If you follow current trends in USDA issues related to organic labelling matters, you won’t be surprised to know that there’s a difference between products labeled “organic” (minimum 90% organic ingredients), products labeled “made with organic [insert name of ingredient food or groups] (minimum 70% organic ingredients and “100% organic” (made without the use of a non-organic processing aid).  But you may be surprised to know that there is some debate regarding applying these labels to multi-ingredient products and that the method and standards used in that application by various certifying agents has lead to “different” and “inconsistent applications” of these labels to multi-ingredient products.

In order to help clarify matters, and in response to a National Organic Standards Board recommendation the USDA has issued Draft Guidance on the identifying procedures on how to:

1) Calculate organic percentages of multi-ingredient ingredients used in organic processed products.

2) Determine the organic content of single-ingredient ingredients (raw or processed).

3) Exclude water from ingredients used in organic processed products.

4) Calculate the organic content of carbonated beverages.

5) Exclude salt from ingredients used in organic processed products.

AMS is currently soliciting comment on the guidance through February 2, 2016.  If added water or salt, or perhaps lack of confirmation and documentation from suppliers is are issues you’ve relied on in obtaining the certification, you may want to provide some feedback as those are the major issues addressed here as well as noting that you will now need to keep track of and prove the exact organic content of each of the multi-ingredient ingredients (yes, you read that right, “the parts of the parts”) that you use.

Of note, the guidance explicitly does not cover the use of sanitizers of other materials and how it may affect the 100% Organic labeling claim.

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