Sourcing and Using Ingredients In Organic Products
What To Know About Sourcing and Using Ingredients in Organic Products
Summary: To maintain organic integrity, certified organic products must be made with approved organic ingredients and only permitted non-organic materials listed on the USDA National List. You must verify certificates, maintain traceability, follow specific documentation protocols, and ensure any non-organic substances meet strict requirements. Water, salt, and carbon dioxide have special considerations.
Understanding the National List
The National List of Allowed and Prohibited Substances defines which non-organic ingredients and processing aids may be used in certified organic processing. If a material is not listed, it is not allowed.
For example, non-agricultural ingredients like baking soda, yeast, and citric acid may be permitted—but only if specifically listed.
Are there restrictions on listed substances?
Yes. Materials on the National List often come with annotations that limit how and when they can be used. These restrictions may relate to:
- Source (e.g., plant-based only)
- Form (e.g., non-synthetic only)
- Processing methods
- Ingredient composition
You must submit documentation to Oregon Tilth (OTCO) showing compliance with all applicable annotations before using the material.
Sourcing Organic Ingredients for Processing
How do I verify an organic certificate?
Every organic ingredient you purchase must come with a valid organic certificate from a USDA-accredited certifier. You can verify certificates using:
- The USDA Organic Integrity Database
- The certifier’s website
- Contacting the certifier directly
Please see this presentation on how to verify an organic certificate.
Note: Transaction certificates do not replace organic certificates.
Where can I find organic ingredients?
- Start with the USDA Organic Integrity Database
- Search industry ingredient databases
- Contact certified processors or brokers
Using Water, Salt, and Carbon Dioxide
Water and Salt
Water and salt are not considered organic and must not be included in your organic percentage calculations, unless derived from an organic source (e.g., sea salt from certified seaweed).
Carbon Dioxide
- Naturally occurring CO₂ (from fermentation) = not treated as an ingredient
- Added/synthetic CO₂ = must be documented and included in:
- Product Formulation Sheet
- Master Ingredient List (MIL)
- Specification/purity documentation
- Organic percentage calculation
Using Non-Organic Ingredients
Can I use non-organic ingredients?
Only if:
- The ingredient is on the National List
- It\’s commercially unavailable as organic
- It was not produced using excluded methods
- You obtain approval from OTCO before use
What documents do I need?
Submit the following to OTCO:
| Ingredient Type | Required Documentation |
|---|---|
| Non-organic ingredient (general) | Non-Organic Ingredient Declaration (NOID), full label, list of processing aids |
| Commercially unavailable ingredient | Commercial Availability Form |
| Natural flavor | Natural Flavor Questionnaire, H11 Form, Commercial Availability Form |
| Nutrient, vitamin, or mineral | Declaration for Nutrient Vitamins and Minerals, processing verification |
| Multi-ingredient input (e.g. vitamin) | Manufacturer’s specification sheet with ingredients and processing details |
Use the current Master Ingredient List (MIL) form for all submissions.
Note: You may need to also include a NSF / ANSI 305 Commercial Availability Form, Non-organic Ingredient Declaration, or a Agricultural or Non-agricultural Determination Sheet.
Understanding the Master Ingredient List (MIL)
The Master Ingredient List tracks all ingredients in your certified products. You must match each ingredient to a valid certificate and document:
- Certificate issue date
- Organic percentage (100%, 95%, or 70%)
- 100% Organic = 100% organic content
- Organic = 95% organic content
- Made with Organic = 70% organic content
- International equivalency info (if applicable)
Color code for tracking certificate status:
- White = current
- Orange = expiring soon
- Red = expired
For multi-ingredient inputs, you must obtain a specification sheet from the manufacturer listing:
- All sub-ingredients
- Which are certified organic
- Processing methods
Note: If you use multi-ingredient products as ingredients, request a full ingredient and processing aid list from your supplier (such as a specification sheet) to clearly show which components are certified organic and which are non-organic.
Sourcing Organic Ingredients from Uncertified Entities
Some supply chain partners—like transporters or storage facilities—may be exempt from certification under §205.101. However, you must still verify that these operations have not compromised the integrity of your organic ingredients.
Required documentation when using exempt uncertified operations:
- Maintain the organic certificate from the last certified handler
- Use the Uncertified Handler Affidavit (UHA) to document exempt status
- Submit the Independent Storage Information Sheet (IS) if applicable
- Keep all traceable records (volume, origin, activities performed)
- Clearly identify these exempt uncertified operations in your Organic System Plan and MIL
All documentation must show:
- Continuity and traceability of the organic claim
- Proper handling (no processing, packaging, or relabeling unless certified)
- Matching volume and product identity through each step
Summary Table: Ingredient Sourcing Compliance
| Topic | Key Requirement |
|---|---|
| National List | Only use non-organic ingredients on the National List with OTCO approval |
| Organic certificate verification | Must be current, from a USDA-accredited certifier, and match ingredient name |
| Water and salt | Not counted in organic percentage calculations |
| Carbon dioxide | Documented and included if added; not counted if naturally occurring |
| Non-organic ingredients | Require NOID or specific declarations and forms |
| Master Ingredient List (MIL) | Must match certificates exactly; track ingredient status |
| Uncertified supply chain partners | Use UHA and other forms to maintain traceability and compliance |