Example of organic food labeling.

Your Guide to Organic Food Labeling Requirements

Between 2005 and 2020, sales of organic foods went from 13.2 billion dollars per year to 56.5 billion. While this growing market is lucrative, meeting organic food labeling requirements requires considerable work at each stage of production. While most control over labeling falls under the USDA National Organic Program (NOP), there are additional certifications from organizations like NSI International and Oregon Tilth. So, what are the national organic standards, and how does that affect what you can put on your labels?

USDA Organic: The Primary Certification in America

The USDA’s organic labeling is handled by the National Organic Program (NOP), which is part of the agency’s Agricultural Marketing Service. USDA organic certification of foods must be overseen by a NOP-authorized certifying agent. They’ll identify the changes you need to make in your farming and production systems, as well as gather the paperwork you need to prove you’re following the requirements of the program. Regulations are identical for food products and personal care products.

USDA certified products are only allowed to use ingredients in The National List of Allowed and Permitted Substances, aka the “National List.” Production cannot include or be in contact with genetically modified organisms (GMOs) or sewage sludge. That means facilities that process both organically produced and non-organic products must prevent cross-contamination. Ionizing radiation is often used as an alternative to chemical treatments to kill bacteria and improve shelf life but violates organic regulations.

Regulations for wording used on the Principal Display Panel (PDP) and the Information Panel (IP) vary depending on the percentage of organic ingredients in the product. The USDA does not count salt and water as a percentage of organic content. It also doesn’t include processing aids, which the USDA defines in three ways:

  1. A substance that is added during processing and removed before the food goes into its final packaging.
  2. A substance that is added during processing then converted into ingredients within the food without significantly increasing the amount of those ingredients.
  3. A substance that is added to a food for its effect during processing, but has insignificant levels and doesn’t have a functional effect on the final product.

Four Categories Ingredient Statements for Organic Labels

USDA organic label regulations are broken down into four labeling categories based on the percentage of organic ingredients in the product. Here are the four ingredient categories:

100 Percent Organic

  • All ingredients in the product are certified organic.
  • PDP: The use of the USDA organic seal or organic claims are allowed.
  • IP: Organic ingredients must be identified in the ingredient list. This can be done by calling ingredients “organic” or using an asterisk on ingredients with a note that they are organic.


  • The product uses 95 percent organic ingredients, while the other five percent includes products not available in organic form (as specified in the National List).
  • PDP: The use of the USDA Organic seal or organic claims are allowed.
  • IP: Specific organic ingredients must be identified.

Made With an Organic Ingredient

  • At least 70 percent of the product is organic, with constraints on other ingredients specified in the Natural List.
  • PDP: Can state “made with organic” followed by a list of up to five ingredients. The USDA organic seal cannot be used. 
  • IP: Specific organic ingredients must be identified.

Organic Ingredients Used in Products With Less Than 70 Percent Organic Content

  • The product itself is not considered organic, but you are allowed to identify organic ingredients.
  • PDP: Cannot use the USDA seal, the word “organic” or state information on organic ingredients.
  • IP: Organic ingredients can be identified. Other non-organic ingredients don’t have to be on the National List.

Transitional Certification and Personal Care Products

NSF/ANSI 305 is a standard set by NSF International and the American National Standards Institute for personal care products. This organic standard requires products to contain at least 70 percent organic ingredients from a botanical source. This is a separate certification from USDA organic standards, but a product can meet both standards. USDA regulations have some control over what your 305-certified product must include on the label:

  • Personal care products that are certified with NSF/ANSI 305 are allowed to use the NSF “contains organic ingredients” mark on the PDP. The label must state the exact percentage of organic ingredients in the product.
  • The NOP requires all products with this certification to identify each organic ingredient and the certifying agent on the IP.

NSF subsidiary QAI also provides transitional certification. To get USDA organic certification, you need to show you’ve practiced organic farming and processing for three years. Transitional Certified products use organic processes, but don’t have the three-year history required for full certification. This mark can be used on approved products that have at least 51 percent transitional ingredients, but no other label claims about organic content can be made.

Oregon Tilth and California Certified Organic Farms

The USDA got into organic labeling regulation with the passing of the Organic Foods Production Act of 1990. However, it didn’t reach its current form until the Agriculture, Rural Development, Food and Drug-Related Agencies Appropriations Act was signed into law in 2015. To help consumers, there were organizations established long before current USDA certifications that companies could use to prove their products were organic. While these agencies were independent, they’ve now formed a cooperative relationship with the government and producers.

Two of the most prominent accredited certifying agents are Oregon Tilth and the California Certified Organic Farmers. Both Oregon Tilth and the CCOF are USDA certifying agents, which means you’ll have both the organization’s certification and USDA certification when you complete their programs. That’s why the steps required to certify with Oregon Tilth are similar to the USDA certification process. There are two federal requirements for labels with these third party certifications:

  1. The mark for these organizations must be less prominent than the USDA organic mark.
  2. The rest of the label must adhere to requirements for both the USDA and the certifying organization. While a USDA label may only require you to identify organic ingredients, these third-party associations often require percentages of organic ingredients to be listed.

Selecting Labeling Equipment for Your Organic Products

With prohibited substances, pesticides, fertilizers and the risk of contamination from GMOs, packaging both organic and conventional agricultural products in a single facility can be a headache. Your product labeling solution is with CTM Labeling Systems. Our applicators can be configured for multiple containers and labels. Print and apply applicators are also available to easily add lot numbers or expiration dates to your product labels. 

We Make Labeling Easy 

Whether your products go into cans, bottles or bags, CTM Labeling Systems has the machines you need to get the job done while meeting organic food labeling and regulatory requirements. Contact us to get in touch with your local distributor who will work with you to create a labeling solution that fits all of your requirements!