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. You must also submit a 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).
  • 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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