Labeling and packaging

#Packaging

In general, you have a lot of options — and some clear restrictions — for packaging and labeling your organic product, but there are a few key things to keep in mind:

Forms & Documents

Please note: If you applied for certification using our Online OSP via SOW Organic, you can make all of your OSP updates and requests through your account. All others should download the above and submit it to <http://www.privatedaddy.com/?q=X1RXWEl0S2pIDDhJa3lnAxVscGlvDAIBIUViV29X_19>.

If you are receiving, packaging, and shipping products have a plan in place to make sure the organic product you received is the same one that was packed, labeled and shipped as organic. Your records demonstrate compliance and support full audit traceability of a product and its ingredients.

Note

An example of verification of “product in, product out” is an operator receiving blueberries from several farms that are packed and shipped to grocery stores. The operator must demonstrate that the blueberries sent to the retailer are the same product that was sent from the farm.

#Adding new labels and label revisions

Alert

While we understand the temptation to print unapproved labels to act quickly in your production, simply put: don’t. Using a non-compliant label can result in loss of product sales, recalls, and risk of losing your certification. Whenever you have a new label or changes to an existing one, do not print or use it until after receipt of OTCO review and approval.

Updating a label for an existing product
Each time you need to add a new label or make changes to an existing product label, you must submit your label to OTCO for review and approval prior to use.

Bulk labels
OTCO may be able to accept a label template for use and application on bulk labels, but we require that updates or new bulk label templates be submitted for review and approval prior to use.

Tip

Check out our Labeling and Composition Guide to learn more about requirements that differ depending on the “organicness” of your product(s).

Pre-approval of labels for new clients or products
We are happy to review and issue pre-approval of a label if you’ve submitted an Organic System Plan (OSP) or product addition for review. However, the approval will only verify that the label itself is compliant with the standards. A thorough review (e.g., ingredient verification, formulation, etc.) of your OSP is required to determine if the product itself is compliant. It’s possible that changes occurring during the review of your product might require a change to your label. Our certification services team is available to discuss label questions, even prior to submission of your OSP at:

Contact our Farmer Hotline at: (503) 581-8102 or (503) 378-0690 Ext. 102 or <http://www.privatedaddy.com/?q=SUdKVkl1UGpOCD5TYlB9DzlscSt0FktiV29X_19>
Contact our Processor Hotline at: (541) 368-7645 or (503) 378-0690 Ext. 101 or <http://www.privatedaddy.com/?q=X1RXWEl0S2pIDDhJa3lnAxVscGlvDAIBIUViV29X_19>

Note

It’s important that the ingredients on your new label match ingredients as listed on your Product Formulation Sheet and Master Ingredient List.

#USDA National Organic Program

Alert

Do not risk jeopardizing your certification or making costly mistakes with reprinting or repackaging your organic products. Never print or use labels prior to receipt of OTCO approval.

USDA National Organic Program certified products must follow rigorous production and labeling requirements. In addition to seal placement, mandatory ingredient information, size and organic claims, the labeling of your certified product depends upon the percentage of organic ingredients in your product. To get started, you’ll first want to calculate the percentage of organic ingredients for your product.

Resource

OTCO’s Organic Labeling and Composition Guide provides a one-stop quick reference for all of your labeling questions, from bulk labeled single ingredient products to complicated multi-ingredient processed products.

Depending on your product’s percentage of organic content, you may (or may not) make certain organic claims on specific parts of your product label. However, in all cases the Oregon Tilth logo must not be displayed larger than the USDA organic seal. Remember, you can always reference our labeling guide to learn more about requirements that differ depending on the “organicness” — “100% organic,” “organic,” “made with organic” or “contains organic ingredients” — of your product(s).

Tip

You can download the USDA organic seal on their website, as well as find a selection of Oregon Tilth’s approved for use logos.

Once you have finalized your label composition, submit it to OTCO for review and approval prior to use. Send label requests by email at <http://www.privatedaddy.com/?q=X1RXWEl0S2pIDDhJa3lnAxVscGlvDAIBIUViV29X_19> or fax at (541) 753-4924.

Note

OTCO does not review labels for the Food and Drug Administration (FDA) or other agencies with labeling requirements.

For more details, please refer to our webinar on Product Composition and Labeling for 100% Organic and Organic.

#Transitional

Use of the Oregon Tilth Certified Transitional logo on packaging is allowed for operations certified by our transitional program. It may not be used with the USDA organic seal or use the word “organic” on anywhere on product’s principal display panel. No modifications to the Oregon Tilth Certified Transitional logo are allowed (e.g., color, fonts, orientation or distortion of shape).

Resource

Download the Oregon Tilth Certified Transitional Logo in our logos section.

Once you have finalized your label composition, submit it to OTCO for review and approval prior to use. Send label requests by email at <http://www.privatedaddy.com/?q=X1RXWEl0S2pIDDhJa3lnAxVscGlvDAIBIUViV29X_19> or fax at (541) 753-4924.

#International

Alert

It is important to make sure your labels are in compliance with all international requirements of the destination country for your exported products.

For international organic certification programs, products must follow rigorous production and labeling requirements. In addition to seal placement, mandatory ingredient information, font size, and organic claims, the labeling of your certified product depends upon the percentage of organic ingredients in your product. To get started, you’ll first want to calculate the percentage of organic ingredients for your product.

Note

It is important to make sure your labels are in compliance with all international requirements of the destination country for your exported products.

Canada Organic Regime (COR)

The COR seal may only be used on products with 95-100 percent organic content. For eligible organic products, the seal must be displayed in accordance with Canadian Food Inspection Agency (CIFA) requirements as detailed on the CIFA website. Learn more about the labeling requirements for COR-certified products in our Canada Organic Labeling and Regulations Guide.

Contact OTCO by email at <http://www.privatedaddy.com/?q=X1RXWEl0S2pIDDhJa3lnAxVscGlvDAIBIUViV29X_19> or call our Processor Hotline at (503) 378-0690 ext. 101 to submit a request for use of the COR seal.

Alert

When not in compliance with NOP requirements (labeled for Canada only), containers and shipping documents must be labeled “For Export Only.” 

Product imports (to Canada)
All products imported into Canada using the COR Seal must include the phrase “Imported”, “Imported From (country of origin)”, or “Product of (listed country of origin)” in close proximity to the COR seal. The required phrasing is required to be in close proximity to one instance of the seal but may be used multiple times on the product display panel.

All imported products packaged and labeled in Canada — provided no processing steps that modify the nature of the product occur in Canada — must also include the required import designations (see above).

Mexico Organic Program (LPO)

Labels for Mexico Organic Program certified products must follow several requirements for each organic category. For a detailed listing for each category and full descriptions of how to use and place the SAGARPA organic seal, view our Organic and Labeling Composition Guide for Mexico Organic Regulations.

European Union (EU)

Labels for EU Organic Program certified products must follow several requirements for each organic category. The European Commission offers details regarding use restrictions and high-resolution versions of the seal, in addition to a user manual. Additionally, you may review requirements for each organic category in our Organic and Labeling Composition Guide for the EU.

Once you have finalized your label composition, submit it to OTCO for review and approval prior to use. Send label requests by email at <http://www.privatedaddy.com/?q=X1RXWEl0S2pIDDhJa3lnAxVscGlvDAIBIUViV29X_19> or fax at (541) 753-4924.

Note

OTCO does not review labels for the Food and Drug Administration (FDA) or other domestic and international agencies with labeling requirements.

#NSF

The NSF/ANSI 305 Personal Care standard is a private, specific organic standard for personal care products. The labeling allowances for this certification only cover “contains organic ingredients” claims.

Alert

Do not risk jeopardizing your certification or making costly mistakes with reprinting or repackaging your organic products. Never print or use labels prior to receipt of OTCO approval.

Your product must contain at least 70 percent organic ingredients — excluding mined minerals, water, and salt — to use the allowed organic claim on your label. Please note that all organic ingredients in your product must be certified to the USDA National Organic Program (NOP), standards recognized as equivalent by the USDA NOP, or EC 834/2007 and EC 889/2008. You may calculate the percentage of organic content of your product using our Personal Care Product Formulation Sheet.

Resource

You must follow all of the labeling requirements for NSF/ANSI 305 certified products, as noted under the “made with organic” category (page 3) in our Organic Labeling and Composition Guide.

Basic NSF/ANSI 305 labeling requirements

  • Ingredient statement lists all organic and non-organic ingredients following INCI requirements
  • Organic ingredients identified clearly as “organic” in the ingredient listing
    Non-organic ingredients identified clearly
  • Ingredients produced by an approved process may be identified as “contains organic ingredients”
  • Product certifier identified on the information panel, below or next to the information identifying the handler or distributor of the product and after the phrase “Certified to NSF/ANSI 305 by…” or similar phrase

Allowed NSF/ANSI 305 labeling practices

  • Information panel may use “Contains organic [specified ingredients or ingredient groups],” provided that the statement does not list more than three organically produced ingredients and follows all text size and styling requirements
  • Percentage of organic ingredients in the product may be listed and must follow all text size and styling requirements
  • Certifying agent seal(s) may be used
  • NSF/ANSI 305 Personal Care Product standard logo may be used

Prohibited NSF/ANSI 305 labeling practices

  • Use of USDA National Organic Program seal
  • Product or individual ingredient identification as “certified organic”
  • Implication of certification to any organic standards other than NSF/ANSI 305
  • Identification of any ingredients as “organic” when are certified as “contains organic ingredients”

Once you have finalized your label composition, submit it to OTCO for review and approval prior to use. Send label requests by email at <http://www.privatedaddy.com/?q=X1RXWEl0S2pIDDhJa3lnAxVscGlvDAIBIUViV29X_19> or fax at (541) 753-4924.

Tip

NSF will supply you with logos after your certification, you can find all the Oregon Tilth logos you need in our logos section.

Note

OTCO does not review labels for the Food and Drug Administration (FDA) or other agencies with labeling requirements.

#GOTS

GOTS certification carries specific licensing and labelling conditions. Each label “grade” has specific wording to be used in conjunction with the GOTS logo.

Resource

Learn more about GOTS labeling requirements from the GOTS Licensing and Labeling Guide.

Sample GOTS Logo for Help Center

Per the above sample, the following information is required:

  • ‘Organic’ is the label grade (95 percent or greater)
  • “Certified by…” is the certifier reference (e.g., Certified by OTCO)
  • “License number” is a certifier issued number for each GOTS client

Note

Your license number is linked to the GOTS database and allows customers, buyers, and the general public to find your business listing and check that your operation is certified and what GOTS products are available.

Use of the GOTS logo is not permitted if the product is not certified to its standards. Logo use must always include the label grade, “certified by” statement and license number.

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