Understanding Certified Organic Products

Since 2008 Essential Labs has proudly carried the Oregon Tilth (OTCO) and USDA certifications for Organic Certified Products. 

Recently, after careful consideration and evaluation of our operations, we have made the decision to temporarily put our organic certification on hold. This was due to a multitude of reasons, one of them relying on external factors that we could not control. Rather than reaching out to each external party, and due to all of our other internal focuses, we decided putting the certification on hold was necessary. However, we will continue to purchase organic, sustainable and pure ingredients in the same manner we always have.

We have found that many parties are not aware of what it takes to be organically certified, and quite a few have been utilizing our organic certification to advertise that they are certified. However, the regulatory framework governing the production and sale of organic products, called the National Organic Program (NOP) is pretty strict about qualifications. While it can be very challenging to understand, Essential Labs would like to help with the understanding. 

Before we lay out a lot for you to read, we do want to let you know to not be disheartened. Just because an ingredient is “organic”, does not mean it is sustainable. With Essential, all organically grown ingredients we buy are also sustainable… and since we cannot sell our products/ingredients as “Certified Organic”, we do want you to know that they’re Responsibly Grown.

What is a Certified Organic Facility?

In order to produce a certified organic product, one must first be operating in a facility certified to handle and manufacture organic products. This requires a company to follow all NOP guidelines of ordering, receiving, quarantining, handling, manufacturing, packaging, labeling, and marketing as well as facility, equipment, and documentation maintenance. Organic facilities must pass detailed annual inspections by certifying agencies as well as the occasional unannounced inspection. Unless one successfully sees this process through, one cannot create a product and legally label it “organic”.

In fact, if you purchase a pail of certified organic olive oil and you break the seal of that pail inside a non-certified facility, such as your home, the olive oil immediately ceases to be organic. Of course, nothing can change the fact that the oil was pressed in a certified organic facility from olives cultivated and harvested according to organic agricultural processes, but from a strictly legal point of view a certified organic product can only be handled in a certified organic facility. Once the olive oil is handled in a non-certified facility the organic “chain of custody” is broken and it can no longer be labeled “organic”. This is where Essential is now; we can purchase Certified Organic ingredients, but we can no longer list or label them as Certified Organic, Organic, or Grown Organically. 

What About Using Just the Word, ‘Organic’ on my Product?

It isn’t at all unusual to come across products falsely labeled “organic”. Vendors may offer the naïve explanation that their products are organic, they just aren’t “certified organic”. Never fall for this. If a product is not certified organic then it is not legally organic and does not qualify to use the word “organic” on its labeling. If the ingredients in the product were originally certified organic but the manufacturer is not, then the word “organic” cannot appear anywhere on the label and yes, the USDA and Federal Trade Commission (FTC) do have the authority to take action against companies labeling non-certified products as “organic”. Please note that the term “labeling” doesn’t just extend to your actual labels, but to all of your branding, meaning your flyers, posters, marketing materials, and website. 

Can Essential Help Me?

Just as you need to understand the requirements for selling into certain states and countries, it is imperative you understand and follow the requirements of the NOP to get your organic certification.

Not all organic products are created equal. You’ll find that some cosmetic and skincare companies claim their products are organic even when those products have not been certified under programs such as the USDA National Organic Program under the organization of Oregon Tilth. We are always here to help you understand the program, but since we are no longer certified, if you buy organic ingredients from us, you will not qualify for a handlers certification.

However, like we mentioned earlier, “organic” doesn’t necessarily mean it is sustainable. We’ll continue following our strict sustainable and responsible sourcing guidelines as we always have, which can still be leveraged on labels or marketing material.

Label Options for USDA Certified Organic Products

The below information is from the US Department of Agriculture’s documentation on Organic Standards for personal care products. Any cosmetic, body care product, or personal care product that does not meet the production, handling, processing, labeling, and certification standards described below, may not state, imply, or convey in any way that the product is USDA-Certified Organic or meets the USDA Organic Standards.

1. “100 percent organic”– Product must contain (excluding water and salt) only organically produced ingredients. Products may display the USDA Organic Seal and must display the certifying agent’s name and address. 
2. “Organic”– Product must contain at least 95 percent organically produced ingredients (excluding water and salt). Remaining product ingredients must consist of nonagricultural substances approved on the National List or non-organically produced agricultural products that are not commercially available in organic form, also on the National List. Products may display the USDA Organic Seal and must display the certifying agent’s name and address. 
3. “Made with organic ingredients”– Products contain at least 70 percent organic ingredients and product label can list up to three of the organic ingredients or “food” groups on the principal display panel. For example, body lotion made with at least 70 percent organic ingredients (excluding water and salt) and only organic herbs may be labeled either “body lotion made with organic lavender, rosemary, and chamomile,” or “body lotion made with organic herbs.” Products may not display the USDA Organic Seal and must display the certifying agent’s name and address. 
4. Less than 70 percent organic ingredients– Products cannot use the term “organic” anywhere on the principal display panel. However, they may identify the specific ingredients that are USDA-certified as being organically produced on the ingredients statement on the information panel. Products may not display the USDA Organic Seal and may not display a certifying agent’s name and address. (Water and salt are also excluded here). Again, one must be approved to carry the Certifying agency’s seal, and be certified by them, even though they cannot use the seal on this category.

NSF/ANSI 305: Personal Care Products Containing Organic Ingredients

In 2009, NSF, in conjunction with ANSI, created this standard specifically for personal care products. To become certified to this standard, products must undergo a thorough review by an independent organic certification organization, such as Oregon Tilth, to verify that a manufacturer’s product formulation contains at least 70 percent organic content by weight.

This program differs slightly from the USDA Certified Organic program. One such difference is that NSF/ANSI 305 allows for some limited chemical processing necessary to create personal care products. For example, soaps containing organic ingredients are permitted to undergo chemical processing known as saponification, without which these products could not lather. However, such processing would not normally be permitted under traditional organic regulations.

Please let us know if you have any other questions or comments. We’re here to help!