Product ingredients

#Sourcing organic ingredients for processing

It all begins with organic ingredients. The process for sourcing, documenting and verifying organic ingredients is critical to ensure the organic integrity of your products.

Verification of an organic certificate
Prior to purchase, you must confirm the validity of the organic certificate for each product or ingredient. Organic certificates may only be issued by accredited certifiers of the USDA National Organic Program (NOP).


We recommend starting the verification process of organic certificates with the USDA Organic Integrity Database and reviewing the listed certifier’s website (or calling the certifier directly). Please observe additional requirements for imported organic products.

In every instance, a valid organic certificate must include:

  • The phrase “USDA National Organic Program,” “USDA NOP” or “USDA organic standards”
  • An inspection date — or last printed date — from within the last year
  • A listing of crops, products, services, or brands covered by the certification (extends to international compliances)


Transaction certificates are not an acceptable substitute for a supplier’s organic certificate.

You must organize and maintain records for all of your organic ingredients as part of your Organic System Plan. No matter what documentation approach you use, it should provide accessible and clear traceability. Additionally, it must demonstrate the prevention of contamination or commingling. From using lot code numbers to UPC codes, we will need to work through each phase of your operation (e.g, ordering, receiving, processing, distribution, etc.) to verify all organic ingredients received align with the products you produced and shipped.


Finding ingredients can be a challenge, start with reputable sources such as the USDA Organic Integrity Database and OTCO’s list of ingredient resources.

#Water, salt and carbon dioxide

In addition to use of approved non-organic ingredients, you might want to also use the common ingredients salt, water, or carbon dioxide.

Water and salt
These ingredients cannot be considered or certified as “organic,” unless they are sourced as an agricultural byproduct (e.g., salt from seaweed).  If using 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.


Our Product Formulation Sheet (see below) can help calculate the organic percentage of your multi-ingredient product.

Carbon dioxide
Naturally occurring carbon dioxide (e.g., the carbon dioxide produced in the fermentation process of beer) does not count as an ingredient and does not need to be included on your Product Formulation Sheet (PFS).

Synthetic carbon dioxide (e.g, forced carbon dioxide in a beverage) that is added to a product does need to be included on your PFS. Additionally, you must list it on your Master Ingredient List and provide a specification sheet (e.g., statement of purity) from the manufacturer of the carbon dioxide. Carbon dioxide must be accounted for in your calculations of the percentage of organic contents in the product.

#Updating your Master Ingredient List

All product ingredients need to be documented on your Master Ingredient List (MIL), the information needed to correctly fill out your MIL can be found on the supplier certificates for each ingredient.

Using your organic certificate from your supplier you will be able to fill in all the information required for each ingredient. This includes the issue date the certificate, the organic percentage of the ingredient and any international equivalences.


Make sure the name on the certificate matches the ingredient name on your Master Ingredient List exactly.

Organic Content Percentage
The supplier certificate will break down ingredients into three potential categories, 100 percent organic, organic and made with organic. You will use the information 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%

Read more about allowable non-organic ingredients here.


This is crucial information for correctly calculating the organic content percentage of any multi-ingredient products you produce.

Certificate Issue Date
Be sure to check that your supplier certificates or Non-Organic Ingredient Declarations (NOIDs) are also up-to-date in your Master Ingredient List (MIL). The certificate issue date cell in your MIL will turn orange (ingredients close to being out of date), red (ingredients out of date), or white (ingredients are current).

If you find any out of date ingredients, or those that are close to out of date, submit new certificates for those, as well as for any new or updated suppliers.

Please note that if you use multiple-ingredient products as an ingredient, you must 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).

Forms & Documents

Download the above and submit it to your client service team.

#Understanding 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.

When considering ingredients and materials for your product, it helps to understand the different requirements between categories for products labeled as “100% organic,” “organic,” and “Made with organic.” In all instances of “100% organic” claims, you must use only certified organic materials.

Use restrictions for 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 must submit documentation of compliance with all listed restrictions to OTCO for review and approval prior to use.

#Using non-organic ingredients

Understanding use of allowable non-organic ingredients
The USDA National Organic Program allows for a limited number of non-organic ingredients to be used in organic, labeled products provided the:

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


606 Organic was developed to assist in the search for organic sources of allowed non-organically produced ingredients. These “606” ingredients may only be used when an organic form is not commercially available.

Documentation for use of allowable non-organic ingredients
It depends on the type of non-organic ingredient you are using. There are a few differences for vitamins, minerals and natural flavors.

  • For all non-organic ingredients with commercial availability restrictions as well as non-organic natural flavors, 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
  • To demonstrate it is produced using only approved methods and follows restrictions, you must submit a completed Non-Organic Ingredient Declaration (NOID) — unless it is a natural flavor, vitamin or mineral (see forms below)
  • 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; additionally, use of non-organic natural flavors will require a commercial availability search (see first bullet above) beginning December 27, 2019 (read March 2019 Notice)
  • 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 (form below)
  • 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

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