Add a new product to certification

How do I add a product?

When adding or updating a product to your organic certification, you will be required to provide different records depending on the type of product. However, a few important guidelines apply to all product types and request scenarios.

  1. Submit your new label
    Every product addition will require you to submit all your new label(s) for each product to our team for review. Always have your labels reviewed prior to printing/manufacture.
  2. Update your Master Ingredient List
    Be sure to check that your supplier certificates or Non-Organic Ingredient Declarations (NOIDs) are also up-to-date in your Master Ingredient List (MIL). The certificate issue date cell in your MIL will turn orange (ingredients close to being out of date), red (ingredients out of date), or white (ingredients are current).
  3. Update your Master Products List (MPL)
    The MPL is where you’ll add new product(s), and it should also contain all products already on your certificate. Make sure your ingredients and names match across all of your labels, certificates, and forms, such as your Product Formulation Sheet if you are required to use one.

What if my product includes non-organic ingredients?

You must follow the same process for adding a new non-organic ingredient.

To start, submit all non-organic ingredients to OTCO for approval prior to use, including the manufacturer’s full list of ingredients and/or processing aids that went into creating the ingredient. You must also submit a Non-Organic Ingredient Declaration (NOID) to ensure the ingredient was not produced using organic excluded methods (with a few exceptions outlined below).

  • If your non-organic ingredient has commercial availability restrictions…
    You will need to demonstrate an organic version is unavailable through the completion of a Commercial Availability Form.
  • If your non-organic ingredient is a natural flavor…
    You must submit a Natural Flavor Questionnaire (in place of a NOID), and verify it is produced using only approved methods or following restrictions per the organic requirements.  Additionally, use of non-organic natural flavors requires a Commercial Availability Form (see March 2019 Notice).
  • If your non-organic ingredient is a nutrient, vitamin or mineral…
    You will complete the Declaration for Nutrient Vitamins and Minerals in place of the NOID, as well as verification it is produced using only approved methods.

What if my product has multiple-ingredients?

In addition to the above requirements, you must submit a Product Formulation Sheet for all multi-ingredient products — you can read more about multi-ingredient products here.

Please note that if you use multiple-ingredient products as an ingredient, you must work with your supplier to obtain a manufacturer’s full list of ingredients and/or processing aids that demonstrates which are organic and which are non-organic (i.e., a specification sheet).

Does my product addition require an inspection?

Not all product additions require an inspection. Typically, if the new product is made using equipment, facilities, and processes that are part of your existing OSP, no additional inspection is required. However, for any product made using new equipment or facilities, you must update your OSP appropriately and an inspection will be required.

What do I need to know if my new product is for export?

If you plan to export your new product, let us know when you submit your product composition and labeling information. OTCO will then preapprove your product for export.

Waiting to request approval for exporting a product until it is already in transit may cause costly delays.

Tip

Depending on your product addition, you may find our articles on adding a label, calculating the percentage of organic content, updating your Master Ingredient List.

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