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Can I label the value-added product I sell as organic?

Answer

The word organic on a retail food label is a guarantee to consumers that the entire process, from seed through field production, storage, sales and any food processing is reviewed and approved as meeting the organic regulations. Since you sell more than $5,000 per year of product that you wish to sell as organic, as the processor, you must be certified in order to use the word organic on the product label.

Organic ingredients alone are not sufficient for using the word organic on a product—the processing facility also must be certified organic. A certified food processor goes through a similar annual certification process as a farmer or rancher.

If you choose not to be certified, you may identify which ingredients are organic on your product’s ingredient list. However, you cannot label the finished product on the principal label as organic, nor use the USDA organic seal on the package.

To label your finished beverage something like “Organic Roasted Vanilla Coffee,” all ingredients or inputs either must be certified organic or on the National List of approved ingredients if they are synthetic. Recipes for each product you wish to label as organic, along with the production methods, needs to be included in your Organic System Plan that a certification agency will review.

Sanitation and pest management materials and protocols must also be documented. Processed organic food products have their own sections on the National List of approved pest control inputs, sanitation products, ingredients and more. Reviewing an organic certifier’s organic system plan will provide you with the information you need to prepare the necessary documentation if you decide to become certified. Pay special attention to the organic regulation section on labeling, which specifies the colors of the USDA organic seal, font size of the word organic and placement of your organic certifier’s name.

If you grew, processed and sold less than $5,000 in annual sales of organically labeled products, then, under the small operator exemption from certification, you could label the product as organic without going through and achieving organic certification. You would still need to follow all of the organic regulations, including use of approved sanitation materials and processes, approved pest management strategies, documentation that all ingredients were either certified organic or on the National List, etc. Again, a review of a sample Handler Organic System Plan would help you prepare and maintain the records you need to have to meet the law. You still could not use the USDA organic seal on your package—that is reserved for certified organic operations only. Most organic certification agencies have Handler Organic System Plans on their websites.

The National Organic Program regulations are here . Since each product and process is unique, it would be best to contact the Marbleseed Organic Answer Line if you have more questions.

Posted: Dec 2007
Answer By: Harriet Behar