Using non-organic ingredients

Can I use non-organic ingredients in my product?

Yes, in certain cases with specific documentation. The USDA National Organic Program allows for a limited number of non-organic ingredients to be used in organic labeled products, if the:

  • Ingredient is a listed, acceptable commercially non-available restricted ingredient
  • Ingredient was not produced using organic excluded methods
  • Ingredient is allowed per the National List

What records do I need for allowable non-organic ingredients?

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. All non-organic ingredient submissions must include the full label including the brand and manufacture’s name for the product. For most non-organic ingredients and processing aids, submit the Non-Organic Ingredient Declaration (NOID) to ensure the ingredient was not produced using organic excluded methods.

A few exceptions include:

  • 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). You will need to fill out an H11 (as well as the NFQ that is already listed), and you must be on the current MIL form. You can download the H11 and MIL forms below.
  • 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.
  • If your non-organic ingredient is a multi-ingredient product (e.g., vitamins)…
    You must submit a manufacturer specification sheet listing all ingredients found in the ingredient, as well as any processing methods used to produce it.

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