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USDA Offers Guidance on “Made with Organic ___” Label Claims

The National Organic Program (NOP) of the U.S. Department of Agriculture’s Agricultural Marketing Service (AMS) has issued a final guidance document on “made with organic ___” labeling.  The guidance became effective on May 2, 2014.

The guidance document explains that the claim “made with organic ___” may be made if the following conditions are met:

  1. The product contains at least 70 percent organic ingredients (excluding water and salt) (see 7 C.F.R. § 205.301(c));
  1. The remaining ingredients (up to 30 percent, excluding water and salt) may be non-organic, but any non-agricultural ingredient must be allowed on the National List of Allowed and Prohibited Substances (the National List found at 7 C.F.R. § 205.605); and
  1. None of the ingredients may be produced using excluded methods, i.e., genetic engineering, ionizing radiation, or sewage sludge (see 7 § C.F.R. 205.105).

In addition, operations that grow, handle, or process “made with organic ___” products must be certified as organic by an accredited certifying agent, unless subject to an exemption or exclusion from that requirement.

The guidance document also clarifies the permissible wording of the claim, as well as accompanying label statements:

  • The claim must identify up to three organic ingredients or food groups present in the product (e.g., “made with organic vegetables, rice and beans”).  If a food group is identified, only the following food groups may be listed: beans, fish, fruits, grains, herbs, meats, nuts, oils, poultry, seeds, spices, sweeteners, vegetables and processed milk products.
  • If an ingredient or food group is identified as organic, then all raw and processed forms of ingredients from that ingredient or food group must be certified organic.  For example, if the claim states “made with organic corn,” then all corn-based ingredients (e.g., corn oil, cornstarch, corn syrup) must be organic.  (There is an exemption in the case of poultry in pet food.)
  • If the claim “made with organic [up to 3 ingredients, food groups, or combination of ingredients and food groups]” is made, the label may also declare the percentage of organic ingredients in the finished product (e.g., “75% organic,” “contains 90% certified organic ingredients”).  However, a percentage organic statement (e.g., “made with 70 percent organic ingredients,” “made with organic ingredients”) may not appear by itself; it must be accompanied by the claim “made with organic [up to 3 ingredients, food groups, or combination of ingredients and food groups].”
  • All words used in the claim and the percentage organic statement must appear in the same format (i.e., the same type size, style, and color) without highlighting, and must be no more than half the size of the largest text on that label panel.
  • The ingredients declaration must identify all certified organic ingredients as “organic.”  If the product contains both organic and non-organic forms of the same ingredient, they must be listed separately in the ingredients declaration.
  • The statement “Certified organic by [name of certifying agent]” must appear below the signature line.  The certifier’s seal or logo may also be presented.
  • The USDA organic seal may not appear on the label.

The NOP has also issued two related documents: examples of permissible and impermissible “made with organic ___” claims and responses to comments received regarding its 2011 draft guidance.

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