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Only Listing Organic Ingredients in the Ingredient Panel - No Organic Status


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#1 jbell4711

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Posted 01 July 2020 - 04:43 PM

Hello,

 

My product will only be listing its organic ingredients on the ingredient panel. We will not be holding any organic status ie. Organic on PDP or Made with Organic.

 

For documentation maintenance and to stay in compliance with labeling organic ingredients only in the ingredient panel, I know we should maintain the organic certificates of the individual ingredients, but if the ingredients go through any processing in a facility, does that facility that handles the organic product need to be organically certified as well? Our final co-packer for most of our SKUs is NOP certified, but the other facility is not organically certified. Can we still list the ingredients as Organic if that's the case????

 

Help is greatly appreciated!!



#2 olenazh

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Posted 01 July 2020 - 04:57 PM

What's the point of listing organic ingredients if the product is not Organic certified? Consumers don't usually pay attention to ingredient "status", label claims (e.g. Organic, Natural, etc.) - that's what matters.



#3 SQFconsultant

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Posted 01 July 2020 - 05:30 PM

I've seen companies list organic ingredients on the panel and not be organic certified - that is fine.

 

You just better be able to prove the ingredients are organic.

 

As consumers we buy organics as much as possible and go right to the panel for information - that is really all that matters, the certs mean nothing to me when we are food shopping.


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#4 Njaquino

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Posted 01 July 2020 - 05:52 PM

What's the point of listing organic ingredients if the product is not Organic certified? Consumers don't usually pay attention to ingredient "status", label claims (e.g. Organic, Natural, etc.) - that's what matters.

 

I was about to ask the same thing. If you don't plan on being organic certified is would be more cost effective, to not buy organic ingredients. 

 

To answer you question OP,

 

Does that facility that handles the organic product need to be organically certified as well? From my experience, if you want to be listed as organic our facility had to be organic. If the co-packer wasn't organic then we had to add them to our list. I could be wrong but that is how I was taught. 


Edited by Njaquino, 01 July 2020 - 05:54 PM.


#5 Ryan M.

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Posted 01 July 2020 - 10:54 PM

If you use "organic" for any ingredient on your label that supplier of the organic must be organic certified for that ingredient.  Certified organic means it is 95% or greater of organic content.

 

You do not need to obtain organic certification, but must be able to prove the ingredients you list as "organic" are organic certified.  This means you need the supplier's organic certificate and their organic summary plan (OSP).  Be sure to have them highlight, or tell you the specific item on the organic summary plan that you are purchasing as sometimes this can be confusing since an OSP can be broken out by brand names, pack sizes, and slightly differing names of materials.

 

https://www.usda.gov...ic ingredients.



#6 Charles.C

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Posted 02 July 2020 - 03:08 AM

Not my area as a producer or consumer but "Organic" seems to be as much a PR issue as a Manufacturing one.

 

If I were a potential "Organic" consumer, knowledge that the final product derived from any arbitrarily controlled Manufacturing process would render any claimed "Organic" status null and void.  

 

I noticed this text from Ryan's fascinating link (a story of "fudges" ? :smile: )  -
 

 

In the “100 Percent Organic” category, products must be made up of 100 percent certified organic ingredients.  The label must include the name of the certifying agent and may include the USDA Organic Seal and/or the 100 percent organic claim.

 

 

IMO this is a (clever?) example of a "necessary but not sufficient" definition.

 

The conclusion appears to be that (a) even the (Gold Star?) " USDA Organic Seal"  does not guarantee a "fully"  "Organic" consumerable (see def. of "organic"), (b) neither does a label stating "100% Organic" per se.

 

The nearest you can get to Organic Perfection seems to be (a) + (b).


Kind Regards,

 

Charles.C


#7 Ryan M.

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Posted 03 July 2020 - 02:57 AM

This is in regards to how a product can be labeled and if they wish to use the organic seal.  They do not have to use the organic seal, and they do not have to state "100% Organic" rather it can state "Organic".

 

Either way, the item is verified 100% organic through the certification audit so no real fudging at all.

 

 

IMO this is a (clever?) example of a "necessary but not sufficient" definition.

 

The conclusion appears to be that (a) even the (Gold Star?) " USDA Organic Seal"  does not guarantee a "fully"  "Organic" consumerable (see def. of "organic"), (b) neither does a label stating "100% Organic" per se.

 

The nearest you can get to Organic Perfection seems to be (a) + (b).



#8 Charles.C

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Posted 03 July 2020 - 06:39 AM

This is in regards to how a product can be labeled and if they wish to use the organic seal.  They do not have to use the organic seal, and they do not have to state "100% Organic" rather it can state "Organic".

 

Either way, the item is verified 100% organic through the certification audit so no real fudging at all.

IMO the primary marketing objective is to get "Organic" on the Label's PDP which is "enhanced" via USDA's labelling scheme, ie - 

 

Attached File  usda organic.PNG   155.89KB   0 downloads

 

If a legal obligation existed for the labelling to include the above index then I would concur "no fudge".  Similarly if the seal had a "%"  included on it.

 

JFI I also noticed this so-called organic myth (older ref. so things may have changed. Hope so.) -

 

Attached File  organic myth.png   85.62KB   0 downloads


Kind Regards,

 

Charles.C


#9 Charles.C

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Posted 03 July 2020 - 01:08 PM

Possibly an official answer to the OP -

 

Can a product be labeled “organic” without being certified?

Overall, if you make a product and want to claim that it or its ingredients are organic, your final product probably needs to be certified. If you are not certified, you must not make any organic claim on the principal display panel or use the USDA organic seal anywhere on the package*. You may only, on the information panel, identify the certified organic ingredients as organic and the percentage of organic ingredients.

*Some operations are exempt from certification, including organic farmers who sell $5,000 or less

 

 

https://www.ams.usda...rganic/labeling

 

(similar to post 5 but possibly, significantly, "extrapolated")

 

PS -It seems to me that the above (somewhat vague) interpretation implies that, contrary to Post 3, USDA believe that consumers judge Organic Products via the PDP/Seal rather than the ingredient list. Hmmmm.


Kind Regards,

 

Charles.C


#10 Ryan M.

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Posted 03 July 2020 - 04:35 PM

I am speaking strictly from a certification point of view; marketing of organic is another matter entirely.  I really don't know what consumers look at, or "trust", in terms of organic when they are purchasing and I don't really care.  There will always be some "mistrust" of food companies by consumers, it is only natural because of consumer ignorance and the few bad apples in the industry.

 

And yes, pesticides and herbicides, among other things, can be used on organic crops / food, and in processing so long as they are on the NOP approved list AND used in the matter required on the NOP approved list.  There is always a degree of "vagueness" with certifications and regulations which is on purpose to provide some "gray areas" to work within and just a matter of language as well.

 

 

Possibly an official answer to the OP -

 

 

https://www.ams.usda...rganic/labeling

 

(similar to post 5 but possibly, significantly, "extrapolated")

 

PS -It seems to me that the above (somewhat vague) interpretation implies that, contrary to Post 3, USDA believe that consumers judge Organic Products via the PDP/Seal rather than the ingredient list. Hmmmm.



#11 Charles.C

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Posted 04 July 2020 - 04:54 AM

I am speaking strictly from a certification point of view; marketing of organic is another matter entirely.  I really don't know what consumers look at, or "trust", in terms of organic when they are purchasing and I don't really care.  There will always be some "mistrust" of food companies by consumers, it is only natural because of consumer ignorance and the few bad apples in the industry.

 

And yes, pesticides and herbicides, among other things, can be used on organic crops / food, and in processing so long as they are on the NOP approved list AND used in the matter required on the NOP approved list.  There is always a degree of "vagueness" with certifications and regulations which is on purpose to provide some "gray areas" to work within and just a matter of language as well.

Hi Ryan,

 

Returning to the OP, as I understand, for the product whose labelling/commercialisation is as described in the OP

 

(1) Despite the inclusion of (stated) organic ingredients in the ingredients list, due ^^^(red) the final product avoids being regarded as "Organic"  by USDA and therefore is automatically outside involvement in the USDA's certification program.

 

(2) Similarly the additional activities mentioned in the OP avoid being regarded as "handling activities" within the context of the NOP Program (subpart D)..

 

The only query therefore appears to be as to any necessary requirements related to the ability to refer to the listed ingredients as "organic" which are responded to in yr Post 5.

 

It would appear that to avoid fines Distributors of this final product will have to exercise extreme caution in any related Promotional activities.


Kind Regards,

 

Charles.C





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