Product Composition – 100% Organic, Organic, and Made with Organic

The National Organic Standards specifies different labeling categories depending on the type of product and the percentage of organic ingredients in the product. One of the most important decisions in the certification process is choosing which organic labeling claim to use. The label claim depends on the percentage of organic ingredients in your product at formulation, so you may need to adjust your formulation to qualify for the category you want to use.

Product Composition

The USDA organic regulations set labeling categories for organic processed products. This article focuses on the categories available for products intended for human use (food, body care, etc.). Livestock feed products have specific requirements, which can be found in Livestock Feed Composition and Product Formulation. They are based on the percentage of the ingredients that are organic.¹ The labeling categories are:

• “100% Organic”
• “Organic” or “certified organic”
• “Made with Organic”

For each label, there are specific rules about the percentage of organic ingredients, whether – and which – nonorganic ingredients and processing aids may be used, and labeling requirements.²

If Your Product Has Less Than 70% Organic Ingredients

Products meant for human use that have less than 70% organic ingredients cannot make any organic claim on their label. For example, you cannot use the USDA seal or identify your certifier on the label. All you can do is identify each organically produced ingredient in the ingredient statement as organic.

Which Claim is Right for You? Some Considerations…

Choosing a label claim is a significant decision that reflects your company and your customers. There are many values and goals that come into play.

• What type of product are you producing?
• What ingredients are required?
• Do you have flexibility with them?
• Which is the highest label claim you can achieve given your product constraints?
• What opportunities are there for reformulation?
• Who is your customer and what are they looking for?

A top consideration is that the USDA organic seal is trusted by over 70% of consumers.⁷ This seal can only be used on products certified to the “100% Organic” or “Organic” categories.

The “100% Organic” label has the strictest requirements. If you pursue this label, your certifier may ask for additional verification of your suppliers’ organic certificates, particularly if you source any ingredients from abroad. This label can also be difficult to maintain if your product type, ingredients, or suppliers change frequently. Finally, keep in mind that the “100% Organic” claim is not recognized in all countries, which may create challenges if you plan to export your products.

The “organic” label claim is the most commonly used. Achieving this label requires valid organic certificates for all organic ingredients, but may not require any additional verification of organic ingredient percentages. This allows for more flexibility if your suppliers change frequently or you want more flexibility.

The “Made with Organic” label may be the highest labeling claim achievable for some types of products. You could have 99.9% organic ingredient content, but if you plan to use a nonorganic ingredient that is not on the National List, you cannot use the “organic” labeling category. This label can make an organic claim on the package, but it must specify which ingredients or food groups are organic, and it can identify no more than three. For example, “Made with organic sugar, raisins, and cinnamon” or “Made with organic beans, grains, and herbs.”