What the USDA Organic Label Means (and What "Made With Organic" Doesn't)

The word "organic" appears on everything from breakfast cereal to snack bars, and it can mean quite different things depending on how it is worded. In the United States, the term is regulated for agricultural products under the USDA's National Organic Program, and the wording on a package follows a set of defined tiers. Knowing the tiers makes it much easier to read a label without relying on the front-of-pack impression.

This guide covers packaged food-type products, where the rules are most clearly spelled out. It is general consumer information. The regulations have many details and exceptions, so read the current text if you need to make a business or compliance decision.

The four wording tiers

The product composition rules are in 7 CFR 205.301. They set out these tiers. In each case, water and salt are excluded when the percentage is calculated.

"100 percent organic"

Every ingredient must be organically produced. Under 7 CFR 205.303, the label may carry the USDA organic seal, and it may show the seal of the certifying agent. Packaged products in this tier and the next must also name the certifier on the information panel, preceded by "Certified organic by" or a similar phrase.

"Organic"

At least 95 percent of the product must be organically produced agricultural ingredients, excluding water and salt. The remaining ingredients must also be organic unless organic versions are not commercially available, or they are non-agricultural substances or non-organic agricultural products that comply with the National List of allowed substances. Section 205.303 allows the label to display the percentage of organic ingredients, and requires each organic ingredient in the ingredient statement to be identified with the word "organic" or with an asterisk or other reference mark defined below the list. Salt and water cannot be identified as organic. The USDA seal may be used.

"Made with organic ingredients"

This is the tier where many shoppers get caught out. Under 7 CFR 205.304, a multi-ingredient product with at least 70 percent organic content may say "Made with organic (specified ingredients)" or "Made with organic (specified food groups)." The label may name no more than three organic ingredients, or no more than three food groups from the regulation's list. The "made with" statement may not appear in letters larger than half the size of the largest type on its panel, and the label may also display the percentage of organic ingredients, subject to the same size limit. The rule is explicit that these products must not display the USDA seal.

So when you see a package that says "made with organic oats" and has no USDA seal, that is consistent with the rules: the label is describing a specific ingredient claim and not claiming the finished product is organic.

Below 70 percent

Products with less than 70 percent organic ingredients cannot display the USDA seal or any certifier's seal or mark indicating organic certification of the product or its ingredients (7 CFR 205.305). They may flag organic ingredients in the ingredient list, using the word "organic" or a reference mark, and if they do, the organic percentage must appear on the information panel.

Reading a real label: a short walk-through

1. Look for the exact wording. "100 percent organic," "organic" and "made with organic" are not interchangeable. The difference is what share of the product is organic, and whether the finished product itself is represented as organic.
2. Check for the seal. The USDA seal is limited to the top two tiers. 7 CFR 205.311 limits the seal to raw or processed agricultural products described in 205.301(a) and (b) (the 100 percent organic and organic tiers) and in (e)(1) and (e)(2), which cover livestock feed, and 205.304 and 205.305 say the lower tiers must not display it. A seal on a "made with" product would be a red flag.
3. Look for the percentage. Products in the "organic" and "made with" tiers are allowed to display it, so a missing percentage is not a violation on its own. Products under 70 percent that mark organic ingredients in the ingredient list must show the percentage on the information panel.
4. Read the ingredient list for marked organic ingredients. Asterisks or the word "organic" tell you which items are organic.
5. Look for the certifier statement. A "Certified organic by" line with the certifier's name is required on the information panel for the three certified tiers (7 CFR 205.303 and 205.304). A certifier's own logo does not replace that statement.

Common misunderstandings

"Organic means nothing synthetic was ever used." The composition rules allow some exceptions: the remaining ingredients in the "organic" tier can include non-agricultural substances or non-organic agricultural products that comply with the National List. If you have a specific concern, such as an allergy or a sensitivity, read the ingredient list and talk to a health professional.

"Organic means healthier." USDA describes organic as a labeling term for products produced according to the USDA organic regulations, and says those regulations do not address food safety or nutrition. Compare the nutrition facts panel as you would for any other product.

"Natural means organic." They are different words. The USDA tiers above apply to the term "organic." A package that says "natural" or uses green imagery has not necessarily met any of the organic composition rules. Our guide on how to spot greenwashing on product labels covers how vague wording works.

"Made with organic" is the same as organic. As described above, it is a lower tier. Up to 30 percent of the product may be non-organic ingredients (excluding water and salt), and the product is not allowed to carry the USDA seal.

What this guide leaves out

The USDA organic standards also cover crops, livestock, processing and handling, allowed and prohibited substances, certification and inspections, and the details of how a farm or business gets certified. For a particular product or a business question, consult the USDA's National Organic Program, a certifier, or a qualified adviser.

Key takeaways

• Four wording tiers exist: 100 percent organic, organic (95 percent or more), made with organic ingredients (70 percent or more), and below 70 percent.
• The USDA seal is for the top two tiers only; "made with" and below-70-percent products must not display it.
• Water and salt are left out of the percentage calculation.
• The certifier's name should appear on certified packaged products, using wording such as "Certified organic by."
• The organic tiers are about composition and certification, not a nutrition claim.

Sources

• 7 CFR 205.301, Product composition: https://www.law.cornell.edu/cfr/text/7/205.301
• 7 CFR 205.303, Packaged products labeled "100 percent organic" or "organic": https://www.law.cornell.edu/cfr/text/7/205.303
• 7 CFR 205.304, Packaged products labeled "made with organic (specified ingredients or food group(s))": https://www.law.cornell.edu/cfr/text/7/205.304
• 7 CFR 205.305, Multi-ingredient packaged products with less than 70 percent organically produced ingredients: https://www.law.cornell.edu/cfr/text/7/205.305
• 7 CFR 205.311, USDA Seal: https://www.law.cornell.edu/cfr/text/7/205.311
• USDA AMS, USDA Oversight of Organic Products (fact sheet): https://www.ams.usda.gov/sites/default/files/media/USDA%20Oversight.pdf