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What Are The Requirements for Multi-Ingredient Organic Products
Summary: If your product has more than one ingredient, you must calculate the percentage of organic content to determine how it can be labeled under USDA Organic regulations. This article explains how to do that, which processes are allowed or prohibited, and which forms you need to complete.
Why You Need to Calculate Organic Content
If you’re making a multi-ingredient product, calculating the percentage of organic content is essential for determining your product’s organic labeling category under the USDA National Organic Program (NOP):
| Label Category | Minimum Organic Content |
|---|---|
| 100% Organic | 100% organic ingredients |
| Organic | At least 95% |
| Made with Organic | At least 70% |
Products with less than 70% organic content cannot be labeled as organic but may list organic ingredients in the ingredient panel.
Do I need to include everything I use to make my product in my calculations?
Yes, under SOE anything that goes into a product (including processing aids) must be included in the formula and will impact the calculated weight for organic status. This includes processing aids that are added but then removed, such as organic alcohol used as an extraction material that is then distilled off leaving only the extract behind. Exceptions are processing aids that are never added to the product, such as a charcoal filter that the product is passed through. Note that processing aids and ancillary ingredients do not need to be listed on the finished product label.
What to Include (and Exclude) in the Calculation
Include:
- All agricultural ingredients (organic and non-organic)
- Processing aids that are added to a product, whether they are or are not removed
Exclude:
- Water
- Salt
- Processing aids that are not added to the product e.g. charcoal filter
What Is a Processing Aid?
A processing aid is not considered an ingredient. It may be used during production but does not significantly remain in the final product or does not have a technical effect in the final product.
According to the USDA NOP, a substance is a processing aid if it:
- Is removed before packaging,
- Is transformed into a naturally occurring component of the food, or
- Remains in the food at insignificant levels with no technical function.
How to Calculate Organic Content
Step 1: Update Your Master Ingredient List (MIL)
Start by making sure your MIL is up to date with:
- The correct ingredient names (matching supplier certificates)
- Valid organic certificates for all organic ingredients
Step 2: Complete a Product Formulation Sheet (PFS)
Download blank PFS form, here.
Use your MIL to copy all the ingredients for the product into your PFS:
- List organic and non-organic ingredients and processing aids
- Note that water and salt have their own cells and their percentages should be included there
- Calculate the percent of each ingredient by dividing the weight of each individual ingredient by the total weight of all ingredients (based on what goes into the product)
Make sure the ingredient name on your certificate matches the ingredient name on the MIL and PFS sheets exactly.
Step 3: Add the Organic Percentages of Individual Ingredients
Get this information from:
- The supplier’s organic certificate, or
- Composition/specification sheets from the ingredient supplier
- Note that the organic content percentage of any organic ingredient must be rounded down to the nearest whole number
Step 4: Processing Aids
- Processing aids that are added to the product and remain in the product: list in the ingredient table on the PFS
- Processing aid will appear on finished product label ingredient statement
- Processing aids that are added to the product and removed/not present at significant levels in the finished product: list in both the ingredient table and processing aid cell on the PFS
- Processing aid will not appear on finished product label ingredient statement
- Processing aids that are never added to the product (e.g. charcoal filter): list only in the processing aid cell of the PFS
- Processing aid will not appear on finished product label ingredient statement
Required Forms
To complete your product review, submit these forms to your client services team:
Allowed Processes for Multi-Ingredient Organic Products
The following processing methods are generally allowed under the USDA National Organic Program:
From ingredients to finished product:
- Cooking
- Baking
- Drying
- Grinding
- Mixing
- Fermenting
- Extracting
- Distilling
- Freezing
- Chilling
Packaging and preservation:
- Canning
- Jarring
- Packaging
Advanced methods:
- High-pressure processing
- Freeze-drying
- Infrared cooking
- Purification technologies
Note: If you’re using a new or advanced processing method or piece of equipment, notify your certifier first to confirm compliance.
Prohibited Processes in Organic Products
The following are not allowed under USDA Organic regulations:
- Genetic engineering (GMOs)
- Ionizing radiation
- Sewage sludge
- Use of non-approved synthetic substances (refer to the National List)
Summary
If you’re producing a multi-ingredient product, you must:
- Calculate the percent organic content to determine the correct labeling category (this is automatically calculated on the PFS in the bottom right red cell),
- Use only approved processing methods,
- Note that water and salt are excluded from organic content calculations,
- Submit accurate and complete documentation.
If you’re ever unsure about an ingredient or processing method, check with your certification team before proceeding.