Organic Labeling Requirements: Rules for Food Manufacturers Using Organic Ingredients

With more and more Americans opting for organic food, certifying your product with the USDA could positively impact your sales. Image courtesy Flickr user U.S. Department of Agriculture.

It’s no secret that Americans are becoming increasingly health-conscious. And while in the past this has meant fad dieting and low-fat foods, the emerging narrative around healthy eating is one of wholesome, high-quality food that is good for the environment as well your body.

Although organic food and farming practices have been around since the 1940s, they are now gaining mainstream appeal. In fact, the Organic Trade Association reported a revenue of $47 billion from organic foods in 2016, a significant 8.4% increase in organic food sales in the past year. Furthermore, over 82% of American households report buying organic food. With such a high demand, more and more food manufacturers are deciding to sell organic products.

If you are a food manufacturer who wants to use organic ingredients in a product or the USDA organic seal, it’s important that you know the organic labeling requirements set out by the USDA so you can label your product properly.  

Key Organic Labeling Requirements

In order to use the USDA organic seal, your food product and its ingredients must be certified under the USDA National Organic Program. Under this program, there are four main categories that your product can fall under when it comes to labeling: 100 percent organic, organic, made with organic ingredients, and specific organic ingredients. Let’s look at what each of these terms means so you can choose the right one for your product.

Image courtesy Flickr user Paul Swansen.

100 Percent Organic: If your product and all its ingredients are certified organic (with the name of the certifying agent on the information panel of your product) and use organic processing aids, then it may fall into this category. Your ingredient list must state that each ingredient is organic, either by using the word “organic” before the ingredient name (ie. organic cauliflower) or by using an asterisk that denotes organic ingredients. If these requirements are met, you are permitted to use the “100% organic” claim and the USDA’s organic seal.

Image courtesy Flickr user nikoretro.

Organic: If your product and all of its ingredients are certified organic, except for those on the National List of Allowed and Prohibited Substances, then your product can use the organic label. Your product may only contain a total of 5% of the allowed non-organic ingredients that are specified on the National List. Again, the name of the certifying agent must appear on the information panel of your product, and you must identify organic ingredients in the same way as you would for a 100 Percent Organic product. If these requirements are met, you are permitted to use the USDA organic seal and the “organic” claim on your packaging.

Image courtesy Flickr user theimpulsivebuy.

Made with Organic Ingredients: This is the category that many manufactured food products using organic ingredients fall under. In order to use the “made with organic” claim, 70% of your ingredients must be certified organic and identified as such in your ingredient list, and you must state the certifying agent on your information panel. Non-organic ingredients have special requirements, too; they cannot be genetically modified, use ionizing radiation, or be produced with sewage sludge, and any non-agricultural ingredients must be allowed on the National List.

If these requirements are met, you are permitted to state that your product is made with specific organic ingredients. However, you are not permitted to use the phrase “made with organic ingredients” on your package. Instead, you must specifically state what ingredients or ingredient categories are organic (i.e. “made with organic dairy, wheat, and apples”). You may not use the USDA seal on your product.

Image courtesy Flickr user Michael Pereckas

Specific Organic Ingredients (Less than 70%): If your food product contains less than 70% certified organic ingredients, you don’t have to worry about too many stringent guidelines, as with the other categories. Simply mention which ingredients are certified organic in your ingredient list, and indicate what percentage of certified organic ingredients you product contains. Non-organic ingredients don’t need to comply with USDA organic regulations as they do for the “made with organic” category. If you use this category, you aren’t permitted to put the USDA seal on your product, and the term “organic” can’t appear on the main display panel.

Other Ways to Appeal to Health-Conscious Consumers

While the organic label certainly appeals to Americans concerned about their health and the environment, it isn’t easy for all food manufacturers to use the term “organic” on their product or to display the USDA organic seal. It takes time and money to ensure everything is certified and labeled properly, which can discourage manufacturers—especially those who are just starting out and have limited budgets.

Fortunately, there are other ways to appeal to the growing demographic of health-conscious consumers in America. Having your product certified as non-GMO by a qualified third party is one way to do so, as it offers a level of transparency about the quality of your ingredients and shows brand integrity, much like the organic label does.

You may also want to determine if your product meets the FDA guidelines for using “natural” on your food label. This can be an effective way to increase consumer attention without having to get certified by a third party. In fact, a recent consumer report showed “natural” foods to be very popular among Americans, with 73% of people reporting purchasing foods that use the term “natural.”

Of course, if you want to use any claims on your product, from “made with organic” to “natural,” be sure to consult with a nutrition label expert and use an FDA-approved nutritional analysis software to ensure your product is eligible to use such terms in compliance with FDA standards. Food labeling can be overwhelming and complex, and it really helps to consult with someone who is familiar with the specific laws and regulations.

Ultimately, whether you use the organic label or choose another method, showing consumers that your brand has integrity and uses quality ingredients will benefit your business by gaining customers’ trust and potentially increasing demand for your product. Americans are indeed increasingly interested in knowing more about what is in the food they buy and consume—and as a food manufacturer, you have the responsibility to inform them and the opportunity to cater to their wishes.

Complying with labeling guidelines and regulations can be tricky and time-consuming. At LabelCalc, our nutrition label expert consultants are here to help with all your label needs. If you need organic labeling requirements, contact us today.