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United States Dept.

of Agriculture | Agricultural Marketing Service

The National Organic Program’s


Online Training
Subpart D-
Labels, Labeling &
Market Information

8/6/2012 1
United States Dept. of Agriculture | Agricultural Marketing Service

TABLE OF CONTENTS
PART I PART II PART III PART IV
• Percentage
• §205.301 • §205.301 Product • §205.303 Statements
• Product sold in Composition 100% organic • Ingredient
the US • §205.302 Calculating “organic” Statements
• Label Anatomy Percentages • §205.304 • Mandatory
• solid “made with Information
• liquid organic” • “Certified by”
• solid & liquid • §205.305 location
Multi- • Optional
ingredient -less Information
than 70% • Other
Information
CONTINUED ON NEXT PAGE

8/6/2012 2
United States Dept. of Agriculture | Agricultural Marketing Service

TABLE OF CONTENTS
PART V PART VI PART VII TEXTILE PART VIII ALCOHOL
• §205.306 Livestock • Private Label • NOP Standards • Regulatory
feed Certification • Use of the Agencies for
• §205.307 Non- • Certifiers’ term “organic” alcohol
retail Containers Responsibilities • Use of the beverage
• §205.307(c) Export • Changing term “organic” labeling
Containers Certifiers in 3rd • Approval
• §205.308 • Errors in party process for
Unpackaged Retail Labeling certification alcohol
• §205.309 • Additional Label • Label guide beverage labels
Unpackaged retail Claims • Example of • Composition
• §205.310 Exempt- labels and Labeling
Excluded • Resources Categories
Operations • Labeling
• §205.311 NOP Seal Requirements

8/6/2012 3
United States Dept. of Agriculture | Agricultural Marketing Service
CONTENT – PART I
TOPICS COVERED

• §205.300 – use of the


term “organic”
• Products sold in the
U.S.
• Label Anatomy

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.300 Use of the term “organic”

The use of the term “organic” and its derivations may


only be used on:
• labels and in labeling of raw or processed agricultural
products, including ingredients,
• that have been produced and handled in accordance with the
regulations in this part. The term “organic” may not be used
in a product name to modify a nonorganic ingredient in the
product.

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United States Dept. of Agriculture | Agricultural Marketing Service

Products Sold in the United States


For products sold as organic in the United
States, the products must be produced in
compliance with the NOP regulations and
certified by an NOP authorized (accredited or
recognized) certifying agent or produced in
compliance with an equivalency agreement

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United States Dept. of Agriculture | Agricultural Marketing Service

Label Anatomy-
Organic Designation
Product Name
NOP Seal
Additional Label Claims
Low Sodium
Nutritional Facts
Ingredient Statement
Allergen Warnings
Low Sodium
Name of Distributor
Name of Certifying Agent
Certifying Agent’s Seal

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United States Dept. of Agriculture | Agricultural Marketing Service
CONTENT – PART II

TOPICS COVERED

§205.301 Product Composition


§205.302 Calculating Percentages
§205.302 Calculating Percentages- solid
§205.302 Calculating Percentages- liquid
§205.302 Calculating Percentages-
solid & liquid

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.301 Product Composition


• 100% All agricultural ingredients and processing aids
(a) Organic must be certified organic

• “Organic” 95% of product must be certified organic


(b) (>95%) agricultural products

• “Made With Organic At least 70% certified organic


(c) Ingredients” produced ingredients

• <70% Organically Only use “organic” on ingredient


(d) Produced Ingredients statement

(e) • Organic Livestock Feed also see §205.237

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.301- 100% Organic


• Products labeled as 100% organic may
only contain 100% certified organic
agricultural ingredients.

• All processing aids must be certified


organic ingredients.

• Products labeled as 100% organic may


not contain any materials from the
National List of Allowed and Prohibited
Substances (sections 205.605 &205.606)

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.301
Product Composition- “Organic”
• 5% may be:
5% – Substances from 205.605
– Non-organic agricultural
products from 205.606
95% that are not commercially
Certified Organic available in organic form.
Agricultural Products – No excluded methods,
sewage sludge, or
irradiation.

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.301 “Organic”
• Products labeled as “Organic” must
contain at least 95% certified organic
agricultural ingredients.
• All agricultural ingredients must be
organic unless they are listed on
205.606 and are not commercially
available in organic form (e.g. casings,
some colors, gelatin)
• Non-agricultural or synthetic
ingredients from 205.605 may also be
used.

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.301
“Made with Organic
[specified ingredients
or food groups]”

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.301 “Made with Organic


[specified ingredients or food groups]”
• 30% may be any
nonorganic agricultural
30% ingredient /product
70%
produced without
Certified Organic
excluded methods,
Agricultural Products
sewage sludge, or
irradiation.
Continued on next slide

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United States Dept. of Agriculture | Agricultural Marketing Service

What also may go in


the 30%- • Nonorganic agricultural products
– May be produced using
synthetic fertilizers and
pesticides not on the National
List.

• Materials listed on 205.605 from


the National List.

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.302 (c) Calculating Percentage of


Organically Produced Ingredients
• Percentages must be determined by handler
who affixes the label on the consumer package
and verified by the certifying agent of the
handler.
• The handler may use information provided by
the certified operation (who supplies
ingredients) in determining the percentage.

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.302 Calculating Percentage of


Organic Ingredients for Solid Ingredients
• Divide weight of organic ingredients by total
weight (excluding water and salt).
• Round percentage of organic ingredients
DOWN to a whole number.
EXAMPLE:
94.95% = 94%

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United States Dept. of Agriculture | Agricultural Marketing Service

Calculating Solid Ingredients


Baking Mix Formulation (1000 LB Batch)

Organic Flour 700 lbs


Divide weight of Organic shortening 250 lbs
organic ingredients by Organic non-fat dry milk 100 lbs
total weight (excluding Organic corn starch 12 lbs
water and salt). Cream of Tartar 10 lbs
(Potassium acid tartrate)
Ammonium bicarbonate 13 lbs

Salt 10 lbs

Total 1000 lbs

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United States Dept. of Agriculture | Agricultural Marketing Service

Calculating Solid Ingredients


Baking Mix Formulation (1000 LB Batch)

Organic Flour 700 lbs


Organic shortening 250 lbs
Certified organic ingredients Organic non-fat dry milk 100 lbs
Organic corn starch 12 lbs

Cream of Tartar 10 lbs


Non-organic ingredients from 205.605 (Potassium acid tartrate)
Ammonium bicarbonate 13 lbs

Excluded from calculation Salt 10 lbs

Total 1000 lbs

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United States Dept. of Agriculture | Agricultural Marketing Service

Calculating Solid Ingredients


Here’s an Example . . . Baking Mix Formulation (1000 LB Batch)
Organic Flour 700 lbs
Total organic ingredients
Organic shortening 150 lbs
962 lbs.
Organic non-fat dry milk 100 lbs
Organic corn starch 12 lbs

Total nonorganic Cream of Tartar 15 lbs


(Potassium acid tartrate)
ingredients
Ammonium bicarbonate 13 lbs
28lbs
Salt 10 lbs
Total weight of organic and Total 1000 lbs
nonorganic ingredients
990lbs
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United States Dept. of Agriculture | Agricultural Marketing Service

Calculating Solid Ingredients


962 lbs. -- total organic ingredients divided by

990 lbs. -- total ingredient weight (organic and


nonorganic ingredients)
= .971 or 97%

Qualifies for an ORGANIC label

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.302 Calculating Percentage of


Organic Ingredients (Liquid Ingredients)
• Divide fluid volume of organic ingredients by total
volume (excluding water and salt);
• If liquid products are identified as reconstituted
from concentrate, calculation should be based on
single-strength concentrations of the ingredients
and finished products;
• Round down to nearest whole number.

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United States Dept. of Agriculture | Agricultural Marketing Service

Calculating Liquid Ingredients


Fruit Drink Formulation (1000 L Batch)
Water 500 L
• Determine total volume Organic corn syrup 390 L
minus water and salt. Organic orange juice 100 L

• Determine percentage of Citric acid 5L


organic ingredients in Natural flavor 2.5 L
remaining volume. Beet juice extract color* 2.5 L
(nonorganic / non-GMO)
Total 1000 L
* Not commercially available in organic
form.

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United States Dept. of Agriculture | Agricultural Marketing Service

Calculating Liquid Ingredients


Here’s an Example . . . Fruit Drink Formulation (1000 L Batch)

Excluded from calculation Water 500 L


Organic corn syrup 390 L
490 L total organic ingredients Organic orange juice 100 L

Citric acid 5L
10 L nonorganic ingredients from Natural flavor 2.5 L
205.605 and 205.606
Beet juice extract color* 2.5 L
(nonorganic / non-GMO)
500 L total organic & nonorganic Total 1000 L
ingredients * Not commercially available in organic
form.

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United States Dept. of Agriculture | Agricultural Marketing Service

Calculating Liquid Ingredients


Fruit Drink Formulation (1000 L Batch)
Water 500 L
Organic corn syrup 390 L
490 L Total organic ingredients Organic orange juice 100 L

Citric acid 5L
500 L Total organic &
Natural flavor 2.5 L
nonorganic
ingredients Beet juice extract color* 2.5 L
(nonorganic / non-GMO)
Total 1000 L
= .98 or 98%
* Not commercially available in organic
Qualifies for an ORGANIC label form.

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.302 Calculating Percentage of Organic


Ingredients (Solid and Liquid Ingredients)
• Divide combined weight of liquid and solid
organic ingredients by total weight of liquid
and solid ingredients, excluding water and
salt;
• Round down to nearest whole number.

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United States Dept. of Agriculture | Agricultural Marketing Service
CONTENT – PART III

TOPICS COVERED

§205.303 -
100% Organic
“Organic”
§205.304 “Made with Organic”
§205.305 Multi-ingredient -less than 70%

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.303 Labeling 100% Organic Content

• May say “100% Organic” or “Organic”


• May use NOP seal
• May display Certifier’s logo
-Not more prominent than NOP seal
• May make percentage claim
-Note size restriction

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.303 Labeling 95% or more


Organic Content

• May say “Organic”


• May make a percentage statement:
–Percentage statement must not
exceed ½ the size of the largest type
on the panel.
–Must be entirely the same type,
style, size, and color, without
highlighting.
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United States Dept. of Agriculture | Agricultural Marketing Service

§205.304 “Made with Organic


[specified ingredients or food groups]”
• May list up to 3 ingredients or food groups
• May make a percentage statement
– Percentage statement must not exceed ½ the size of
the largest type on the panel.
– Must be entirely the same type, style, size, and
color, without highlighting.

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United States Dept. of Agriculture | Agricultural Marketing Service

“Made with Organic ***”


• It is acceptable to mix and match
food groups and ingredients within
the “made with organic ***”
statement.
– However, the statement can not
contain more than three food groups
or ingredients combined.

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United States Dept. of Agriculture | Agricultural Marketing Service

Made with Organic


“specified food groups”
• 205.304(a)(1)(ii) Fish, fruits, grains, herbs, meats,
nuts, oils, poultry, seeds, spices,
When referencing
sweeteners, and vegetables. In
food groups in the addition, organically produced and
“made with organic” processed butter, cheeses, yogurt,
statement, use only milk, sour cream, etc., may be
the groups listed: identified as a “milk products” food
group” (65 FR 80579).
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United States Dept. of Agriculture | Agricultural Marketing Service

“Made with Organic ***” All forms of


blueberries
must be
“Made With Organic ***” organic
products must not include
organic and non-organic forms
of the same ingredient, when
these ingredients and/or food
groups, are listed within the
“made with” statement.

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.305 Multi-ingredient packaged products


with less than 70% Organic Ingredients

• No use of the term organic


on primary display panel.
• May list organic ingredients
on information panel.
• May not refer to
ingredients as “certified.”

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United States Dept. of Agriculture | Agricultural Marketing Service
CONTENT – PART IV

TOPICS COVERED

Percentage Statements
Ingredient Statements
Mandatory Information
“Certified Organic by” location
Optional Information
Other Information
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United States Dept. of Agriculture | Agricultural Marketing Service

Percentage Statements
• Percentage statement must
not exceed ½ the size of
the largest type on the
panel.
• Must be entirely the same
type, style, size, and color,
without highlighting.

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United States Dept. of Agriculture | Agricultural Marketing Service

Percentage Statements
This label would not comply
with paragraph 205.304(a)(2)
because the type is not all the
same size and style and the
word “Organic” is highlighted
and in another color.

INCORRECT

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United States Dept. of Agriculture | Agricultural Marketing Service

correct
This label would comply with Paragraph
205.304 (a) (1) (iii) because the type style
and size of the statement “Made with
Organic Yellow Corn” are the same
without highlighting.
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United States Dept. of Agriculture | Agricultural Marketing Service

INCORRECT

This label would not comply with Paragraph


205.304 (a) (1) (iii) because the type style and
size of the words in the statement “Made with
Organic Flour” are not the same and the word
“Organic” is highlighted
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United States Dept. of Agriculture | Agricultural Marketing Service

Ingredient
Statement
Each ingredient used in the
product must be included in the
ingredient statement on the
container’s information panel.
Organic ingredients must be
identified as being organic.

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United States Dept. of Agriculture | Agricultural Marketing Service

Ingredient
Statement
As an option, an
asterisk (*) may be used
to identify organically
produced agreements.

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United States Dept. of Agriculture | Agricultural Marketing Service

Ingredient
Statement
It is permissible to make
mandatory allergy
warning statements as
shown in this example.

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United States Dept. of Agriculture | Agricultural Marketing Service

Mandatory Information
NAME OF CERTIFIER
“Certified organic by [name of
Certifier]” or similar phrase must
appear on the information panel
below information identifying the
handler or distributor of the
finished product.
Certified products may use the
certifier’s logo to meet this
requirement if the seal states
“certified organic by.”

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United States Dept. of Agriculture | Agricultural Marketing Service

Location of “certified organic by”


statement
On the information panel, below the
information identifying the handler or
distributor of the product and preceded
by the statement, “Certified organic
by * * *,” or similar phrase, identify the
name of the certifying agent that certified
the handler of the finished product:

Except, That, the business address,


Internet address, or telephone number of
the certifying agent may be included in
such label.

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United States Dept. of Agriculture | Agricultural Marketing Service

Optional Information
ADDITIONAL CERTIFIER
In addition to information
about the certifier of the
handler of the finished
product, labels may also
display certifier information
of other certifiers.
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United States Dept. of Agriculture | Agricultural Marketing Service

Other information
ADDITONAL LABEL CLAIMS
Labels may display addition claims as long as they
are truthful and do not violate other US regulations

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United States Dept. of Agriculture | Agricultural Marketing Service
CONTENT – PART V

TOPICS COVERED

§205.306 Livestock feed


§205.307 Non-retail Containers
§205.307(c) Export Containers
§205.308 Unpackaged Retail
§205.309 Unpackaged retail
§205.310 Exempt- Excluded Operations
§205.311 NOP Seal
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United States Dept. of Agriculture | Agricultural Marketing Service

§205.306 Livestock feed


• May display:
– “100% Organic” or “Organic”
– USDA Seal
– Mark of certifying agent
• Can not be more prominent than the NOP seal
– The term “organic” to identify organic ingredients
• Must display “Certified organic by” [Certifier]
• Must comply with other Federal and State feed labeling requirements.

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United States Dept. of Agriculture | Agricultural Marketing Service

Countryside Products Information Panel


Organic Goat Feed
100% ORGANIC AGRICULTURAL
INGREDIENTS
Organic Corn, Organic Field Peas, Organic Oats, Organic Wheat, Organic Flaxseed, Organic Alfalfa INGREDIENTS
Meal, , Dried Organic Kelp, Organic Coconut Oil,
Calcium Carbonate Sulfur, Salt,, Soft Rock Phosphate, Dicalcium Phosphate, Monocalcium
Phosphate, Tricalcium Phosphate, Dried Lactobacillus Acidophilus Fermentation Product,
Condensed Lactobacillus Fermentation Solubles, Seashell Flour, Magnesium Oxide, Potassium
Chloride, Yeast Culture, Sodium Selenite, Vitamin A Supplement, Vitamin D3 Supplement, Vitamin
VITAMINS,
E Supplement, Vitamin B12 Supplement, Menadione Sodium Bisulfite Complex (source of Vitamin MINERALS, SUPPLEMENTS
K activity), d-Calcium Pantothenate, Sodium Bentonite, Zinc Polysaccharide Complex, Manganese
Polysaccharide Complex, Iron Polysaccharide Complex, Copper Polysaccharide Complex, Cobalt SALT
Polysaccharide Complex, Cobalt Choline Citrate, Niacin, Riboflavin, Thiamine, Folic Acid.

FEEDING DIRECTIONS
Feed as needed to supplement nutritional intake.

Countryside Products, Inc.


1688 Jefferson Hwy
Fishersville, VA 22939
NAME OF CERTIFIED
888-999-7088 OPERATION
Certified organic by
Organic Inc.
Net Weight - 50 Lb. (22.68 KG)
NAME OF CERTIFIER

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.307 Non-Retail Containers


• Must display:
– Production or lot number, if applicable
– Information must be traceable to documentation supporting the
organic status of the product
• May Display
– Name and contact information of Certifier
– Organic designation
– Handling instructions to maintain organic integrity
– NOP seal
– Certifier seal

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.307(c) Export Containers


• May be labeled to meet destination
country’s requirements.
• Shipping containers and documents:
– “For Export Only”
• Handler must maintain export and
marking records.

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.308 Unpackaged Retail


• May label as “100% Organic” or “Organic”
– Retail displays
– Labeling
– Display containers
• Organic content must be identified on the
ingredient statement
• If facility is certified, they may display:
– Certified organic
– Use the NOP seal
– Certifier seal

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United States Dept. of Agriculture | Agricultural Marketing Service

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.309 Unpackaged Retail


• May label as “Made with organic (specified ingredients or
food group(s))”
– Retail displays
– Labeling
– Display containers
• Statement must not list more than 3 organic ingredients or
food groups
• Organic content must be identified in ingredient statement
• If prepared in a certified facility, products labeled as “made
with organic (specified ingredients or food group(s)),” may
display the Certifier seal, logo or other identifying marking.

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.310 Exempt or Excluded Operations


• Products produced on exempt or excluded operations must
not:
– Display NOP seal or Certifier’s seal or other identifying
mark.
– Be represented as certified organic or containing organic
ingredients.
• An agricultural product organically produced or handled on an
exempt or excluded operation may be identified as an organic
product or organic ingredient in a multi-ingredient product
produced by the exempt or excluded operation.
• However, the product or ingredient may not be represented as
organic in a product processed by others.
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United States Dept. of Agriculture | Agricultural Marketing Service

§205.311 NOP Seal


The colors of the NOP seal must
appear as described in the NOP
regulations.

(incorrect)

correct

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United States Dept. of Agriculture | Agricultural Marketing Service

§205.311 NOP Seal


Look alike logos are not permitted.

95% 70% 50%

INCORRECT

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United States Dept. of Agriculture | Agricultural Marketing Service
CONTENTS – PART VI

TOPICS COVERED

Private Label Certification


Certifiers’ Responsibilities
Changing Certifiers
Errors in Labeling
Additional Label Claims

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United States Dept. of Agriculture | Agricultural Marketing Service

Private Label Certification


• A “private label” merchant is a
company that contracts out
the processing and packaging
of organic products and does
not physically handle the
product.

• Not required to be certified

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United States Dept. of Agriculture | Agricultural Marketing Service

Private Label Certification


• If certified, the private label company must have
complete information concerning labels, formulas
and production to be fully audited by certifying
agent.

• Co-packers also must have complete information


about labels, formulas, suppliers so that the
certifier of the co-packer is fully accountable for
final products.

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United States Dept. of Agriculture | Agricultural Marketing Service

Private Label Certification

The Certifying Agent whose name appears on the


product of the final handler, must be able to
address any inquiries about the product, by a
consumer or other interested party, and is fully
responsible for ensuring that the certified operation
and organically produced product meets all
requirements of the NOP regulations.

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United States Dept. of Agriculture | Agricultural Marketing Service

Private Label Certification

The name of the certifier of the


private label merchant may appear
on the information panel.

The certifier of the actual handler of


the finished product may require
their name to also be listed on the
information panel.

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United States Dept. of Agriculture | Agricultural Marketing Service

Certifiers’ Responsibilities
• Certifiers are responsible for reviewing and
approving all labels prior to labeling and
distribution of certified products.
• Certifiers who certify co-packers must review and
approve all private labels handled by the co-packer.
• The certifier whose name appears on the
information panel is responsible for verifying label
compliance as well as compliance with all other
organic requirements.
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United States Dept. of Agriculture | Agricultural Marketing Service

Changing Certifiers, use up labels


• When a certified producer or handler changes certifying
agents, the certified operation must change its labels to
reflect the change immediately.
• A certified producer or handler is allowed limited use-
up of existing labels in the event its current certifier has
lost its accreditation or has gone out of business. The
certified producer or handler’s new certifier will require
that the operation revise its labels.

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United States Dept. of Agriculture | Agricultural Marketing Service

Errors in Labeling
When errors are discovered in labeling, certifiers and their
certified operations are required to ensure that errors are
corrected immediately and that any incorrect labels that have
not entered the stream of commerce are not used.
No use up of labels is permitted for serious errors such as:
1. Improper use of the NOP seal.
2. Incorrect product classification such as if a “made-with”
product is labeled “organic.”
3. Omission of the name of the certifying agent.

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United States Dept. of Agriculture | Agricultural Marketing Service

Additional Label Claims


INCORRECT

Additional label claims may NOT suggest


that any particular organic product has a
superior level of “organicness.”
Prohibited claims might include:
•Better than USDA organic
•Exceeds USDA standards for organic
products

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United States Dept. of Agriculture | Agricultural Marketing Service

Additional Label Claims


Handlers of organic products may make
additional label claims, provided such claims
are truthful and do not violate the NOP
regulations or other Federal or State labeling
regulations.
Such claims might include:
•Grass-fed
•Raised without synthetic hormones
•Antibiotic-free
•Product of the USA
•Locally Grown

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United States Dept. of Agriculture | Agricultural Marketing Service

Labeling of
PART VII

Textiles that
Contain
Organic Fibers

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United States Dept. of Agriculture | Agricultural Marketing Service
CONTENT- PART VII

TOPICS COVERED
NOP Standards
Use of the term “organic”
Use of the term “organic” in
3rd party certification
Label guide
Example of labels
Resources
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United States Dept. of Agriculture | Agricultural Marketing Service

The USDA regulates the term “organic” as it


applies to agricultural products. This
includes fibers and agricultural products
covered under the NOP crop and livestock
standards.
For example:
Silk
Wool
Cotton
Flax
Raw latex
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United States Dept. of Agriculture | Agricultural Marketing Service

Textile Processing Standards


• There are no NOP regulations specifically
for processing or manufacturing textile
products.
• However, textile products that are
produced in compliance with the NOP
crop or livestock regulations and NOP
processing regulations may be labeled as
certified organic and display the USDA
seal.

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United States Dept. of Agriculture | Agricultural Marketing Service

Textile products labeled as “Organic”

may: must not:


• Use the USDA seal unless certified to the
• Use label claims that crop/livestock and processing regulations
identify specific fibers • Imply or lead the consumer to believe
as organic* that the final product is certified under
• Use statements the NOP.
identifying the • Use a combination of both organic and
percentage of organic organic sources for a single fiber that is
fibers* identified as “organic” in the final
*providing the fiber is certified to product label.
the NOP crops/livestock regulations.

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United States Dept. of Agriculture | Agricultural Marketing Service

Use of the term “Organic” in textile products


that are 3rd-party certified
• Use of the term “organic” in 3rd-party certified textile
products is not regulated by the NOP.
• Fibers identified as “organic” in these products, and
sold in the U.S., must be certified under the NOP
regulations.
• Textiles are produced in accordance with the Global
Organic Textile Standard (GOTS). These products
may be sold as “organic” in the U.S., but may not
refer to NOP certification or display the USDA seal.
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United States Dept. of Agriculture | Agricultural Marketing Service

Labeling Categories and Claims


labeling guide- Textiles Certified to NOP
Crop/Livestock Production
and Processing Regulations
Use of the USDA seal

100% organic claim

Organic claim

Contains organic ingredients

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United States Dept. of Agriculture | Agricultural Marketing Service

correct

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United States Dept. of Agriculture | Agricultural Marketing Service

Additional References
• These policies do not supersede requirements of
other Federal and State laws.
• The NOP requirements are in addition to those
required by the Federal Trade Commission’s (FTC)
Textile and Wool Acts. The FTC labeling
requirements for textiles can be found here:
http://www.ftc.gov/os/statutes/textilejump.shtm

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United States Dept. of Agriculture | Agricultural Marketing Service

Organic Label Claims on


Alcohol Beverages
Wine, Malt Beverages,
Distilled Spirits

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United States Dept. of Agriculture | Agricultural Marketing Service

TOPICS COVERED
CONTENT - PART VIII
Regulatory Agencies for
for alcohol beverage labeling

Approval process for alcohol


beverage labels

Composition and Labeling


Categories

Labeling Requirements
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United States Dept. of Agriculture | Agricultural Marketing Service

Regulation by TTB-

• The Alcohol and Tobacco Tax and Trade Bureau (TTB), part of
the Department of the Treasury, has the authority to regulate
the labeling and advertising of domestic and imported
distilled spirits, wines, and malt beverages. Federal Alcohol
Administration Act (FAA Act), and the Internal Revenue Code
of 1986

• According to the regulations which TTB enforces, the use of


the term “organic’ is optional and is treated as “additional
information on labels.”
27 CFR parts 4.101 (wine), 5.71 (distilled spirits), 7.81 (malt beverages)

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United States Dept. of Agriculture | Agricultural Marketing Service

Regulatory Agencies continued-


TTB-NOP Cooperation
• Any use of the term “organic” on alcohol beverage
labels or advertisements must comply with USDA
National Organic Program regulations at 7 CFR part
205.
• TTB and AMS established an agreement under which
TTB is responsible for reviewing alcohol beverage
labels for compliance with the NOP regulations.
Memorandum of Understanding

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United States Dept. of Agriculture | Agricultural Marketing Service

TTB Label Approval


Requirements
• Proof of NOP certification.
• Written approval
of labels from certifier (ACA Preview).
• Copy of certifier approved
label(s).

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United States Dept. of Agriculture | Agricultural Marketing Service

TTB label applications:


Proof of NOP Certification
Certificates presented in label application must:

• Indicate that product is certified to NOP


standards.
• Be effective before the vintage date.
• Be written in or translated to English.

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United States Dept. of Agriculture | Agricultural Marketing Service

TTB Label Applications: ACA Preview


A written statement from the certifier of the handler, that
the product label(s) and corresponding certificates for the
handling operation and all organic ingredients are in
compliance with the NOP.
Certifier approval must be obtained prior to submission
of labels to TTB and include:
• Date of approval.
• Certifier’s stamp or signature on legible photocopies of
label images as proof of review and approval.

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United States Dept. of Agriculture | Agricultural Marketing Service

Labeling features unique to


alcohol beverages
• An ingredient statement on product is not
required.
• The use of sulfites must be disclosed on the
label.

84
United States Dept. of Agriculture | Agricultural Marketing Service

Sulfite Statement-
• Sulfite Disclosure is required on alcohol beverage
products (TTB regulations 27 CFR 4.32(e)).
• A product is exempt from sulfite disclosure when: (i) any
sulfiting agent is detected at less than 10 ppm, and (ii)
verification by laboratory analysis from a TTB recognized
laboratory- http://www.ttb.gov/ssd/beverage_alcohol_lab.shtml
• “Sulfite Free” and “No Sulfites” claims are prohibited.
– “No Added Sulfites” must further be qualified with “May
contain Naturally Occurring Sulfites” every time it
appears on the label.

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United States Dept. of Agriculture | Agricultural Marketing Service

W I NE Grapeful
100%
100%ORGANIC Organic

PRINCIPAL DISPLAY CALIFORNIA CABERNET


SAUVIGNON
PANEL 13.2% Alc./Vol.
750 ml

Grapeful
INFORMATION
100%
Organic

PANEL PRODUCED & BOTTLED BY:


GRAPEFUL CELLARS, SOLIS, CA

CERTIFIED ORGANIC BY:


ABC Organic Certifiers
GOVERNMENT WARNING: (1) ACCORDING TO THE
SURGEON GENERAL, WOMEN SHOULD NOT DRINK
ALCOHOLIC BEVERAGES DURING PREGNANCY BECAUSE
OF THE RISK OF BIRTH DEFECTS. (2) CONSUMPTION OF
ALCOHOLIC BEVERAGES IMPAIRS YOUR ABILITY TO DRIVE
A CAR OR OPERATE MACHINERY, AND MAY CAUSE
HEALTH PROBLEMS.

86
United States Dept. of Agriculture | Agricultural Marketing Service

WINE Mas Amore


ORGANIC
ORGANIC
PRINCIPAL
DISPLAY Malbec
Mendoza . Argentina
PANEL 2008 13.2% Alc./Vol.
750 ml

Mas Amore
ORGANIC
INFORMATION Malbec

PANEL PRODUCED & BOTTLED BY: Caballero Vineyards

Imported by: AM Wine Trade Co., NY, NY

CERTIFIED ORGANIC BY: PRODUCT OF ARGENTINA


ABC Organic Certifiers

GOVERNMENT WARNING: (1) ACCORDING TO THE SURGEON GENERAL,


WOMEN SHOULD NOT DRINK ALCOHOLIC BEVERAGES DURING
PREGNANCY BECAUSE OF THE RISK OF BIRTH DEFECTS. (2)
CONSUMPTION OF ALCOHOLIC BEVERAGES IMPAIRS YOUR ABILITY TO
DRIVE A CAR OR OPERATE MACHINERY, AND MAY CAUSE HEALTH
PROBLEMS.

87
United States Dept. of Agriculture | Agricultural Marketing Service

“Made with organic (ingredients)”


Acceptable variations
of the “Made with…”
statement include:

Made with Made with


Organically Grown Made with
Organic Grapes
Grapes Organic Grapes
from our Vineyard

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United States Dept. of Agriculture | Agricultural Marketing Service

“Organic” restricted to an
ingredients statement
Non-certified products which contain less than 70%
organically produced ingredients, excluding water and salt,
may use the term “organic” only on the information panel
to indicate:

• Organically produced ingredients


• The percentage of organic ingredients in the product

89
United States Dept. of Agriculture | Agricultural Marketing Service

BEER Racehorse
ORGANIC Organic
Ale
RACEHORSE
PRINCIPAL BREWING
COMPANY,
MILTON, NY
DISPLAY PANEL
Certified Organic By:
ABC Certifiers 12 Fl.Oz

Racehorse
Organic Ale
INFORMATION Contains: Water, Organic wheat
malt, organic barley malt , Organic
PANEL Cascade hops, Organic
Hallertauer hops, yeast
99% Organic Ingredients

GOVERNMENT WARNING: (1) ACCORDING TO THE SURGEON


GENERAL, WOMEN SHOULD NOT DRINK ALCOHOLIC BEVERAGES
DURING PREGNANCY BECAUSE OF THE RISK OF BIRTH DEFECTS. (2)
CONSUMPTION OF ALCOHOLIC BEVERAGES IMPAIRS YOUR ABILITY TO
DRIVE A CAR OR OPERATE MACHINERY, AND MAY CAUSE HEALTH
PROBLEMS.

90
United States Dept. of Agriculture | Agricultural Marketing Service

BEER
ORGANIC
Racehorse
Organic
Ale
RACEHORSE
PRINCIPAL DISPLAY BREWING
COMPANY,
PANEL MILTON, NY

Certified Organic By:


ABC Certifiers 12 Fl.Oz

Organic
Racehorse Ale
INFORMATION Contains: Water, Organic
wheat malt, Organic barley
PANEL malt , Organic Cascade hops,
and yeast

96% Organic Ingredients

GOVERNMENT WARNING: (1) ACCORDING TO THE SURGEON


GENERAL, WOMEN SHOULD NOT DRINK ALCOHOLIC BEVERAGES
DURING PREGNANCY BECAUSE OF THE RISK OF BIRTH DEFECTS. (2)
CONSUMPTION OF ALCOHOLIC BEVERAGES IMPAIRS YOUR ABILITY TO
DRIVE A CAR OR OPERATE MACHINERY, AND MAY CAUSE HEALTH
PROBLEMS.

91
United States Dept. of Agriculture | Agricultural Marketing Service

BEER Racehorse
Made With Made with

Organic… Organic Malt

RACEHORSE
BREWING
COMPANY,
MILTON, NY
PRINCIPAL DISPLAY
PANEL
Certified Organic By:
ABC Certifiers 12 Fl.Oz

Racehorse
INFORMATION
75% Organic Ingredients
PANEL
Ingredients:
Water, Organic
Malt, Organic
Hops, Yeast

GOVERNMENT WARNING: (1) ACCORDING TO


THE SURGEON GENERAL, WOMEN SHOULD NOT DRINK
ALCOHOLIC BEVERAGES DURING PREGNANCY BECAUSE
OF THE RISK OF BIRTH DEFECTS. (2) CONSUMPTION OF
ALCOHOLIC BEVERAGES IMPAIRS YOUR ABILITY TO
DRIVE A CAR OR OPERATE MACHINERY, AND MAY
CAUSE HEALTH PROBLEMS.

92
United States Dept. of Agriculture | Agricultural Marketing Service

INCORRECT
ORGANIC
PRINCIPAL DISPLAY
Vulcan
PANEL

Vodka organic

97% Organic
Ingredients

Product makes
100% organic
DISTILLED AND BOTTLED BY:
VULCAN ORGANIC SPIRITS, MT

claim and CERTIFIED ORGANIC BY:


ABC Organic Certifiers

contains 97 % .

organic
Ingredients 40% Alc./Vol. (80 PROOF)
750 ml

93
United States Dept. of Agriculture | Agricultural Marketing Service

INCORRECT MAINMAST THE LABELS MUST


Rum NOT SHOW:
PRINCIPAL
THE USDA
DISPLAY PANEL
ORGANIC SEAL
43% Alc./Vol.
750 ml THE CERTIFYING
AGENT SEAL

INFORMATION MAINMAST Rum A CERTIFICATION


PANEL 45% Organic STATEMENT
ingredients

Less than 70% BOTTLED BY MAINMAST


THE TERM
uncertified
DISTILLERS, TAMPA, FL
“ORGANIC” IN THE
product without GOVERNMENT WARNING: (1) ACCORDING TO THE
SURGEON GENERAL, WOMEN SHOULD NOT DRINK
ABSENCE OF AN
an ingredient ALCOHOLIC BEVERAGES DURING PREGNANCY BECAUSE
OF THE RISK OF BIRTH DEFECTS. (2) CONSUMPTION OF
ALCOHOLIC BEVERAGES IMPAIRS YOUR ABILITY TO DRIVE
INGREDIENT
statement A CAR OR OPERATE MACHINERY, AND MAY CAUSE
HEALTH PROBLEMS. STATEMENT

94
United States Dept. of Agriculture | Agricultural Marketing Service

8/6/2012 95

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