Here at RL Food Testing Laboratory, we often get questions from our customers about organic food labels. In a recent blog article New Guidelines for Organic Food Labels, we review the new rules set forth by the National Organic Program (NOP). Below are some general questions about organic food labeling that you may find helpful to understand what is organic, when can you use the organic seal, and how do you get your product certified organic.
What is organic?
Organic refers not only to the food itself, but also how it is handled and produced. Organic food production is based on a system of farming that copycats a natural ecosystem and maintains and refills the fertility and nutrients of the soil. These methods mix cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and preserve biodiversity. Organic foods are produced without genetically modified organism (GMO) and radiation.
What is an organic seal?
The USDA Organic Seal is a seal, or label, that is affixed to certified USDA organic products. Two levels of certified products are allowed to have the USDA Organic Seal:
100% USDA certified organic products that are made with 100% organic ingredients
Organic products that are made with at least 95% organic ingredients
What are the requirements for a 100% organic label?
In order for a product to be labeled as 100% organic the following requirements must be met:
The product contains 100% USDA certified organic ingredients
Zero non-organic ingredients are allowed in the product
Any processing aids used must be organic
A 100% organic certified product is allowed to have the USDA Organic Seal
What are the requirements for an organic label?
In order for a product to be labeled organic, the product must have the following characteristic:
The product must contain at least 95% organic ingredients
Remaining 5% of the ingredients can be non-organic
All agricultural ingredients in the product must be organic unless not available
An "Organic" product is allowed to wear the USDA Organic Seal (Organic Apple Juice)
What are the requirements for products that are labeled "Made with Organic Ingredients?
Products that are processed and contain at least 70% organic ingredients can use the phrase "made with organic ingredients". The manufacturer will have to list up to three of the organic ingredients or food groups on the main display panel. Furthermore, foods that contain at least 70% organic ingredients will not be able to place the USDA seal on their product.
Is an Organic Label mandatory on an organic product?
Labeling is optional. But, labeling is encouraged because these labels help consumers to identify products quickly. It will help consumers understand the type of organic product they are purchasing.
Once the USDA labels a product as "organic" will the item still be subject to the laws and regulations that are enforced by the FDA? Yes, foods that are labeled as organic must follow with both the USDA guidelines for the organic claim as well as with the FDA regulations for labeling.
If a product claims organic, does it also need to be certified?
Yes, any final product claiming organic ingredients needs to be certified.
Where can I get my product certified as organic?
The National Organic Program oversees USDA endorsed certifying agents and their organic production and handling operations. Producers can view a current list which shows all certified, cancelled and suspended operations as they have been reported to the NOP on January 2, 2014. Only the specialized operations can label, sell or represent their product as organic.
Can I download the USDA Organic Seal?
Yes, the seal for 100% organic certified products can be downloaded here. The user has the option of four color seals or black and white seals.
On May 2, 2014, the National Organic Program (NOP) issued new guidelines for organic food labels. These new guidelines were the result of the organic trade and certifiers request for the NOP to clarify the requirements for “Made with Organic” labeling category.
The new guidelines for organic food labeling clarifies the following five aspects of products that are labeled “Made with Organic:” 1. Composition 2. Compliant organic labeling claims 3. Organic and non-organic forms of the same ingredient 4. Percentage of organic ingredients statements 5. Ingredients or food groups in the “made with organic” claim
In order to label the product “made with organic” it must contain at least 70% organic ingredients, excluding salt and water. It cannot contain any ingredients that were made using excluded methods such as ionizing radiation, genetic engineering or sewage sludge.
The USDA defines excluded methods as various "Methods used to genetically modify organisms or influence their growth and development by means that are not possible under natural conditions or processes”. If these conditions are met then the product can be labeled “made with organic.”
Compliant organic labeling claims
If it meets the above percentage requirements then the label can say “made with organic.” Up to three ingredients, combination of ingredients or food groups may be inserted after. You cannot say “85% organic”. It must be an ingredient specific claim such as “made with organic sugar”. Also specific ingredients cannot have a percent organic statement like “100% organic flour”.
All labeling “made with organic” cannot stand out among the rest of the labeling. It must be the same format as the rest of the label. No highlighting and the text must not be more than half the size of the largest text.
Organic and non-organic forms of the same ingredient
A product that is made with both organic and non-organic forms of an ingredient must be labeled as such. If the ingredient label statement is “made with organic sugar and corn” then both ingredients must be organic. You could also say “made with organic sugar and organic corn.”
Ingredients or food groups in the “made with organic” claim
The “made with organic” label may include a combined total of three ingredients, food groups or a combination of both.
If a statement is made in regards to an ingredient on the label “Made with organic apples” then all forms of an apple must be organic. Anything derived from apples must be organic as well such as apple juice.
If a product is stating “Made with organic milk” then all milk-based products, such as yogurt, cheese, or whey powder must be certified organic.
Only certain items can be listed as food groups – beans, fish, fruits, grains, herbs, meats, nuts, oils, poultry, seeds, spices, sweeteners, vegetables or processed milk products.
The final guidance documents are available from the COP through the Program Handbook: Guidance and Instructions for Accredited Certifying Agents and Certified Operations.
Helpful examples of these new guidelines for organic food labels can be viewed here.