Example 1: Product Composition

If Peak’s Muffin Mix contains the following, does it meet the requirements for the “made with” labeling category?

7.8 lb organic wheat flour

1.5 lb blueberries

0.5 lb organic cane sugar

0.05 lb baking soda 

0.05 lb salt

0.05 lb cream of tartar

0.05 lb cinnamon

With 83 percent organic content, this product meets 

the 70 percent organic requirement for the “made 

with” organic labeling category. The other agricultural 

ingredients—blueberries and cinnamon—don’t need 

to be organic, but must be produced without genetic 

engineering, sewage sludge, or ionizing radiation. 

Additionally, the non-agricultural ingredients used—

baking soda (sodium bicarbonate) and cream of tartar 

(potassium acid tartrate)— are specifically allowed 

on the National List of Allowed and Prohibited 

Substances.

Example 2: Organic and Non-Organic Forms of the Same Ingredient

The Peak’s Muffin Mix label below states “made with organic wheat and sugar” on the Principal Display Panel. Can this product 

be labeled as shown below?

7.3 lb organic wheat flour

1.5 lb blueberries

0.5 lb whole durum wheat flour

0.5 lb organic cane sugar

0.05 lb baking soda

0.05 lb salt

0.05 lb cream of tartar

0.05 lb cinnamon

No. While the product contains at least 70 percent organic content, there are two problems:

1) The product contains organic and nonorganic flours, but the ingredient statement only lists organic wheat flour.

2) Since the label claims, “made with organic wheat,” the whole durum wheat flour must be certified organic because it is 

derived from wheat. 

Since the finished product has 78 percent organic content, it meets the 70 percent organic minimum for the “made with” 

organic labeling category. As described above, all 

nonorganic ingredients (in this case, the whole 

durum wheat flour, blueberries, and cinnamon) must 

be produced without genetic engineering, sewage 

sludge, or ionizing radiation.

To correct it:

1) Change the claim to, “made with organic sugar” 

and list both flours in the ingredients OR:

2) Reformulate the mix to contain only certified 

organic wheat flour. It could contain any 

combination of organic wheat or organic durum 

wheat flour.

 Made with organic 

 flour and sugar!

Ingredients: Organic wheat 

flour, blueberries, organic cane 

sugar, baking soda, salt, cream 

of tartar, cinnamon.

Distributed by Peak’s Foods, Inc.

Certified Organic By John Doe 

Certification, Inc.

 Peak’s Muffin Mix

National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture April 2014

“MADE WITH” ORGANIC LABELING EXAMPLES

 Made with organic 

 wheat and sugar!

Ingredients: Organic wheat 

flour, blueberries, organic cane 

sugar, baking soda, salt, cream 

of tartar, cinnamon.

Distributed by Peak’s Foods, 

Inc.

Certified Organic By John Doe 

Certification, Inc.

Peak’s Muffin Mix
Example 3: Organic and Non-Organic Forms of the Same Ingredient

A pasta sauce contains organic diced tomatoes and non-organic tomato paste and is labeled, “made with organic 

tomatoes.” Is the labeling example below correct?

No. There are two problems:

1) The sauce contains nonorganic tomato 

paste, but the ingredient statement only lists 

organic diced tomatoes. 

2) Since tomato paste is derived from 

tomatoes, it must be certified organic to 

support a made with organic tomatoes 

claim.

To correct it:

Reformulate product to contain organic tomato 

paste and list this in the ingredient statement. The 

“made with organic tomatoes” claim would then 

be compliant, OR change the claim to “made with 

organic diced tomatoes” and add tomato paste to 

the ingredient statement (see label to left).

National Organic Program | Agricultural Marketing Service | U.S. Department of Agriculture April 2014

“MADE WITH” ORGANIC LABELING EXAMPLES (continued)

Using the reformulated muffin 

mix containing organic wheat flour described 

on the bottom of page 1, is the label to the 

left compliant?

No. There are two problems:

1) Since the label doesn’t include a “made 

with” claim, the 83 percent organic 

statement can’t be used.

2) Specific ingredients can’t have percent 

organic statements. Therefore, the 

“100% organic cane sugar” claim is noncompliant. 

To correct it:

The example to the left would be a compliant 

way to label the reformulated muffin mix 

since: the 83 percent organic claim is paired 

with a “made with” statement, and it doesn’t 

identify specific ingredients as “100 percent 

organic.”

Peak’s Muffin Mix

83% 

Organic

100% Organic 

Cane Sugar

Peak’s Muffin Mix

Made with organic 

flour and sugar!

83% 

Organic

Ingredients: Organic diced 

tomatoes, olive oil, salt, natural seasoning.

Distributed by Vines Foods, Inc.

Certified Organic By Jane Doe 

Certification, Inc.

Made with 

organic tomatoes!

Vines 

T-Sauce

Ingredients: Organic diced 

tomatoes, tomato paste, olive oil, salt, 

natural seasoning.

Distributed by Vines Foods, Inc.

Certified Organic By Jane Doe 

Certification, Inc.

Made with organic 

diced tomatoes!

Vines 

T-Sauce

Ingredients: Organic wheat 

flour, blueberries, organic cane 

sugar, baking soda, salt, cream of 

tartar, cinnamon.

Distributed by Peak’s Foods, Inc.

Certified Organic By John Doe 

Certification, Inc.

Ingredients: Organic wheat 

flour, blueberries, organic cane 

sugar, baking soda, salt, cream of 

tartar, cinnamon.

Distributed by Peak’s Foods, Inc.

Certified Organic By John Doe 

Certification, Inc.