Multiple ingredient products
#Documentation for ingredients
Maintaining thorough and appropriate records for your product’s ingredients is critical for an inspector and certification reviewer to audit and verify compliance. You must collect, organize and provide declarations and affidavits to validate the integrity and sourcing of your ingredients.
We’ll examine your documentation to check the composition, manufacturer and production process for each ingredient to determine compliance with organic regulations.
If your ingredient will be sourced internationally, you must review our international imports policies and protocols for at-risk products.
Required documentation and forms
- For multi-ingredient ingredients (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
- For certified organic ingredients, you must maintain a valid organic certificate
- For all non-organic ingredients with commercial availability restrictions, you must first demonstrate an organic version is unavailable through completion of a Commercial Availability Form showing outreach to at least three suppliers of an organic version of the ingredient
- For non-organic ingredients, you must demonstrate it is produced using only approved methods and follows restrictions, with a Non-Organic Ingredient Declaration (NOID) — unless your ingredient is a natural flavor, vitamin, or mineral
- For a natural flavor, you must submit a Natural Flavor Questionnaire (instead of a NOID), and verify it is produced using only approved methods or following restrictions per the organic requirements
- For a vitamin or mineral, you must submit a Declaration for Nutrient Vitamins and Minerals (instead of a NOID), and verify it is produced using only approved methods or following restrictions per the organic requirements
Forms & Documents
Commercial Availability Form
Natural Flavor Questionnaire
Download the above and submit it to your client service team.
#Using approved materials
The National List of Allowed and Prohibited Substances defines which non-organic substances are allowed and which agricultural substances are prohibited for use in organic crop, livestock, and processed food production. For processors, the National List covers non-agricultural materials for use as ingredients and processing aids, including baking soda, yeast and citric acid.
If a non-agricultural material is not approved for use on the National List, it is not permitted in organic production.
Do not risk jeopardizing your certification. Never use an unapproved material until after OTCO review and approval is granted.
Learn more on adding (or removing) an approved material, including how to determine if it is approved for use in processing. Always be sure to check that the desired material is approved for processing — some materials may be approved for use in only one certification scope (e.g., crops not processing).
#Calculating percentage of organic content
When formulating a multiple-ingredient product, you must calculate the percentage of organic content to determine the organic certification category of the end product. Before you can do this though, you first have to determine the organic content of each of the individual ingredients that make up your product formulation.
This is where your Master Ingredient List (MIL) comes into play. Your MIL is used to track important information about all of your organic ingredients. Before you get started, make sure the information on your MIL is updated to all your current supplier certificates. Along with your updated MIL, you’ll need a blank Product Formulation Sheet (PFS).
First, copy all the ingredients for your product from your MIL onto your product formulation sheet. Make sure the ingredient name on your certificate matches the ingredient name on both sheets exactly.
For example: if the ingredient is listed on your MIL as OG Soft White Wheat Flour be sure to list the ingredient as OG Soft White Wheat Flour on your PFS.
Your supplier certificate has all the product information you need to correctly fill out your MIL. The supplier certificate will break down ingredients into three potential categories, which are used to correctly identify the organic content percentage of each ingredient. The percent equivalents are as follows:
- 100% Organic = 100%
- Organic = 95%
- Made with Organic = 70%
Next list the percentage of organic content of each of your ingredients. This information is located on your MIL and your supplier certificate, check out our article on using and updating your MIL if you are unsure how to identify the percentage of organic content for any of your organic ingredients.
After you have all of your organic ingredient information, list all non-organic ingredients that will be used in the product (excluding water and salt) within the Ingredient column of your PFS.
Understanding ingredients vs. processing aids in calculations
You do not need to include processing aids in the weight of your organic ingredients or your combined ingredients. So, what’s the difference between an ingredient and a processing aid?
The USDA National Organic Program (NOP) defines an ingredient as:
Any substance used in the preparation of an agricultural product that is still present in the final commercial product as consumed
The USDA NOP defines a processing aid as:
- A substance that is added to a food during the processing of such food, but is removed in some manner from the food before it is packaged in its finished form
- A substance that is added to a food during processing, is converted into constituents normally present in the food and does not significantly increase the amount of the constituents naturally found in the food
- A substance that is added to a food for its technical or functional effect in the processing but is present in the finished food at insignificant levels and does not have any technical or functional effect in that food
Percentages for organic calculations are always rounded down to the nearest whole percent (e.g., 94.7 percent would be 94 percent).
Now that all of your product ingredients are listed within your PFS, you will list each ingredient’s total percentage within your product. The PFS will then use the information you’ve entered to calculate the percent organic content for your product, which you will use to determine your labeling.
Formula for calculating organic content
To determine the percentage of organic content in your multi-ingredient product, use the following formula:
Total net weight or volume of combined organic ingredients*
Total weight of all combined ingredients*
* Excluding salt and water
Still unclear? Questions? Reach out to your client service team for help.
#Allowed and prohibited processes
For the most part, common mechanical and biological processing used for multiple-ingredient products is allowed under the USDA National Organic Program (NOP). However, there are specific actions and technologies that are prohibited in organic food processing.
OTCO recommends you always notify us prior to purchase of new technology to determine compliance of the new equipment, device, and its processing actions.
- From ingredients to product: Cooking, baking, curing, heating, drying, mixing, grinding, churning, separating, distilling, extracting, slaughtering, cutting, fermenting, eviscerating, preserving, dehydrating, freezing, chilling or otherwise manufacturing
- From product to retail: Packaging, canning, jarring and otherwise enclosing food in a container
- Advanced methods: High pressure processing, infrared dehydrating/ cooking, freeze drying and various purification technologies
The USDA NOP allows — applicable to organic and allowed non-organic materials — for organic products to use only approved methods and follow all restrictions for a material. Prohibitions include:
- Use of all unallowed non-organic, non-agricultural substances (per the National List)
- Use of genetic modification and/or genetic engineering
- Use of ionizing radiation
- Use of sewage sludge