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Guidance

Products in the “Made with Organic ***” Labeling Category

Links Updated March 20, 2024 

1. Purpose and Scope

This guidance describes the requirements for products in the “made with organic (specified 

ingredients or food group(s))” labeling category. Specifically, this guidance clarifies the 

following aspects of products in this labeling category, referred to as “made with organic ***”: 

1. Composition; 

2. Compliant organic labeling claims;

3. Organic and nonorganic forms of the same ingredient;

4. Percentage of organic ingredients statements; and

5. Ingredients or food groups in the “made with organic ***” claim. 

This guidance applies to all products sold, labeled, or represented as “made with organic 

(specified ingredients or food group(s)).” 

2. Background 

Operations that grow, handle, or process organic products that are intended to be sold, labeled, or 

represented as “made with organic ***” must be certified organic (7 CFR 205.100(a)). 

Exceptions to this rule are explained in 7 CFR 205.101. The USDA organic regulations specify 

the required composition of products in the “made with organic ***” category, and compliant 

labeling claims for these products (7 CFR 205.304).

Accredited certifying agents (certifiers) review product labels in the following labeling 

categories to verify compliance: “100 percent organic;” “organic;” “made with organic ***;” and 

livestock feed. Certifiers and the organic trade have asked the NOP to clarify the requirements 

for “made with organic ***” products. 

3. Policy

The following specifications apply to products in the “made with organic ***” labeling category:

3.1 Composition

“Made with organic ***” products: 

• Must contain at least 70 percent organic ingredients, excluding salt and water (7 CFR 

205.301(c)); 

• May contain up to 30 percent nonorganic ingredients. Any nonagricultural ingredient

in a “made with organic***” product must be allowed by the National List of 

Allowed and Prohibited Substances (7 CFR 205.605);
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• Must not contain any ingredient that was produced using excluded methods, such as 

genetic engineering, sewage sludge, or ionizing radiation (7 CFR 205.105). 

3.2 Labeling Claims

If a product meets all the composition requirements of the “made with organic ***” labeling 

category (7 CFR 205.301(c)), then: 

• Labels may include the statement, “made with organic (insert up to three ingredients, 

food groups, or combination of ingredients and food groups).” The statement, “made 

with organic ingredients” is not allowed. For restrictions on this statement, see section 

3.4 below. 

• If the “made with organic ***” statement is used, labels may also include the 

percentage of organic ingredients of the finished product. Examples of acceptable and 

unacceptable versions of the percentage of organic ingredients statement include:

o Acceptable 

− 70 percent organic*; 

− 99% organic ingredients*; and 

− Contains 92% certified organic ingredients*.

*If ingredient-specific claim such as “made with organic corn” is also on the label.

o Unacceptable 

− 100% organic spices; 

− 100 percent organic grapes; and 

− Made with 75% organic ingredients (“made with” claim can only apply to organic 

ingredient- or food group-specific claim). 

Additional requirements: 

• All words in the “made with organic ***” and percentage of organic ingredients 

statements must be in the same format without highlighting, and be no more than half 

the size of the largest text on the panel.

• The USDA organic seal cannot be used anywhere on the label or package.

• The statement, “certified organic by ***,” must be included below the identified final 

handler or distributor. The certifier’s logo may be present anywhere.

• The label cannot represent the finished product as organic.

• The ingredient statement must identify certified organic ingredients as organic.

3.3 Organic and Nonorganic Forms of the Same Ingredient

If a product contains both organic and nonorganic forms of the same ingredient, the ingredients 

must be identified separately in the ingredient statement. For example, the ingredient statement 

for sugar cookies labeled “made with organic flour and sugar” could state: “organic flour, 

organic sugar, organic butter, nonorganic butter....” 
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These requirements apply to variants and derivatives of the same ingredient in a product, such as 

organic tomatoes and nonorganic tomato paste, or organic spearmint leaves and nonorganic 

spearmint oil. These also must be identified separately in the ingredient statement.

3.4 Ingredients or Food Groups in the “Made With Organic ***” Claim

The “made with organic ***” claim may include a combined total of three ingredients, food 

groups, or combination of ingredients and food groups. For example, a product could be labeled, 

“made with organic grains, pistachios, and cranberries.” Specific guidance on ingredients and 

food groups is provided below.

If an ingredient is identified in the “made with organic ***” statement, it must be a truthful 

claim. This means the product can only contain organic forms of that specific ingredient or any 

further processed form thereof.* For example, if the label states: 

• “Made with organic corn”: all raw and processed corn-based ingredients, such as 

blue corn, corn oil, and corn starch, must be certified organic.

• “Made with organic flour”: all flour, including enriched wheat flour, almond flour, or 

whole durum wheat flour, must be certified organic. Other ingredients that are 

precursors to the flour ingredients, however, such as almonds or whole wheat berries, 

could be used in a nonorganic form.

• “Made with organic beets”: any ingredient derived from beets, such as beet color 

extract, must be certified organic.

• “Made with organic chicken”: all ingredients derived from chicken, such as chicken 

meat, chicken liver, or chicken broth, must be certified organic.* 

• “Made with organic chicken broth”: all chicken broth must be certified organic, but 

other ingredients derived from chicken, such as chicken meat or chicken liver, do not 

have to be certified organic. 

• “Made with organic milk”: all milk-based products, such as yogurt, cheese, or whey 

powder, must be certified organic.

• “Made with organic cheese”: all ingredients derived from cheese, such as cheese 

curds or whey powder, must be certified organic. Additional ingredients derived from 

a dairy animal, such as added milk and yogurt, do not have to be certified organic. 

*Pet food. Ingredients used in pet food must meet the definitions of the Association of American 

Feed Control Officials (AAFCO). For example, AAFCO defines “poultry” as clean flesh and 

skin, and doesn’t include other ingredients derived from poultry, such as chicken meal or chicken 

broth. Therefore, if an organic pet food label states, “made with organic chicken,” all chicken 

must be certified organic. Other ingredients derived from chicken, which have separate 

definitions under AAFCO, would not have to be certified organic. This exemption applies only 

to animal products, as more narrowly defined by AAFCO, used as ingredients in pet food. 

If a food group is identified in the “made with organic ***” statement: 
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• Only the following may be listed as food groups: beans, fish, fruits, grains, herbs, 

meats, nuts, oils, poultry, seeds, spices, sweeteners, vegetables, or processed milk 

products. The USDA organic regulations do not allow any other food group to be 

listed. (See 7 CFR 205.304).

• It must be a truthful claim; all raw and processed forms of ingredients in that category 

must be certified organic. For example, if a product states, “made with organic***”: 

o Fruits – any ingredient derived from a fruit, such as mango nectar, key lime juice, 

or banana chips, must be certified organic.

o Vegetables – any ingredient derived from a vegetable, such as carrot juice, kale 

chips, or celery, must be certified organic. 

o Grains – any ingredient derived from a grain, such as enriched wheat flour, corn 

oil, or oats, must be certified organic.

4. References

USDA Organic Regulations (7 CFR Part 205) 

7 CFR 205.100 What has to be certified.

7 CFR 205.101 Exemptions from certification.

7 CFR 205.105 Allowed and prohibited substances, methods, and ingredients in organic 

production and handling. 

7 CFR 205.301 Product composition. 

7 CFR 205.304 Packaged products labeled “made with organic (specified ingredients or food 

group(s)).” 

7 CFR 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on 

processed products labeled as “organic” or “made with organic (specified ingredients or food 

group(s)).” 

National Organic Standards Board Recommendation

Recommendation for Rule Change Concerning Made With Organic Ingredients, 2005. 

Other Laws and Regulations

Association of American Feed Control Officials 

https://www.aafco.org/

Original Issue Date April 30, 2014