A co-packer, also known as a co-manufacturer, is an operation that offers manufacturing/handling services for products and brands not owned by them. Such services may include sourcing ingredients, formulation development, processing,
re-packing, labeling, storage and shipment.
Under the NOP National Organic Standards, any handler engaged in the manufacturing of products labeled as organic needs to be certified, regardless of who owns the final product. A few narrow exemptions and exclusions from certification are outlined in Section 205.101, but in general, if your operation would like to offer organic handling services to private label brand owners, your operation needs to be certified.
If our company is the co-packer, do we have to be certified for each product we co-pack?
Yes, each product being labeled or represented as organic needs to be submitted to your certifier for review and approval prior to manufacturing, regardless of who owns the final product. Once approved, new products will be added to your Organic Certificate which you can then share with the brand owner.
Future changes to products, labels, or formulations also need to be submitted to your certifier for review and approval.
How do we add new products to our certificate?
The process for adding a new co-packed product is the same as adding a product you own. A new product submission should include an updated Master Products List (MPL), copy of the draft label, and, as needed, an updated Master Ingredient List (MIL), suppliers’ organic certificates, Specification Sheets, formulations for multi-ingredient products, a Private Label Agreement and any information needed to review non-organic ingredients, such as Non-Organic Ingredient Declarations (NOIDs), Commercial Availability information and ingredient labels. Blank forms and more information can be found on our website.
A new product fee may be charged, please refer to “Mid-Year Additions” in our Fee Schedule for more information.
Since our company is not responsible for sourcing ingredients, do we have to have all of the information associated with products we don’t even own?
Yes, as the certified operation, it is your responsibility to collect, submit and maintain documentation verifying the organic status of ingredients used in organic products. This includes traceability through the chain of custody back to the last certified entity, which may include import documentation even if your operation is not arranging the importation.
Do we have to report sales of products we don’t own?
Although co-packers do not necessarily sell final products they do not own, any income/fees received from the co-packing service of organic products does need to be reported to your certifier on your annual renewal/OSP update as organic income. OTCO offers a special fee class if more than 50% of your gross organic income is from co-packed products. Please refer to our Fee Schedule for more information.
Will private label branded products be audited during my inspection?
Any organic products being handled at a certified operation may be selected for a production audit. Complete records must be made available during each inspection for all organic handling. More information on the general types of records needed can be found on our website.
Does the brand owner need to be certified?
No, if they are not doing any physical handling, re-packing, re-labeling, they are not required to be certified. However, they may choose to become certified, and the benefits of this option are discussed here.
If the brand owner is certified, they have the option to list their certifier on the label. A copy of their certificate must be included with your submission to your certifier if they are certified. The brand owner and the co-packer do not need to be certified by the same certifier.
If they are not certified, a Private Label Agreement must be completed and signed by representatives of both the brand owner and co-packer and submitted with your new product request.