some additional background reading on the subject to understand what the results mean, and below I’ve expressed my thoughts on these findings. You can read the whole 111 page report here if you like, but I’ve summarised her findings below.

Summary of Dr. Kaayla’s report

  • Cod liver cannot be fermented because fermentation requires carbohydrates.
  • 7 Samples of fermented cod liver oil were sent to 7 different labs to test for:
    • 6 Rancid bio-marker tests (varying results)
    • Biogenic amines – a product of rotting/ fermented foods with in some circumstances can be toxic
    • Vitamin content showing –
      • Moderate levels of vitamin A.
      • Low levels of vitamin D3.
      • Low/ insignificant levels of Co-Q10 and vitamin K.
  • DNA testing which shows the product is 100% Alaska Pollock.
  • Trans-fat content (suggesting heat processing/ vegetable oil).

How are cod livers fermented?

In biology, the fermentation process generally does require carbohydrates for the bacteria to feed on. This is true for milk, which contains lactose, and true for the probiotics in our gut which feed on the fibre we eat from plants. Yet cod livers don’t contain any carbohydrates in any significant quantity, which poses the good question of how can a cod liver ferment to produce oil?

Well, although fermentation usually requires some carbohydrates, there are many circumstances where it doesn’t. In fact, the term ‘fermentation’ is defined as ‘the chemical breakdown of a substance by bacteria, yeasts, or other microorganisms1, and there is no need for carbohydrates, although they are usually involved.

There are many fish products which don’t require carbohydrates to ferment, and fish products have been fermented for  years and years, in many countries without carbohydrates2. A great example is a very old East Asian fish sauce recipe which ferments small fish with sea salt to produce a sauce called ‘nuoc mam’ – which is very similar to how Green Pastures create their oil.

So, cod livers can be fermented.

For the record, Green Pastures state that their oil is made using salt, a fish broth starter, and livers. In industrial fermentation, the most common being yoghurt making, a ‘starter’ is a sample of which contains the bacteria cultures needed to produce the product. Using a starter broth ensures a consistent product is produced, and although we don’t know the specific bacteria Green Pastures use (industry secrets I guess), I am more than satisfied that the livers are indeed fermented.

Is fermented cod liver oil rancid?

A rancid fish oil is bad for you, there is no doubt about that, and there are some simple home tests you can do to check if your oil is rancid, but these tests don’t usually work for fermented cod liver oil. For starters, it’s brown, it’s fermented (so will smell different from other cod liver oils) and the ‘gels’ often have flavours/ scents in which would mask some of the rancid flavours/ tastes.

Besides, lab tests are much more accurate and reliable, so I was glad to see that a number of rancid bio-markers have been checked by Dr. Kaayla:


The peroxide value is a measurement of the amount of harmful lipid peroxides, and is an indicator for rancidity. FCLO scored extremely low for lipid peroxides from all lab tests – which is great. Dr. Kaayla says that this is unsurprising as the oil has been fermenting for so long that the lipid peroxides have probably decomposed into secondary and tertiary oxidation products.


Anisidine is one of the secondary metabolites mentioned above, and as peroxide levels go down, the levels of anisidine should go up (and then break down into tertiary oxidation products). Results from Labs 2, 4 and 7 all reported anisidine levels of 6.8, 13 and 3.44 – all of which is lower than the value Green Pastures shows on their site (which is 16). Lab 5 encountered problems in trying to measure anisidine due to colour of the product.

We don’t know what testing methods each lab used to test anisidine in their samples, but these results look very good and show low levels of anisidine (but Dr. Kaayla questions the reliability of the lab reports).


TOTOX is a measure of the total oxidation, and because the peroxide value and anisidine values are so very low, the TOTOX is also very low. This is good news for FCLO users – it doesn’t contain many oxidative products.

TBA (THIOBARBITURIC ACID)/ malondialdehyde (MDA)

MDA is a toxic product made when an oil by-product reacts with DNA. Dr. Kaayla admits that levels of MDA are not a reliable way to determine if fermented cod liver oil is rancid or not, but she tests for TBA/ MDA anyway. Lab 2 and 4 reported very low levels, whereas Lab 7 reported high levels (no results from other labs). Make of this what you will, but it is inconclusive, and even Dr. Kaayla says it means nothing for fermented cod liver oil (other than TBA/ MDA levels are low in 2/3 samples of course).

Free fatty acids content

There is no doubt that Green Pastures FCLO does contain some free fatty acids. This is something that Dr. Kaayla and Green Pastures agree on, but what they don’t agree on is what it means.

Fats are made up of a fatty acids attached to a glycerol backbone in a shape like an ‘E’ (see image) which is called a triglyceride, and it is in this form that you find fats in your food. In fact, this is the form most fats are found in fermented cod liver oil, and the presence of triglycerides is an indicator of a quality fish oil. In the digestive system they get broken down into glycerol and fatty acids by an enzyme called lipase, which allows them to be absorbed. Once absorbed, they are reassembled into a triglyceride.glycerol

Personally, I see no problem with eating fats as free fatty acids, because fats become free fatty acids in the digestive system anyway (you could even think of this as helping the digestive system).

Dr. Kaayla says that these free fatty acids are toxic to cell membranes, and so the body re-assembles them in the body. This may be true, but only once they have passed through the digestive system where they would have been converted in free fatty acids and glycerol anyway.

The presence of free fatty acids is an indicator that an oil is rancid because it shows the triglycerides have broken down, but by no means is it conclusive. The presence of these fatty acids has lead some marine oil experts to say that ‘FCLO is the most rancid oil they’ve ever tested’ (according to Dr. Kaayla) despite the other indicators of rancidity coming back negative.

Dr. Kaayla assumes that these free fatty acids show the oil is rancid (of which we have seen no real evidence for) and so say they are toxic. Yes, rancid fats are toxic, but we do not know that these fats are rancid.

For me, the presence of free fatty acids isn’t something to worry about, and only means that some of the triglycerides are effectively ‘pre-digested’ in a way my body would have done anyway.


The presence of aldehydes is another indicator that an oil has gone rancid. Dr. Kaayla didn’t test for aldehydes, but the Western A. Price foundation did send some samples to De Montford University for testing, which came back as ‘non-detectable’3. So again, good news for fermented cod liver oil.

Rancidity test summary

So, tests for rancidity are either good (not rancid) or inconclusive – hardly the dig at Green Pastures that Dr. Kaayla set out to do. Dr. Kaayla does say that these results would be expected for a product which has been fermenting for so long though (this does pose the question as to why they were tested for to being with…).

Amine content

Amines are not always bad – they give cheeses/ fish sauces/ wines their characteristics for example, but they do have toxic properties and indicate that proteins have ‘gone bad’ or have started to decompose (no surprise they are found in many fermented foods then).

Lab 4 found no amines, lab 2 found moderate but acceptable levels of amines, and lab 7 showed that the amines were very high (no results from other labs). This doesn’t show us much other than there is some variation in the products, which is to be expected. I wouldn’t want a high amine product, so the one high result is a concern, but these findings are far from being conclusive. I would be interested to know what a larger sample would show, but currently, I’m not too worried.

Vitamin content

Green Pastures say their product contains vitamin A, D and a number of quinones which many people (myself included) assume to mean there is a certain amount of co-enzyme Q10 and vitamin K. Dr. Kaayla tested the presence of all these vitamins.

Vitamin A

Dr. Kaayla’s report showed that vitamin A levels in her samples were 732 IU/ml (roughly 3600 IU per US teaspoon), which is well within what Green Pastures quote on their site4. I feel its worth pointing out here that throughout Dr. Kaayla report she quotes figures from the Green Pastures site, but in this case she incorrectly quotes figures from the Western A. Price site and ones which are “lobbed around the internet”, which are 10,000IU per teaspoon (I think, she gives no units).

In fact, the Western A.Price site quotes vitamin A levels in fermented cod liver oil to be 4,000 – 9,000 IU per teaspoon5. This means that Dr. Kaayla’s findings are a little less that what the Western A. Price foundation quote, but within the values Green Pastures have on their site. I do wonder why she didn’t quote Green Pastures’s figures on this…

Vitamin D

Dr. Kaayla’s report found that the vitamin D content of FCLO was 17.6 IU per gram, which is a lot less than the 310 – 1030 IU per gram Green Pastures state on their website.

There is a catch though – Vitamin D is a very difficult vitamin to detect and measure, and I’m not just saying this because Dr. Kaayla’s results show low vitamin D levels. Accurately measuring vitamin D is a problem laboratories have struggled with for a long time6,7. With this in mind, the very best way to measure the vitamin D content of a product, or rather, the vitamin D value of a product, is to feed it to someone for a fixed period of time, and measure changes in their vitamin D levels. If you control all other variables (food, sun light exposure etc) then the only way vitamin D levels will change is a result of the FCLO.

No one has this kind of data (sadly), but Green Pastures do use a rat bio assay to measure vitamin D, which is essentially the same test, but with rats not humans. Could there be a difference in humans and rats? Sure, what that difference is though, we don’t know. There are also mixed anecdotal reports online about how FCLO has or hasn’t helped individuals vitamin D levels, the scientific value of which is minimal, but could suggest that vitamin D content is very variable (more so than previously thought).

We don’t know what tests the labs did to determine vitamin D levels because the labs wanted this data, along with their identity, to remain anonymous. This makes determining the accuracy of their tests somewhat difficult. It would have been useful if the labs did the same rat bio assay to test for the vitamin D content in the fermented cod liver oil, as this would have shown some useful comparisons between the data Green Pastures gets, and what other labs get.

This being said, I am surprised that the labs came back with such low readings for vitamin D. The reason for this could be the method used to detect the vitamin D but I would like to see some more research into this, including rat bio-assays from different labs (or even human trials) to clear this up.

Vitamin K/ co-Q10

Vitamin K and co-Q10 are similar in their structures and both contain a quinone group. The presence of these nutrients is something that has made Green Pastures FCLO stand out from the crowd for a long time, and has made a good selling point for the products. Many fermented products such as cheese contain valuable amounts of vitamin K, so it would be expected that fermented cod liver oil would also contain reasonable levels too.

Dr. Kaayla sent her samples to lab 6, which is the ‘the world’s leading Vitamin K research centre’, and the quinone results came back pretty much as non-detectable. The quinone count was really very low, and this is very disappointing to hear. Quinones are not like vitamin D in their difficulty to measure, and so these results are worrying. Could it be that Green Pasutres had a bad batch, or are lying about their product? Only further tests can say for sure, but these preliminary results don’t look good.

Vitamin E

Tests for vitamin E are low, and this is to be expected for fish oil products. The vitamin E content of FCLO isn’t a selling point, and there is nothing surprising with these results.

Is FCLO from cod?

Dr. Kaayla noticed that the EPA and DHA ratios in Green Pastures fermented cod liver oil are not consistent with other ratios of cod liver oil. Oil from a cod has an EPA: DHA ratio 0.004: 0.1548) (or 2:77). Samples of Green Pastures cod liver oils come to around 2:1, which is very different.

Further research into the Green Pastures cod livers shows that the liver was from a fish called Alaskan Pollock.

Shock horror! The liver isn’t even from Cod!

Well, actually it is. If you want to get into the details of it, Cod is the name of a genus of fish, which means there are many types of cod, and one of these Cod fish is Alaskan Pollock9, which commonly found in the Northern Pacific Ocean.


Dr. Kaayla dismisses this and strongly implies that it is probably a cheap product imported from China, and not the high quality Cod caught in the Arctic that people think they pay for. This is actually quite unlikely – fish from China will probably be intensively farmed and given antibiotics (which Dr. Kaayla has found to not be present in her samples).

In fact Alaskan Pollock (which remember, is a Cod fish) can very well be fished from Arctic waters, and DNA samples recorded by the National Oceanic and Atmospheric Administration (NOAA) showed that Alaskan Pollock is present in the Arctic waters10.

Green Pastures don’t specify the species of cod they use, and only say that it is Cod from the Arctic, which from the information Dr. Kaayla has provided, looks to be true. There is currently no information to suggest that the livers are sourced from anywhere else other than unscientific speculation by Dr. Kaayla.

Trans-Fat in FCLO

Dr. Kaayla’s report does show that a sample contains 3.22% trans-fat, when you would expect there to be none. Dr. Kaayla says that the only way this could be present in the oil is to add a ‘thermally damaged vegetable oil‘. Yes, that would be one way, but the fermentation process could equally be a cause. It would be interesting to see what Green Pastures response to the presence of trans-fats in their product is, because you wouldn’t expect any, and it is a little concerning.

Final thoughts on the report

I always try and keep an open mind with reports like this, especially when I can see that a lot of time and effort has gone into them, but this report seemed flawed from the start. Before Dr. Kaayla did any research or saw any results she had decided that fermented cod liver oil was rancid. She says that “common sense says this product’s rancid” but “proving it is rancid, proved surprisingly difficult”. She has gone out to try and prove that she is right, rather than try and find if FCLO is healthy or not, and this typically leads to people finding results that suit their idea of what is right. The most famous example of this is in the Seven Country case study by Ancel Keys who went out to ‘prove’ the link between saturated fat consumption and heart disease – something which isn’t accepted as true today.

Setting out to prove your theory as Dr. Kaayla has done (combined with the unbelievable amount of terrible puns) somewhat diminishes the value and reliability of the research. When you believe you are right, you will find a way to show you are right (and Dr. Kaayla hasn’t even managed to do that conclusively).

My gut feeling is that Dr. Kaayla expected to find some Earth shaking results, but instead found very little, and has tried to dress them up to be more dramatic than they are.


Dr. Kaayla’s report is far from conclusive, and to be fair to Dr. Kaayla, she does say this is a preliminary report and more research is needed. The only concerns that this report has raised for me is the vitamin K, co-Q10 and trans-fat content of fermented cod liver oil, which I would like more answers for. I would also like to see some more research on the vitamin D content of fermented cod liver oil, but due to the complexity of this, I don’t expect to see anything conclusive any time soon.

I’ll keep my eye out for this information, and update this article accordingly if/ when it becomes available.

You might like to read Green Pastures response to Dr. Kaayla’s report here, which interestingly shows that Green Pastures invited Dr. Kaayla to their facility (all expenses paid) but received no reply from her.


1. Oxford dictionary. (2015). Oxford dictionary. Available: Last accessed 10/9/15.

2. G.Mazza. (2008). 1. In: Edward R.(Ted) Farnworth Handbook of Fermented Functional Foods, Second Edition. Florida: Taylor and francis. 21.

3. martin Grootveld. (2014). n/a. Available: Last accessed 10/9/15.

4. Dr. Jie Zhang. Test Data. Available: Last accessed 10/9/15.

5. David Wetzel. (2009). Update on Cod Liver Oil Manufacture. Available: Last accessed 10/9/15.

6. Andrew M Wootton. (2005). Improving the Measurement of 25-hydroxyvitamin D. Clin Biochem Rev. 26 (1), 33-36.

7. Fraser WD. (2013). Vitamin D assays: past and present debates, difficulties, and developments.. Calcif Tissue Int. 92 (2), 118-92.

8. Original Food Guide Pyramid Patterns and Description of USDA Analyses. Available: Last accessed 10/9/15.

9. Mark W. Coulson et al. (2006). Mitochondrial genomics of gadine fishes: implications for taxonomy and biogeographic origins from whole-genome data sets. Genome. 46, 1115-30.

10. CW and TA Mecklenburg. (2012). What we have learned about change in the distribution of fishes from the RUSALCA mission. Available:

September 11, 2015

The Health Cloud

This site has really interesting articles –

These articles about Green Pasture’s Cod Liver Oil that we have copied and pasted from their site because we think they are really good.

We are a retailer of Green Pasture’s Cod Liver Oil and a Weston A Price Chapter, so we are about as biased as you can get about this subject, but the whole situation annoyed us, because so much of it appears to be a big con job, and to be honest they slaughtered our sales of what we think is a high quality and very effective product.

Rosita and their business partners Corganics have partaken in a very aggressive slander campaign against their primary competitor (Green Pastures fermented cod liver oil). The campaign includes (but is not limited to) creating fake Facebook profiles to promote EVCLO over FCLO in many communities, and the owner of Rosita creating a video which suggests Green Pastures source their oil from China.

Fermented Cod Liver Oil – Let’s look at the Facts


October 7, 2015

Following the recent publication by Dr. Kaayla there has been a lot of speculation and half truth being spread around the internet. All of this has convoluted and twisted the issue at hand, which is the quality and authenticity of Green Pastures FCLO. Dr. Kaayla’s conclusions are a far stretch from what her lab reports show, and I think this has compounded the issue of confusion. In addition to this, people have pointed out that some very influential people have clear political motives which may influence how they interpret the results. People feel very strongly on both sides of this debate, so the aim of this article is to compile and discuss these arguments objectively to try and find where we stand with fermented cod liver oil. I have not been involved in the WAPF in any context before, and do not frequent the prominent bloggers from that community. I have no allegiances to anyone, and I feel that this gives me an impartial view to the situation. All I want to do is provide healthy information and products to our customers in the UK.

So, with this in mind, lets have a look at the facts of the matter, and put the politics to one side.


The labelling of FCLO seems to be the biggest concern. Many people believed that Green Pastures used Atlantic cod, when in fact they were found to use Alaskan pollock in at least one product. I’ve gone into the scientific relationship of Alaskan pollock and cod here, so I won’t touch on that again, rather I’ll look at the legal definitions of the two.

The FDA do not define cod liver oil, but do define cod, and they say that Alaskan pollock is an illegal substitute for cod1. This clearly applies for the food that you might buy from a supermarket or restaurant, but whether it applies for cod liver oil supplements is less clear. I believe this can be interpreted both as applying to supplements, and not applying to supplements depending on how you look at it.

The FDA are also unclear on what is classed as an ingredient on the label of a cod liver oil supplement. Their guidelines state that “the term “ingredient” refers to the compounds used in the manufacture of a dietary supplement1. With ingredients such as calcium carbonate, this is very easily labelled as calcium carbonate because there is no other way to label it. It is less clear when it comes to cod liver oil, and the FDA offers no specifics as to what information is needed on the label. The FDA go as far as to say that allergens (which include cod) must be on the label, but again fail to define what they mean by cod in this context. In biology, the name ‘cod’ is the name for a number of fish which belong in the cod (Gadus) genus, so is simply saying the product contains Gadus sufficient? Perhaps not, but these guidelines can easily be interpreted as such.

The Joint Food and Agriculture Organization of the United Nations and World Health Organization define cod liver oil as “derived from the liver of wild cod, Gadus morhua L and other species of Gadidae”. Alaskan pollock does belongs to the Gadidae family, and even the Gadus (cod) family, so by this definition Green Pastures have not mislabelled their product.

If you look at other brands of cod liver oil, none of them mention the specific species that they use in their oil, and it has been pointed out numerous times that most manufacturers will use a blend of oils from many fish in the Gadidae family. With this being the case (just look at the labels on other brands), it suggests that the FDA regulations for ‘cod’ do not extend to ‘cod liver oil’, otherwise all cod liver oil brands and manufacturers are breaking the law. With this in mind, I see no reason to pressure Green Pastures to name the species of cod they use.

If FCLO is labelled illegally, so are all other cod liver oil brands.

This being said, Green Pastures have responded to the concern and changed their label to mention the specific species they are using. It looks like Green Pastures next batch will contain Pacific cod (which, incidentally, is less closely related to Atlantic cod than Alaskan pollock). This will make Green Pastures label the most specific of all cod liver oil brands I’ve looked at.

Wording from Green Pastures

David Gumpet and others have accused Green Pastures of using legalese in their recent posts about sourcing of their cod, specifically the phrases “We currently do not import livers” and “as noted on the label we are using Gadus macrocephalus (Pacific cod) as this was in excellent supply in the past year.”

The phrasing does suggest other species of cod and other sources of cod livers may be used. This is standard practice for most companies – if one source fails you for whatever reason, you find another one which matches your criteria. You can’t just close down your company because your source can no longer supply you. It is hardly legalese, but because recently many individuals have been interpreting information on the Green Pastures website wrongly, they do seem to have chosen their wording carefully.

There is nothing wrong with using different sources of fish, or different cod fish. However, it would be wrong to use fish which do not meet the standards they say they use. I.e, it would be wrong to use farmed fish if they say they only use wild fish.

The wording and reason for the choice of words is open to speculation and interpretation of course, but it does not show that Green Pastures are using inferior fish. All we can take from these phrases is that they may use different sources for their fish, which isn’t doing anything wrong.

Trans-fat content

The trans-fat that Dr. Kaayla found in a sample of fermented cod liver oil raised a lot of concern, particularity the speculation that it was from vegetable oil. Speculation like this serves to achieve nothing but scaremongering, which is exactly what it achieved. Equally, the trans-fats could be a result of bacterial hydrogenation from the fermentation process. Indeed, trans-fats can be produced by bacteria fermentation in anaerobic conditions2. Bacterial hydrogenation is actually a more plausible possibility than the addition of vegetable oils when you consider the nature of the product.

In addition to this, we know that trans-fats are found throughout nature in cheese, milk and meat – so it doesn’t automatically indicate artificial tampering with the product. The much praised conjugated linoleic acid is a trans-fat, and is higher in the nutritionally superior grass-fed beef than conventional farmed beef. This shows not all trans-fats are a results of hydrogenated vegetable oils – some can be produced naturally and can even be healthy.

To accuse Green Pastures of tampering with their product based on one lab result is a serious accusation, and doesn’t take into account any other causes or variables. Yes, it raises questions, but perhaps not as many as you initially would think when you give it some thought. Before judgement on this is made, I think it only fair to hear both sides of the story.

Trans-fats doesn’t mean vegetable oil.


After Green Pastures announcement that their oil will be from Pacific cod, there was concern that the product would be radioactive as a result of the Fukushima nuclear disaster. This concern has been nicely cleared up by Randy Hartnell, owner of the seafood production company Vital Choice, who has tested seafood from the Pacific for radiation several times (view them here). These results have found no concerning amount of radiation. Randy Hartnell has spoken out against Green Pastures on Dr. Kaayla’s blog and has no reason to support their product (other than the fact they are sourced in similar waters). I believe that this is sufficient evidence to suggest that FCLO has no risk of causing radiation poisoning.

Dr. Rons heart failure

Dr. Ron has blamed his heart failure on fermented cod liver oil. He summarises his experience in his post ‘Too much of NOT so good thing‘, but if you read it, you will find that the cause is not actually the fault of fermented cod liver oil. Dr. Ron was taking excessive amounts of cod liver oil for 25 years, followed by excessive amounts of FCLO for 6 years. As Dr. Rons heart condition worsened he found that excessive amounts of cod liver oil can cause heart abnormalities. This lead him to stop taking any cod liver oil and recover.

The cause for his heart failure would have been any cod liver oil, even by his own admission, and it was just by chance that he was taking FCLO at the time. Yet Dr. Ron supports claims that Dr. Kaayla makes about FCLO being rancid, and blames this for his heart failure without any plausible evidence.

This is an illogical and unfounded conclusion to make, and has resulted in unfair accusations to be made.

Any cod liver oil would have caused Dr. Rons heart failure

On a Personal note, it seems extremely odd for a Doctor to be so naive as to take so much cod liver oil for such a long period of time and think it to be healthy. The devil of everything you eat is in the dosage, and too much of anything, even water, will cause health problems.


Rancidity is a big issue when it comes to fermented cod liver oil. Green Pastures have recently had their products tested as Midwest Laboratories for many rancidity biomarkers, and they have come back negative. Dr. Kaayla’s results came back negative/ inconclusive, and so there is no science showing fermented cod liver oil is rancid. This means that accusations of such are not founded by evidence, but rather opinion.

Marine Stewardship Council

Green Pastures has been accused by a number of people for wrongly claiming that they are accredited by the Marine Stewardship Council (MSC). Green Pastures have since removed their page which mentioned the Marine Stewardship Council, but you can still read it here. The only mention of the Marine Stewardship Council is “Green pastures works exclusively with companies that are certified members of the Marine Stewardship Council”. At no time do they claim that they are certified by Marine Stewardship Council, they only say that they work with companies that are certified by the MSC. This is a typical example of twisting information.


There really isn’t enough evidence to accuse Green Pastures of fraud. Yes, there are some questions which still need answering, namely the presence of trans-fats, but there is nothing to suggest that they are from vegetable oils.


1. FDA. (2005). Dietary Supplement Labeling Guide: Chapter V. Ingredient Labeling. Available:

2. Unknown author. (-). MONOENOIC FATTY ACIDS. Available:

The Other Side of the FCLO Scandal


December 4, 2015

From the very start I had never wanted to get involved with the politics revolving around the FCLO scandal. Politics are synonymous with ulterior motives, lies, and half-truths – none of which I have much time for.  However, as the dust settles on the scandal, and more science is coming to light you do have to look at the politics to fully understand what has gone on, and why Green Pastures were attacked with such ferocity with so little evidence.

It is hard to know where to start with the scandal, but for me, it starts somewhere is mid 2013, which was when I first came across a product called Extra Virgin Cod Liver oil (EVCLO). At the time, I thought the EVCLO website was another site owned by Rosita (which is the company that make EVCLO) but it is actually owned by the owners of Corganic/ Organic 3 (a health site specialising in supplements for sufferers of gut and psychology syndrome and similar disorders). I spoke with the guys at EVCLO back in 2013 as I was interested in selling their product here in the UK, but it was early days, communication and organisation were poor, and we didn’t get very far. I kept a close eye on them though, and regularly visited their site hoping someday, when EVCLO was a bit more established, we would be able to sell their product.

Rosita make EVCLO, but I now know it was the brain child of the guys over at Corganics, and the site is run by Corganics. Nothing wrong with this at all of course, but when you know the connection between EVCLO and Corganics it casts another shadow on some of the events which went on since I discovered them.

A bit of background

The owners of Corganics are heavily involved with the Weston A price foundation (WAPF). In fact, Dan Corrigan (co owner of Corganic helped run the first WAPF chapter in 2001) so it is quite safe to say that a large proportion of their customers were from the WAPF community. The WAPF strongly recommend a brand of cod liver oil called Green Pastures Fermented Cod Liver Oil (FCLO), and it is on their recommendation of this brand that Green Pastures have been very successful globally.

For a short time, Corganics sold this brand of cod liver oil, but many of their customers complained about it because it upset their sensitive digestive systems, and so after 8 months Corganics stopped selling it and started looking for alternatives. This led Archie Welch (co-owner of Corganics) to discover Rosita in 2012, which at the time was a producer of Ratfish oil in Norway.

Archie discussed the possibility of Rosita producing a cod liver oil using their extraction methods, and they began developing the product called he calls Extra Virgin Cod Liver Oil (EVCLO). It was during the development stages of the product that I first came across the EVCLO website.

Obviously, nothing wrong with all of this – one company is helping the other create a great product and launch it in the US market. Companies do this all the time. However, consider this through out the rest of the article: the main target audience of this product in the US is the WAPF members, most of which will be taking Fermented Cod Liver Oil.

Slander campaign

During the final stages of the EVCLO production (which took 2 years), I noticed a considerable amount of Green Pastures slandering online. At the time, I hadn’t realised there was a connection between Corganics, EVCLO and the WAPF (I have nothing to do with WAPF) at the time, I didn’t think much of it, but looking back now, I’m not so sure. Here are some highlights, but this is by no means the full extent:

    • Jan 2013 sees the following blog post published by Sarah Smith (a co-leader of a WAPF chapter), saying how she is switching from FCLO to EVCLO after collaborating with Archie Welch (co-owner of Corganics) on a project (
    • In 2013 EVLO publish the following article about cod liver oil, which says fermented cod liver oil is less nutritious than fresh oil. (
    • in 2014 shortly after the launch of EVCLO, we see a very negative campaign launched against FCLO through social media. Much of this has been deleted, but the remnants of fake Facebook profiles promoting EVCLO still remain. The EVCLO site clearly makes attacks against fermented cod liver oil, and Dan Corrigan instigates open attacks against FCLO, sayings its production methods are a fallacy because oil cannot fermented (not that anyone claimed the oil fermented, it is the liver that ferments). This makes a lot of WAPF members doubt the authenticity of fermented cod liver oil, and look for an alternative, and you can read about all of this more here:
    • Sept 2014 – we see the owner of Rosita publish a video suggesting that Green Pastures purchase their oil from China (or at least Alibaba, which is a Chinese wholesale site).

This kind of activity is unethical to say the least. The owner of Corganics and Rosita have gone out of their way to spread lies about how their direct competition source and process their product. It puts EVCLO in a bad light and paints the picture of an untrustworthy company who are quite happy to lie. And for what? Money? Well, I don’t think you lie like this just to improve peoples health. The motives are speculation on my part, but I don’t doubt that 2 years of experimenting with cod livers costs money, which needs to be recouped. In a recent interview Archie Welch says that at some point he had Rosita on the phone saying  “we’ve got these fishermen out there, and if we don’t keep them busy we will lose them” and “I don’t know if we can keep doing production on this”. To me, this sounds like someone who wants more sales for financial reasons, not for the spreading of health. Perhaps sales of EVCLO didn’t go the way Corganics has expected (not surprising considering the WAPF rated FCLO better than EVCLO), and so tried to take measures to improve their sales, or, perhaps a slander campaign against FCLO was the plan all along.

Now I’m not saying that a company needing to make money makes them evil, but they way they decide to go about it can.

The WAPF warned Corganics about slandering FCLO, at which point EVCLO/ Corganics apologise for their actions and remove what they can of their campaign against FCLO (although there are still comments on the EVCLO blog which mention their unethical marketing). However, the members of WAPF still didn’t seem to take to EVCLO, possibly because WAPF said that FCLO was better than EVCLO, but I think that their obvious slander campaign didn’t do them any favours either.

Since the removal of the slander campaign, discussions about EVCLO and their online activity seemed to die down. Blog posts on the EVCLO site (which previously had been regular) stopped in November 2014 and the general feel that I got was that FCLO was still the favourite cod liver oil in the global health community, and EVCLO was known about, but not used by the masses.

It was around this time (the serendipitous timing hasn’t gone unnoticed) that Dr.Kaayla was expressing her concerns to the WAPF that FCLO was rancid, and in February 2015 the WAPF did test the FCLO at MidWest Laboratories for several rancidity bio-markers (of which none were found). In the same month, Dr. Kaayla decided to do her own research and sent her own samples of FCLO to labs for testing.

On the 20th August 2015, Dan Corrigan published an article saying how Weston A.Price would love EVCLO, and the following day, Dr. Kaayla published her report on the authenticity of FCLO based on her own interpretation of her findings (the timing of which I find coincidental). Kaayla’s report resulted in an explosion in the WAPF community (I can only assume because people mindlessly only read her conclusions, and not her methods/findings, because her findings don’t match her conclusions), with many people turning on Green Pastures.

Regardless of the lack of scientific validity of the study, a rift was made in the WAPF community, and in almost all articles and discussions about it, you will find someone recommending EVCLO as an alternative to Green Pastures FCLO, or rather, rancid Pollock oil, which is what Kaayla and others took to naming FCLO.

Kaayla, who was vice president of WAPF quickly co-founded another organisation (Primal Paleo & Price Foundation, or PPPF) after she was kicked out of the WAPF, and a sponsor of this new foundation is Corganics.

Funnily enough, despite there being so much evidence to show that FCLO doesn’t contain anything toxic, people refuse to accept they are wrong about FCLO and still claim that it is toxic despite not knowing anything about lipid chemistry. I’ve had people email say that are worried that ‘the vitamins have gone rancid after only a few weeks’, which makes no sense!

I’ve asked Ann Marie Michaels (who has taken a very active role against Green Pastures) a number of times to let me know what exactly in FCLO is so toxic, and, after much dancing around the subject, she tells me that it’s the free fatty acids, because they prove the oil is rancid, and so toxic (despite free fatty acids not being toxic).

Anyway, I’ve vented enough on Kaayla’s report all ready. Suffice to say, it is a clear and unfounded attack against Green Pastures and the WAPF.

The Kaayla/ Corganic connection

There is a clear motive for Corganic to slander Green Pastures and the WAPF. Corganic’s EVCLO will only ever be second best in the eyes of the WAPF, and so their EVCLO would never reach the level they wanted, but what about Kaayla? How is she connected to EVCLO/ Corganics?

There is no doubt that Kaayla and the owners of Corganics know each other, and have for many years. I’ve also read that Kaayla was unhappy with the way Sally Fallon (President of the WAPF) was doing things with the WAPF, so perhaps Kaayla saw this as a way to cripple the WAPF and start her own foundation (which has actually happened). This, considering the unethical actions of Kaayla and Corganic we have seen, wouldn’t surprise me.

I can’t prove this of course, but I do think that there has been some collaboration between Dr. Kaayla and Corganics in the systematic attack on the WAPF/ Green Pastures, and seeing as they have both benefited from the resulting chaos, I think it would be quite likely.

The darker shadow

EVCLO has demonstrated its unethical marketing, but tests by the Norwegian Food Safety Authority have shown that oils produced by Rosita contain pollutants above the safe limit. I spoke to Rosita about this, and they say that they were tricked by the Norwegian authorities into providing a contaminated sample. Usually, I would be more than happy to give Rosita the benefit of the doubt, but considering the barefaced lying that their company has done already, I’m not so sure. It’s your judgement to make.

So, not only are EVCLO acting unethically, but their product might also be poisonous.


So, to summarise the events:

Corganics invested heavily into the development of EVCLO, upon release of this product, the WAPF rated it below FCLO, and so sales were poor. Either in reaction to this, or as part of their marketing plan, Corganics/ EVCLO and Rosita launched a malicious campaign against Green Pastures, which included accusing them of purchasing ingredients from China, lying about their producing methods, and saying that FCLO is lower in vitamins than EVCLO. This campaign got EVCLO noticed, but the lies and rumours they were spreading were unfounded and obviously malicious, so peoples opinion of the company fell. After a warning from the WAPF about EVCLO’s behaviour, they apologies for their actions, and removed much of their campaign.

The slander campaign seemed to end in late 2014, which is when I suspect Corganics started conferring with Dr. Kaayla, because shortly after the end of the slander campaign Dr. Kaayla voices her concern about FCLO being rancid. The WAPF sent out samples of FCLO to Midwest Labs and Leicester School of Pharmacy which shows that FCLO had no lipid peroxide species and is safe. Despite the evidence showing that FCLO is not toxic, Dr.Kaayla decides to do her own research (you need to ask yourself why), and publishes a damning report against FCLO. Dr. Kaaylas research is riddled with flaws but this seems to mean very little considering her position of trust in the WAPF (vice president). People read her conclusions and chaos ensues, resulting in the WAPF and Green Pastures being accused of fraud, lying and worse.

As a result of the chaos Dr. Kaayla establishes her own foundation (FFNW), people are encouraged to get rid of their FCLO and take EVCLO, and according to Archie Welch sales of EVCLO are starting to increase.

Rosita EVCLO vs Green Pastures Cod Liver Oil


This is a comparison of the quality of product produced. Rosita has been a part of some rather unethical attacks against Green Pastures, which may also influence your buying decision, and you can read about it here.

For a long time Green Pastures fermented cod liver oil has been the gold standard of cod liver oil products, and with good reason. It has minimal processing, naturally occurring vitamins, and even additional nutrients such as co-enzyme Q-10 produced from the fermentation process. However, recently a new product has come to the market, which I have been following closely during its development. This product is created by Rosita Real Foods and is called Extra Virgin Cod Liver oil (EVCLO), and on the surface looks to be comparable (or even better) than Green Pastures cod liver oil

Nutritional comparison

As EVCLO servings are represented in teaspoons, I’ve converted all nutrient values to mg/g, with 1 teaspoon weighing 4.3g of cod liver oil.

Nutrient Green Pastures Cod Liver oil Rosita Real Foods EVCLO
Vitamin E 0mg 0.86-2.3 mg (Added to the oil)
Vitamin A 345-2380iu 698-1123iu
Vitamin D3 310-1030mg 93-116mg
EPA 120-157mg 119mg
DHA 58-84mg 163mg
Quinone 5.65 – 17.06mg 0

The key differences are:

  • Green Pastures vitamin A has a greater variance than EVCLO.
  • Green Pastures has consistently more vitamin D than EVCLO. Much more.
  • EPA content is similar in both, but Green Pastures is slightly higher.
  • DHA content of EVCLO is higher than Green Pastures.
  • EVCLO does contain vitamin E, but this is added to the oil, and is in very small amounts.

So nutritionally, the products are comparable but Green Pastures has the nutritional edge because it contains quinones, and the vitamin D is much higher than EVCLO. The advantage EVCLO has is higher DHA and a more consistent vitamin A profile. Still, its pretty close.

Toxic chemicals

When it comes to fish oils, contaminants are a big concern (after all, these are meant to be health supplements, not toxic oils). Fortunately both companies have their products tested for toxic chemicals, and neither have any significant levels of anything harmful. So you have nothing to worry about with either these products. Despite this testing the Norwegian Food Safety Authority has tested Rosita’s products for toxins, and found they are higher than the safe limit, which does raise some questions about their filtration process.


Both products are processed very differently, which is something Rosita is very keen to stress.

Green Pastures ferments the liver of cods, which releases oils which can then be filtered off. This processes uses no heat or chemicals, meaning the fatty acids are not damaged, and the fermentation process creates some useful additional nutrients. With this extraction method there is concern that it can produce some amines, which are toxic. Whilst it is true that amino acids will produce amines when fermented, Green Pastures cod liver oil is tested for amine content, and is free of any biologically significant amount of amines.

Rosita is less clear on how they process their oil. Their website is consistently vague, and states that the oil is extracted using a very rare ancient extraction technique”. Not being satisfied with this I emailed Rosita asking for more information about their processing. Their response was refreshingly quick, but not very helpful:

 Our oils are NON-Processed, that is why you may find our ways of having the oils out of the fish livers so “vague” – simply said there is no processing at all.

It was frustrating to not be given a clear answer, but after quite a bit of digging I found one – once the cod are caught, the livers removed and exposed to ‘winter conditions’. The cold causes the oil to seep out of the livers, which is then gravity filtered and bottled. This method also uses no chemicals or heath to extract the oil.


The is the only area where EVCLO clearly trumps fermented cod liver oil. Even Green Pastures has said that “t


These prices are based on the RRP from the sellers websites. Depending on where you live, you may not necessarily be able to get it for the same price.

Green Pasutres Fermented cod liver oil costs £0.34 per serving in capsule form, or £0.54 per teaspoon. Rosita EVCLO on the other hand is £0.73 per teaspoon. This makes Green Pastures quite a bit cheaper.

David vs Goliath

Unsurprisingly, Rosita feels like its in the shadow of Green Pastures, and Green Pastures for the first time feels a little threatened by a comparable product. This has lead to the two companies ‘bad mouthing’ each other. I first saw this from Rosita who made some blogs/ Youtube videos questioning the authenticity of Green Pastures. This actually put many people off Rosita (myself included) but this media has since been removed.

Needless to say though, you should take what each company has to say about each other with a pinch of salt, there is clearly reason for bias from either side.


Final Thoughts

There is quite a bit to consider when picking between the 2 brands, but as far as quality and price goes, I’d pick Green Pastures. This isn’t to say EVCLO is bad, quite the opposite. EVCLO is still a very natural and nutritional product, it’s just produced in a different way. There is certainly nothing wrong with either, so if you can afford EVCLO over Green Pastures, it might be worth trying them both and seeing which you prefer. It might be that the superior taste of EVCLO will sway you.

Leave a Reply

Your email address will not be published. Required fields are marked *