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Organic transformation

Oregon Tilth's processing gurus explain all

By Connie Karr and Gwendolyn Wyard

At the Oregon Tilth office, we often get phone calls that start with an eager voice saying, “I have a really great product that I want to take organic. What do I need to do?” It is always fun to have this conversation, but it can also be exhausting as there is so much to cover! So, we decided it’s time to put the basics of this conversation in writing using a fun product - pudding. Why not? Pudding is fun and who hasn’t tried it or at least finger-painted with it once in their life?

The Label

How do you want to label your product? This will shape the rest of your decisions. If you want to call your product “Organic Chocolate Pudding,” or use the USDA Organic seal, then your product formulation needs to contain at least 95 percent organic ingredients and the other five percent must be listed on Section (§)205.605 or §205.606 of the National List (hang in there, we will explain this in a minute).

If you want to label your product as “Pudding, Made with Organic Milk and Sugar,” then the composition requirements are going to change a little. You will need a minimum of 70 percent organic ingredients and there is a bit more flexibility in the other 30 percent, primarily the allowance of non-organic agricultural ingredients.

It is always good to first decide your marketing goal (hence, the label) and then figure out if and how you can get there.

Label Considerations

Below is a quick-glance summary of composition and labeling requirements for products making oranic claims. We covered 2 of the 4 listed categories on this chart. The pudding example we're using includes a non-organic ingredient, therefore the 100 percent organic claim is not possible. The "less than 70 percent category" canot make an organic claim on the front panel, or make reference to certification - organic claims may appear in the ingredient panel only for such products.


Let’s consider your ingredients. Can you source enough organic ingredients to get the label claim you want?

If you are going for that “Organic Chocolate Pudding” claim, then you must have at least 95 percent organic content at formulation (excluding water and salt). Furthermore, all agricultural ingredients in the product will need to be organic (milk, sugar, cocoa, starch) or specifically listed on §205.606 which lists the non-organic agricultural ingredients allowed only if they are commercially unavailable in organic form. Commercial availability is defined as the ability to obtain a production input in an appropriate form, quality, or quantity to fulfill an essential function.

If you cannot find organic cocoa, for example, in the form needed for your product, the cocoa would need to be listed on
§205.606 of the National list and commercially unavailable in organic form. Currently there are 43 ingredients listed, and several are annotated with additional restrictions (i.e. annatto extract – water and oil soluble).

Any non-agricultural item would need to be listed on §205.605. Non-agricultural substances are not products of agriculture, such as minerals or bacterial cultures. Unlike ingredients listed on § 205.606, commercial availability does not apply to non-agricultural ingredients. For example, in pudding, carageenan is used as a thickener and is allowed under §205.605 without an annotation (restriction). Always be sure to locate your non-agricultural ingredients (or processing aids) on this list and check whether there are any particular restrictions on them.

Now, if you want to label your product as “Pudding, Made with Organic Milk and Sugar,” then you will need to have a minimum 70 percent organic content (excluding water and salt). In this label category, you can use non-organic cocoa without it being listed on §205.606 and despite its availability as organic. However, any non-agricultural items, like carageenan, would still have to be on §205.605.

The one common prohibition to all ingredients, on or off the National List, is the use of excluded methods (such as GMO’s, ionizing radiation, and sewage sludge). Documentation verifying that these methods have not been used is required for all non-organic ingredients used in “organic” or “made with” products.

Sourcing ingredients can sometimes be one of the greatest challenges. Where would I find organic cocoa? How do I find enough organic milk? There is help out there – don’t fret. You can call Oregon Tilth, and we will provide you with a list of operators we certify for particular ingredients. You’ll also want to do your Internet research. The Internet can yield a source for almost any ingredient you are seeking. For those even-harder-to-find ingredients, there are online listings of organic products and ingredients at and These sites have proven helpful to many folks struggling to find organic ingredients.


Now that you are aware of the basic composition requirements for your product, we should discuss the requirements surrounding production. Organic certification is not just about making your product’s composition and label comply, it is also about how it is produced, and the ability to maintain product integrity throughout storage, production and distribution.

One of the most common questions is whether the entire production facility needs to be organic. The answer is no, but you do have to implement practices in order to prevent any sort of contamination of your organic product (i.e. sanitizers and pest management materials), and protect the organic goods from any sort of commingling (i.e. contact or blending with non-organic ingredients/products).

There are many ways to accomplish this and the regulations require that you create and implement a plan describing how the integrity of the organic product will be preserved. Your certifier will review and verify implementation of this plan. Below is a list of common commingling/contamination preventative practices:

   1. Keep organic ingredients in a separate area that is clearly marked. It doesn’t necessarily have to be a separate room or have a physical divider, just needs to be clear and easily distinguishable for employees.

   2. Properly clean and sanitize processing lines prior to running organic to make sure that non-organic material is removed from all food contact surfaces. Many operators will schedule organic production as the first run of the day or immediately after complete equipment clean down.

   3. Sanitize with non-residual sanitizers and do a thorough rinse of chemical cleaning agents to ensure they do not contaminate the organic product.

   4. Implement an equipment line purge using organic product. This can be expensive, but may be the only way to clean certain types of equipment. Examples include flour mills and oil refining operations where water and sanitizers just aren’t an option. The purge will ensure that conventional product is adequately removed from equipment and lines prior to establishing the start point for organic. The organic material used for the purge is then sold as non-organic.

These are the just the most common examples. The bottom line is to come up with a plan that works for you and your system! The plan should be easily implemented and ensure organic product integrity.


Once you have a good understanding for label, product composition and production requirements, and feel you can meet these requirements, the next step is certification. This entails a simple five-step process: of application, inspection, review, resolution and certification.

Everything you need to know about this process can be found on our website at:

There are many more questions that can be asked; believe us, we know. But hopefully this article provides a good basic start if you are thinking of taking your product to the organic market. Good luck, have fun, and remember we’re only a phone call or computer click away!

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