Organic Labeling of Multi-Ingredient Food Products

Prepared by Kimberly A. Baker, PhD, RD, LD, State Consumer Food Safety Program Coordinator, Clemson Extension, Clemson University and reviewed by Adair Hoover, Food Safety Extension Agent, Clemson Extension, Clemson University, 07/17.

HGIC 4085

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The labeling of organic foods or agricultural products is regulated by the National Organic Program (NOP), which is a division of the USDA’s Agricultural Marketing Service (AMS). The NOP ensures that all products that are marketed as organic meet the same set of standards set by the USDA and the National Organic Standards Board.

What is Organic?

Organic is a term used to label foods and other agricultural products that are produced in compliance with USDA organic regulations. This includes producing these products using cultural, biological and mechanical methods that promote the re-use of resources on the farm, enhance environmental benefits, promote the conservation of the surrounding land and wildlife and restricts the use of synthetic fertilizers, sewage sludge, irradiation, and genetic engineering. All products that meet these standards must be certified by a USDA-accredited certifying agency to ensure that the national organic standards are met. This factsheet will focus on the regulations for labeling multi-ingredient food products as organic.

General Organic Labeling Standards: All food products that contain an organic claim should be certified. If a producer is not certified, then an organic claim cannot be made on the principal display panel of the product’s packaging and the USDA organic seal cannot be used. The non-certified producer is allowed to identify any certified organic ingredients on the information panel either within the ingredient list or by listing the percentage of organic ingredients. Any product containing a USDA organic claim and/or seal must have their product’s label reviewed and approved by the certifying agency to ensure compliance. More information on this can be found at www.ams.usda.gov/NOPOrganicLabeling.

100 Percent Organic Labeling: The following conditions must be met for any product to be labeled as 100 percent organic:

  • All ingredients in the product must be certified organic
  • All processing aids must be organic
  • The certifying agency must be listed on the information panel of the product label

These products can include the USDA organic seal and/or can state the 100% organic claim on the principal display panel of the product’s packaging. Additionally, the information panel must identify the ingredients as organic either by wording (e.g. organic spinach) or with the use of an asterisk or other identifying symbol.

USDA Certified Organic Seal Image courtesy of the USDA-AMS

USDA Certified Organic Seal Image courtesy of the USDA-AMS

Organic Labeling: The following criteria must be met for any product to be labeled as organic:

  • Product must contain a minimum of 95% organic ingredients (not including salt and water).
  • Any non-organic ingredients that are permissible by the National List can be used in the product as long as these ingredients do not make up more than a combined total of 5% non-organic ingredients. Salt and water are not included in this percentage as they are classified as natural.
  • The certifying agency must be listed on the information panel of the product label.

These products can include the USDA organic seal and/or can state the organic claim on the principal display panel of the product’s packaging. Additionally, the information panel must identify the ingredients as organic either by wording (e.g. organic spinach), or with the use of an asterisk or other identifying symbol.

Made with Organic _____ Labeling: The following criteria must be met for any product to be labeled as made with organic _____:

  • A minimum of 70% of the product must be made with certified organic ingredients with the exception of salt and water.
  • Any remaining agricultural products that are not required to be organically produced must be produced without the excluded methods such as genetic engineering, ionizing radiation, or sewage sludge.
  • Non-agricultural products used to make the product must be allowed on the National List
  • The certifying agency must be listed on the information panel of the product label

The principal display panel cannot include the USDA organic seal, characterize the product as organic or identify the product as “made with organic ingredients”. The principal display panel can state: “made with organic _____(list up to 3 ingredients or ingredient categories here).” The information panel must identify any organic ingredients as organic either by wording (e.g. organic spinach), or with the use of an asterisk or other identifying symbol.

Specific Organic Ingredient Labeling: Products that contain less than 70% certified organic ingredients (not including salt and water) do not need to be certified organic. The product’s principal display panel cannot include the USDA organic seal or have the word “organic” on it. The information panel can list only certified organic ingredients as organic within the ingredient list and/or state the percentage of organic ingredients. Any non-certified ingredients within the product do not need to meet the USDA organic regulations.

Organic Exemptions and Exclusions

Those who sell less than $5,000 worth of organic products each year are exempt from organic certification. However, they are required to:

  • Comply with the organic production and handling requirements of the regulations.
  • Keep appropriate records as stated by the organic regulations.
  • Products from non-certified producers cannot be used as or identified as an organic ingredient by another certified organic producer.
  • Products cannot display the USDA certified organic seal.

More Information

Clemson University is a USDA accredited certifying agency. For more information about their program and services you can visit their website at: https://www.clemson.edu/public/regulatory/organic/

The National List of Allowed and Prohibited Substances can be downloaded from the following website: https://www.ams.usda.gov/rules-regulations/organic/national-list. 

Sources:

  1. United States Department of Agriculture (USDA). 2016. Labeling Organic Products. Washington, DC: United States Department of Agriculture. Available from: https://www.ams.usda.gov/sites/default/files/media/LabelingOrganicProducts.pdf. Accessed April 11, 2017.
  2. United States Department of Agriculture (USDA). 2016. The National Organic Program. Washington, DC: United States Department of Agriculture. Available from: https://www.ams.usda.gov/publications/content/about-national-organic-program. Accessed April 11, 2017.
  3. United States Department of Agriculture (USDA). 2016. Organic Production and Handling Standards. Washington, DC: United States Department of Agriculture. Available from: https://www.ams.usda.gov/publications/content/organic-production-handling-standards. Accessed April 11, 2017.
  4. United States Department of Agriculture (USDA). 2017. Organic Labeling Standards. Washington, DC: United States Department of Agriculture. Available from: https://www.ams.usda.gov/grades-standards/organic-labeling-standards. Accessed April 11, 2017.
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