Co-Packer Information

Co-Packer Certification Requirements for Organic Products

Summary: If you are a co-packer (also called a co-manufacturer) handling products labeled as organic, you must be certified under the USDA National Organic Program (NOP). Every organic product you produce must be reviewed and approved by your certifier, even if your company does not own the product.

Documentation, inspections, and recordkeeping are required. Brand owners do not need to be certified if they only sell finished retail products.

What Is a Co-Packer?

A co-packer, or co-manufacturer, is a facility that processes or manufactures food or other products for a brand that does not own the facility. Services can include:

• Ingredient sourcing
• Product formulation
• Packaging and labeling
• Organic handling and manufacturing

Organic Certification Is Required for Co-Packers

Under the USDA National Organic Standards, any operation that handles or processes products labeled as “organic” must be certified, unless a narrow exemption applies (see 7 CFR § 205.101). If you co-pack products for private label brands and those products are labeled as organic, your operation must be certified.

✅ If you handle organic ingredients or process organic products — you must be certified.
❌ It does not matter who owns the product — certification is based on who handles it.

FAQs for Certified Co-Packers

Do we need to be certified for every product we co-pack?

Yes. Every product labeled as organic must be submitted to Oregon Tilth (OTCO) for review and approval before manufacturing begins. Once approved, the product will appear on your Organic Certificate, which you can share with the brand owner.

How do we add new co-packed products?

Follow the same steps as for adding a product you own:

Submit:

• Updated Master Products List (MPL)
• Draft label
• Updated Master Ingredient List (MIL)
• Organic certificates for suppliers
• Formulations or recipes
• Specification sheets
• Private Label Agreement (if the brand owner is not certified)
• Any additional documentation for non-organic ingredients (NOIDs, commercial availability, etc.)

A new product fee may apply — see the “Mid-Year Additions” section of our Fee Schedule.

If we don’t source ingredients, do we still need all the documentation?

Yes. As the certified handler, your company is responsible for collecting and maintaining documentation for all organic ingredients used in the product — even if the brand owner sources them. This includes:

• Organic certificates
• Ingredient traceability
• Chain of custody
• Import documentation (if applicable)

Do we have to report income from co-packing services?

Yes. Even if you don’t sell the final product, you must report fees or income earned from organic co-packing on your annual Organic System Plan (OSP) update. OTCO offers a special fee class if over 50% of your organic income comes from co-packed products. Check the [Fee Schedule] for eligibility.

Will private label products be inspected?

Yes. All organic products processed at your facility may be selected for audit during your annual inspection. You must maintain complete, organized records for each product — regardless of ownership — and make them available during inspection.

Do Brand Owners Need Certification?

Not necessarily.

• If a brand owner only receives and sells finished, retail-packaged organic products, certification is not required.
• If they relabel, repackage, or sell non-retail packaged products, they likely need certification.

Certified Brand Owners:

• May list their own certifier on the label
• Must provide a copy of their organic certificate for review
• Do not need to use the same certifier as the co-packer

Non-Certified Brand Owners:

• Must complete a Private Label Agreement with the co-packer
• Agreement must be submitted with your new product request

Summary: Co-Packer Organic Certification Responsibilities

Requirement	Co-Packer	Brand Owner
Must be certified to process organic products	✅ Yes	❌ Not if selling only finished retail products
Submit products for approval before manufacturing	✅ Yes	—
Maintain ingredient traceability and supplier certificates	✅ Yes	❌ No
Responsible for recordkeeping & inspection compliance	✅ Yes	❌ No (if not certified)
Submit Private Label Agreement (if brand is not certified)	✅ Yes	✅ Yes

Pros of Using a Co-Packer

• Lower startup costs (equipment, staff, facility).
• Potential savings on ingredients and packaging.
• Faster time to market.
• More time for marketing and sales instead of production.
• Support with regulatory compliance.
• Access to suppliers and product testing.

Cons of Using a Co-Packer

• Less direct control over production, requiring clear communication.
• Must be flexible with packaging options, scheduling, and costs.
• Risk of exposing proprietary information (use confidentiality agreements).

Finding the Right Co-Packer

• Define your processing needs, order size, and budget.
• Research co-packers that match your requirements.
• Use trade associations, industry directories, and online listings.
• Consider local options to reduce shipping costs.
• Check if they are certified organic or willing to become certified.

Meeting with Potential Co-Packers

When interviewing co-packers, discuss:

• Responsibilities and liabilities.
• Past inspection reports.
• Ingredient procurement.
• Product development support.
• Bar codes, testing, and quality control systems.
• Inventory management.
• Insurance coverage.

Building a cooperative relationship is key to success.

Protecting Your Business

• Verify licenses, certifications, and quality assurance protocols.
• Ensure traceability and recall systems are in place.
• Research background and request references.
• Consider risks of disruption (labor shortages, supply chain issues).

Helpful Resources

• Bevnet Food & Beverage University
• Contract Packaging Association
• Contract Packaging Magazine
• Food Processing Magazine
• Food Manufacturing
• Midwest Food Processors Association
• National Organic Program (NOP) Database
• OPI Kitchen Facilities Listing
• Pack Expo
• Specialty Food Association
• OPI Co-Packer Fact Sheet