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Can I use non-organic ingredients in my product?

Yes. The NSF/ANSI 305 standard allows for a limited number of non-organic ingredients to be used in your personal care product, providing:

• Non-organic ingredients make up no more than 30 percent of the product composition
• Non-organic ingredients were not produced using organic excluded methods
• Non-organic ingredients are on the USDA NOP’s National List of allowed materials (unless it is exclusively allowed for use in food applications)
• Non-organic ingredients are a non-organic agricultural input
• Non-organic ingredients are botano-chemicals

What documentation do I need for allowable non-organic ingredients?

Start by submitting a manufacturer completed NSF/305 ANSI Questionnaire. Depending on the non-organic ingredient you are using, you will need to submit supporting documentation.

You will need to demonstrate an organic version is unavailable by completing a Commercial Availability Form for certain non-organic ingredients:

• All non-organic ingredients with commercial availability restrictions
• All non-organic ingredients created by saponification, transesterification, or hydrolysis
• All botano-chemical ingredients

How do I find organic ingredients for my NSF/ANSI 305 product?

You can use any organic ingredient certified to the USDA NOP or EU standards.

How do I verify an organic certificate?

Before you purchase ingredients for your product, confirm the validity of the organic certificate for each product or ingredient.

Transaction certificates can’t be used in place of a valid organic certificate.

Since organic certificates are issued by USDA NOP-accredited certifiers, start your certificate verification process with the USDA Organic Integrity Database. Once you’ve established which agency certifies your ingredient you can review the listed certifier’s website (or call the certifier directly). Always observe any additional requirements for imported organic products.

What do I need to have on my label?

NSF/ANSI 305 requires certain information to be displayed on a product label, including:

• Ingredient statement listing all organic and non-organic ingredients using the International Nomenclature for Cosmetic Ingredient (INCI) labeling system.
• Clearly distinguish “organic” ingredients produced in accordance with the National Organic Program requirements from those produced in accordance with the NSF/ANSI 305 Standards. 
  • Example: Ingredients: Aqua (Water), Aloe Barbadensis (aloe vera) Extract*, Sodium Coco Sulfate**, Coco Glucoside**, Hydrolyzed Soy Protein*, Benzoic Acid.
    * Organic, **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

What optional information can I put on my label?

• “Contains Organic Ingredients”
• “Contains organic [specified ingredients or ingredient groups]” provided the statement does not list more than three organically produced ingredients
• Percentage of organic ingredients in the product including, “Contains X% organic ingredient”, “X% Organic” and “X% Organic Ingredients”
• OTCO logo (provided it does not say “certified organic”)
• NSF/ANSI 305 Personal Care standard logo

What information am I not allowed to have on my label?

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

Can I use/print labels prior to approval?

Always submit your labels to OTCO before you print them — even if the change was small. Don’t risk reprinting and repackaging a product due to an unapproved label. Product sales with unapproved labels could jeopardize your certification.

Once you have finalized your label composition, submit it to OTCO for review and approval prior to use.

Why do I need to calculate the percentage of organic content in my product?

All NSF/ANSI 305 personal care products must be at least 70 percent organic. Formulations for multiple-ingredient products require a calculation of the organic percentage of the end product to determine compliance.

Do I need to include everything I use for my product in my calculations?

You don’t need to include processing aids in the weight of your organic ingredients or your combined ingredients. It’s important to understand the difference between a processing aid and an ingredient.

An ingredient is:

• Any substance used in the preparation of an agricultural product that is still present in the final commercial product as consumed

A processing aid is:

• A substance that is added to a product during the processing of the product, but is removed in some manner from the product before it is packaged in its finished form
• A substance that is added to a product during processing, is converted into constituents normally present in the product and does not significantly increase the amount of the constituents naturally found in the product
• A substance that is added to a product for its technical or functional effect in the processing but is present in the finished product at insignificant levels and does not have any technical or functional effect in that product

How do I calculate the percentage of organic content in my product?

• Update your Master Ingredient List
  Determine the organic content of each of the individual ingredients that make up your product formulation. Use your Master Ingredient List (MIL) to track important information about all of your organic ingredients. Begin by checking the information on your MIL is updated with current supplier certificates. Along with your updated MIL, you’ll need a blank Product Formulation Sheet. Along with your updated MIL, you’ll need a blank Personal Care Product Formulation Sheet (Personal Care PFS).
• Fill in the Product Formulation Sheet for your new product
  Using your MIL, copy all the organic ingredients for your product onto your Personal Care PFS. Make sure the ingredient name on your certificate matches the ingredient name on both sheets exactly (e.g. if the ingredient is listed on your MIL as “OG Aloe Vera” be sure to list the ingredient as “OG Aloe Vera” on your Personal Care PFS). After you have all of your organic ingredient information, list all non-organic ingredients that will be used in the product (excluding mined minerals, water and salt) within the Ingredient column of your Personal Care PFS.
• List the percentage of organic content for your ingredients
  Organic percentage information is located on your MIL and your supplier certificate. Learn more about how to use and update your MIL to identify the percentage of organic content of your organic ingredients.
• Calculate the percentage of organic content for your product
  The Personal Care PFS will use the information you’ve entered to calculate the percent organic content for your end product and determine your label.

What is the formula for calculating the percentage of organic content?

Percentages for organic calculations are always rounded down (e.g., 94.7 percent would be 94 percent). 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*

* Excludes mined minerals, salt and water