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What is the National List?

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.

Are there use restrictions for these materials?

There are often additional usage restrictions (in the form of “annotations”) for a material on the National List. Restrictions often apply to sourcing, identification, form, use, and composition of the material. You will need to submit documentation of compliance with all listed restrictions to OTCO for review and approval prior to using them in your organic production.

Organic processing begins with using certified organic ingredients. Sourcing, documenting and verifying organic ingredients is critical to ensure the organic integrity of your products.

How do I verify an organic certificate?

Before purchasing ingredients for your product, you must confirm the organic certificate for each product or ingredient is valid and in good standing.

Transaction certificates cannot take the place of a valid organic certificate.

We recommend starting the verification process of organic certificates by using 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). Observe additional requirements for imported organic products as needed.

Where can I find organic ingredients?

Finding ingredients can be a challenge, start with the USDA Organic Integrity Database.

What do I need to know about using water and salt as ingredients in my organic product?

Water and salt are not considered or certified as “organic,” unless they are sourced as an agricultural byproduct (e.g., salt from certified organic seaweed). If you use water and/or salt in a multi-ingredient product, do not include either ingredient in your calculations for the percentage of organic contents in the product.

What do I need to know about using carbon dioxide in my organic product?

If you are using naturally occurring carbon dioxide (e.g., the carbon dioxide produced in the fermentation process of kombucha) in your product, it doesn’t count as an ingredient and does not need to be included on your Product Formulation Sheet.

If you are using synthetic carbon dioxide (e.g, forced carbon dioxide in a beverage) for your product, you’ll need to account for it in the follow the following places:

• Product Formulation Sheet
• Master Ingredient List
• Specification sheet (e.g., statement of purity) from the manufacturer of the carbon dioxide
• Calculations of the percentage of organic content in the product

Can I use non-organic ingredients in my product?

Yes, in certain cases with specific documentation. The USDA National Organic Program allows for a limited number of non-organic ingredients to be used in organic labeled products, if the:

• Ingredient is a listed, acceptable commercially non-available restricted ingredient
• Ingredient was not produced using organic excluded methods
• Ingredient is allowed per the National List

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

To start, submit all non-organic ingredients to OTCO for approval prior to use, including the manufacturer’s full list of ingredients and/or processing aids that went into creating the ingredient. All non-organic ingredient submissions must include the full label including the brand and manufacture’s name for the product. For most non-organic ingredients and processing aids, submit the Non-Organic Ingredient Declaration (NOID) to ensure the ingredient was not produced using organic excluded methods.

A few exceptions include:

• If your non-organic ingredient has commercial availability restrictions…
  You will need to demonstrate an organic version is unavailable through the completion of a Commercial Availability Form.
• If your non-organic ingredient is a natural flavor…
  You must submit a Natural Flavor Questionnaire (in place of a NOID), and verify it is produced using only approved methods or following restrictions per the organic requirements.  Additionally, use of non-organic natural flavors requires a Commercial Availability Form (see March 2019 Notice). You will need to fill out an H11 (as well as the NFQ that is already listed), and you must be on the current MIL form. You can download the H11 and MIL forms below.
• If your non-organic ingredient is a nutrient, vitamin or mineral…
  You will complete the Declaration for Nutrient Vitamins and Minerals in place of the NOID, as well as verification it is produced using only approved methods.
• If your non-organic ingredient is a multi-ingredient product (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.

What is the Master Ingredient List?

The Master Ingredient List (MIL) documents all of your product’s ingredients.

Using organic certificates from your suppliers, you will be able to fill in all the information required for each ingredient to complete your MIL. This includes :

• Issue date of the certificate
• Organic percentage of the ingredient
• International equivalences (as relevant)

How do I calculate the percentage of organic content for my ingredients?

Supplier certificates break down ingredients into three categories. This information will assist you in identifying the correct organic content percentage of each ingredient for all of your multi-ingredient products:

• 100% Organic = 100% organic content
• Organic = 95% organic content
• Made with Organic = 70% organic content

How do I ensure my supplier certificates are valid?

We’ve set up a color code to see if supplier certificates and Non-Organic Ingredient Declarations (NOIDs) are up-to-date in your MIL. Submit new certificates for any ingredients close to out of date or expired, as well as for any new or updated suppliers.

The following will help you track expiration dates:

• Orange – indicates ingredients are will soon be out of date
• Red – indicates ingredients are out of date
• White – indicates ingredients are current

If you use multiple-ingredient products as an ingredient, work with your supplier to obtain a manufacturer’s full list of ingredients and/or processing aids that demonstrates which are organic and which are non-organic (i.e., a specification sheet).

To protect organic integrity, most entities in the organic supply chain require organic certification. There are limited exemptions outlined in §205.101 that do not require organic certification. At times you may need to receive organic ingredients or products that have moved through uncertified operations, like transportation or storage locations. There are special compliance requirements for materials moved through uncertified operations.

What documentation is required when sourcing from uncertified operations?

OTCO clients that receive organic agricultural inputs (ingredients, products, etc.) through exempt uncertified operations must maintain documentation that verifies the materials’ organic status back to the last certified handler and ensure that activities performed by exempt uncertified operations has not compromised the organic integrity of the organic products or ingredients. Collecting documentation from the exempt uncertified parts of the supply chain not only helps verify the integrity of your ingredients, but it also helps to identify operations that are either knowingly or inadvertently performing activities requiring certification.

Certified operations are required to:

• Clearly identify uncertified entities sources in your Organic System Plan Master List(s)
• Verify that the uncertified operations are exempt under the limited exemptions listed in 205.101. The Uncertified Handler Affidavit (UHA) is a useful tool and must be provided for each exempt uncertified operation in use.
• Maintain organic certificates for the last certified handler of organic agricultural inputs received through uncertified entities
• Collect and maintain all records associated with the purchase and transport of organic agricultural inputs through the supply chain back to the last certified entity
• Provide documents and records to verify organic certification of purchased organic agricultural inputs to OTCO staff and inspectors upon request

  Uncertified Handler Affidavit
  Independent Storage Information Sheet (IS)
  Master Ingredient List Form (MIL)

Records for purchased organic agricultural inputs must:

• Clearly link all traceable elements between all documents and points in the supply chain
• Identify all certified organic agricultural inputs as “organic” through the entire supply chain and on each piece of documentation
• Have matching volume/weight through the supply chain, explaining and verifying any variances
• Show that any handling performed (processing, labeling, relabeling, packaging or repackaging organic products) in the supply chain is performed only by certified handlers