To sell a product as organic, you must use organic ingredients, process in a certified organic processing/handling facility and comply with organic labeling requirements. Verify your label is compliant with NOP regulations with your certification agent BEFORE printing many copies, since there are very specific rules such as where the certification agent name must be printed, the size of the type used and the color scheme of the USDA seal.
Q. How do I know if I am “processing” or “handling” a product and must comply with the Organic Rule?
“Processing” is defined as: cooking, baking, curing, heating, drying, mixing, grinding, churning, separating, distilling, extracting, slaughtering, cutting, fermenting, eviscerating, preserving, dehydrating, freezing, chilling or otherwise manufacturing, packaging, canning, jarring or otherwise enclosing food in a container. If you conduct any of the above processing activities, you are considered a handler under the NOP.
Post harvest handling, such as washing produce or cleaning grain before going into a bulk bin is not considered “handling.”
Many farmers will do some of these things in the production of their crops or livestock, such as through harvesting or cleaning feed. These processes must be certified along with fields and animals in order to produce a certified organic product. Individuals that operate plants or facilities that take a product and further process or handle it after delivery from a farmer must also be certified in order for the final product to be considered certified organic.
Q. Does my processing facility need to be certified for organic production?
Yes. Each facility where organic product is processed or handled, from tortilla chips to butchered chickens or hogs, must be certified for organic production, with the exceptions as stated below. Each facility will need to apply for certification, develop an organic handling plan, fill out a processor or handler application, have the inspection, pay fees and keep comprehensive records.
All the buildings where ingredients are stored, all equipment used, product packaging and any storage for the final product must be inspected.
All cleaning products used must be on the National List, or have any residues removed (such as a clear water rinse) before organic production or separated from organic production so there is no threat of contaminating the organic product.
The processor must have a pest management plan that focuses on prevention of pest problems by removal of habitat, food sources and breeding areas; prevents access to facility by pests; and manages environmental factors (light, temperature, humidity, atmosphere and/or air circulation) to prevent pest reproduction. The plan may also use mechanical or physical controls including traps, light or sound, and lures and repellents using approved substances. Only if these management practices are not effective can pest control products on the National List may be used. If National List approved substances are not effective, then conventional pest control substances may be used with the approval of the certifying agency. Measures must be taken to protect against pest control substance contact with organic products and packaging materials. These various stages of pest control must be documented as being performed in this sequence in order to meet the NOP regulations.
Your facility does not have to be 100% organic. You may also process conventional products as long as organic products are protected from commingling with non-organic products and contamination from prohibited substances. Equipment must be cleaned and/or purged with organic product to prevent commingling and contamination. Records must show that organic integrity is maintained throughout the process at the facility.
All certified processing or handling facilities must follow NOS record keeping requirements. Records that need to be kept include: proof of certification for organic ingredients, verification that any non-organic ingredients also meet organic requirements, inventory, storage and sales records and pest control records. Records must track all ingredients and finished products in their flow through the facility, and must be able to show that contamination and commingling were avoided in all processing/handling steps.
As with on-farm production, there is a small processor exemption of $5,000 annual sales of organic product. A small processor may label their product as organic as long as they follow the NOS, including all record keeping.
A handler that receives containers of certified organic product and only transfers or stores that product without removing, altering or further processing the contents does not have to be inspected in order to sell that product as certified organic.
Q. What are the rules for identifying my organically processed product?
The percent of the total that is organic ingredients in a product will determine exactly what your label can say. All organic ingredients must be identified as “organic” in the ingredient list for all labeling categories.
100% Organic: The final product contains only 100% agricultural products and these are 100% certified organic. If processing aids are used, they must also be agricultural and certified organic. If a synthetic processing aid allowed in organic production is used, then the product cannot be labeled as 100% organic. An example would be the use of an agricultural fiber (rice hulls) as a filtration aid. You may use the USDA Organic and/or the certifier’s seal.
Organic: The final product contains at least 95% (by weight or fluid volume) organic ingredients (excluding water and salt). Agriculturally produced ingredients must be organic unless present on §205.606 as not being commercially available as organic, as well as proof of a current search verifying it is still not available organically. No ingredients may be irradiated, genetically engineered or grown using sewage sludge. All remaining ingredients and natural or synthetic processing aids must be on the allowed National List. You may use the “USDA Organic” or certifier’s seal.
Made with organic ingredients: The final product contains at least 70% organic ingredients by weight or fluid volume (excluding water and salt). Conventional agricultural products may be used in the remaining 30%, but they cannot be irradiated, genetically engineered or grown using sewage sludge. All non-agricultural ingredients and processing aids must follow the National List. You can list up to three organic ingredients or three food groups on the front panel. You may use the certifier’s seal, but not the “USDA Organic” seal.
List of ingredients with organic products identified: If your product contains less than 70% organic product (by weight or fluid volume) then you may not make an organic claim on the principal display panel, but may identify items on the ingredients list as organic. You may list the percent of organic ingredients used on the information panel. For example, a cereal ingredient list can state: Ingredients: corn, organic oats, wheat.. etc. In this case there are no restrictions on any non-organic ingredients. If your final products are in this category, they do not have to be processed in a certified organic processing plant. You may not use the “USDA Organic” or certifier’s seal.
Livestock feed: Feed labeled as “organic” must contain agricultural products that are 100% certified organic. However, it may also include any percentage of feed additives and supplements consistent with the National List. Non-organic agricultural products are not allowed in the feed or in feed supplements.
Bulk non-retail sales: All bulk sales of organic processed products or organic single commodities must have a unique lot number on all transfer documents, identifying that specific shipment and tracking it back to production or storage.
Q. Are there regulations for the look of a label or the info listed on it?
Yes. Labels are closely regulated, particularly the types of organic claims that can be made based on finished product content and certifier and handler identification information. You may get details from your certification agency or check NOS §205.303-311. Labels must also state the phrase “Certified organic by (your certifying agency)” and must identify the processor or distributor of the finished product. Use of a certifying agent seal or logo is optional. The USDA Organic Seal can be used on the labels of products in the “100% organic,” “organic,” and “livestock feed” categories, but there are restrictions on its size and color. All retail labels should also comply with all State and Federal regulations for that type of product.
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