Creating Compliant Organic Labels

The last thing anyone wants to do is pull their product off the shelves due to a labeling issue, but that’s exactly what would happen if you got caught in the market with a non-compliant label design. To make sure this never happens to you, follow these easy guidelines and make sure you always get your label approved, in writing, by your organic certifier prior to printing.

The USDA has three categories of certified organic food products. "100% Organic" (self explanatory), "Organic" (95% or higher organic ingredients), and "Made with Organic..." (75% and higher). The first thing you need to do is calculate your product's organic content by weight (water and salt don't count), breaking out organic content in all ingredients (ex. cocoa powder is more than just cocoa), and then figure out which category you fall into based on the above percentages. Got it? Great.

The main rules you need to consider with your label design are the following:

• USDA Logo / Seal
  This logo must be used in the official green & brown colors, or as a one-color black version. No exceptions. In addition it must always be displayed more prominently than the certifier's seal/logo. However, it is not required that this logo be used at all.

• Organic Certifier
  You do not need to use the organic certifier's logo/seal (if you do, check with them on their usage rules for colors), but you do have to print the certifier's name on the information panel (ingredients, etc) below the name of the final product handler (in most cases this is your company). Again, make sure it is below the final handler's name, not above, not to the side, not on a separate panel.

• "Made With" Claims
  If you fall into the 75% or higher category (and below 95% obviously), then you do have the right to make a "Made with Organic..." statement — such as "Made with Organic Wheat". The main rules here are that the type must be no larger than 1/2 the size of the largest type on that panel (including any logos), and you're not allowed to highlight any part of the statement (bold, italic, type size, color, etc). The message must therefore be uniform, and can only mention 3 ingredients (Made with Organic Wheat, Honey, and Sugar), or three food groups (... vegetables, fruit, and grains).

• Organic Percentage Claims
  For products that are 95% or higher, you can make a percentage of organic claim — such as "98% Organic Ingredients". The rules here are similar. The type must be no larger than 1/2 the size of the largest type on that panel (including any logos), and you're not allowed to highlight any part of the statement (bold, italic, type size, color, etc).

• Identifying Organic Ingredients
  You have two options for identifying the organic ingredients in your product. The first is to spell out "organic" before each organic ingredient. The second is the space saver option and allows you to replace the word "organic" in front of each organic ingredient with an asterisk (*). Then at the end of the list you identify the asterisk by writing "*organic".

• Get Approval
  As I said above, it is always best to get approval before you print your packaging. It's better to take a little extra time to make sure you're label is correct than to pull your products off the shelf and reprint your labels.

Keep in mind, the regulations for labeling food products (organic or not) are always changing, so practice due diligence to get updated information. A great place to start is to contact your organic certifier. If you don't already have one, try contacting the CCOF who happen to host great webinars on the subject.