Organic Food – What Does the USDA Organic Label Mean?

USDA Organic SealIf a banana or a box of cereal displays the USDA Organic seal, that means it’s 100% organic, “Right?” Well, not necessarily.

As long as the banana is a whole unprocessed piece of fruit it is 100% organic. The cereal is a multi-ingredient processed food that may or may not have been made entirely with 100% organic ingredients. And yet, they both carry the USDA Organic seal. Confused? I was.

In this post, we’ll learn how the USDA categorizes organic food for marketing purposes via the National Organic Program (NOP) and attempt to answer the question, “What does the USDA Organic label mean?”

Two previous posts covered NOP basics that readers may find useful for understanding terms in this post. Organic Food – USDA National Organic Program gives an overview of the NOP and describes the role of certifying agents. Organic Food – USDA Rules and Regulations explains organic production and handling requirements and the National List of Allowed and Prohibited Substances.

USDA Organic Categories and Labeling Rules

The USDA regulates how organically produced and handled raw and processed agricultural products (food, non-food crops, and livestock feed) is categorized and labeled. We’ll focus on food for people.

Organic food falls into 1 of 3 categories: 100% organic, organic, or made with organic (specified ingredients or food groups).

Organic Fruits, Vegetables, and Packaged Food from Author's Kitchen

Use of the USDA Organic seal is voluntary, however there are specific rules for which products may bear the seal and what may be said on labels and packaging.

The weight or fluid volume (excluding water and salt) of organic ingredients is used to calculate the percentage of organic ingredients in a given product which determines its category.

I pulled some examples of organic raw and processed foods from my pantry, fridge, and kitchen countertop to illustrate various organic labeling methods.

100% Organic

All ingredients must be 100% organic. This is easier for say an apple than a jar of peanut butter. The name of the product may be modified with the words 100% organic. The USDA Organic seal and name and seal of the certifying agent may be used on the product or package.

Fresh Produce

The 100% organic carrots, red cabbage, spinach, broccoli, and radishes in the photo are part of our CSA (Community Supported Agriculture) share from Los Osos Valley Organic Farm, a local certified organic farm. The twist ties perform two functions; keeping like items together and identifying the certifying agent, CCOF (Certified California Organic Farmers).

Organic Broccoli, Carrots, and Red Cabbage with CCOF Twist Ties

Honey

On the Natural Directions 100% Organic Honey bottle, the USDA Organic seal is prominently displayed on the front and the words 100% organic are used to modify the name of the product. For good measure, the word organic appears in a red banner. The back label lists the ingredients as organic honey and identifies the certifying agent, PCO (Pennsylvania Certified Organic).

Natural Directions 100% Organic Honey with USDA Organic Seal

Organic

Products labeled organic must contain not less than 95% organic ingredients. The remaining ingredients may be non-organically produced if not available in organic form and must still comply with the National List of Allowed and Prohibited Substances. The name of the product may be modified with the word organic and organic may be used to preface organic ingredients. The USDA Organic seal and name and seal of the certifying agent may be used on the product or package.

Bread

The bag containing Dave’s Killer Bread displays the USDA seal and the name and seal of the certifying agent, Quality Assurance International. The ingredients are prefaced with the word organic, e.g. organic whole wheat, organic sunflower seeds, organic flaxseeds, etc. Although it’s not strictly necessary because genetically modified organisms are prohibited in organic food, the front of the bag sports the words “GMO free”.

Dave's Killer Power Seed Bread with USDA Organic Seal

Made with Organic

The made with organic designation is for products that contain at least 70% organic ingredients. The other ingredients may not be produced using excluded methods, sewage sludge, or ionizing radiation. The organic ingredients may be prefaced with the word organic, for instance organic wheat. The USDA seal may not be used; however the name and seal of the certifying agent may be used on product packaging.

Energy Bar

The Crunchy Peanut Butter Clif Bar package says, “Made with Organic Oats & Peanut Butter”, in the upper right hand corner and lists some organic ingredients on the back, like organic rolled oats and organic peanuts. Per USDA regulations, the USDA Organic seal is not used on the package but it does say, “Certified Organic by QAI” on the back.

Clif Bar Made with Organic Ingredients and Bunch of Organic Bananas with USDA Seal

Multi-Ingredient

Technically there is a fourth category; products containing less than 70% organic ingredients. In this case, NOP production and handling requirements only apply to the organic ingredients. No organic seals or statements may be made on the packaging. Organic ingredients may be prefaced with the word organic, e.g. organic cane syrup.

Organic Food Label Challenge

You are now armed with the necessary information to be a savvy organic food shopper.

Try this the next time you are at the grocery market. Look for 5 whole or processed foods that exhibit the USDA Organic seal or the word organic. Read the labels and ingredients lists (for processed foods), and identify which of the categories each item belongs in. Then choose one of the items you examined, buy it and try it.

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Organic Food – USDA Rules and Regulations

Chickens in Pasture with Chicken Coop - Photo: USDA NOPWhether it’s a plant or an animal, we eat what our food eats. USDA organic food rules and regulations are more interesting than you may think.

What’s the difference between an organic bell pepper, chicken, or glass of milk and its conventional agriculture counterpart? The main differences are the land it is grown or raised on, what does or does not go in or on it, and how it is labeled.

In the U.S., the USDA National Organic Program (NOP) regulates organic agricultural products (food crops, livestock, and non-food crops). A previous post, Organic Food – USDA National Organic Program, provided an overview of the NOP including certification requirements, the roles of certifying agents and the National Organic Standards Board, and the ramifications of violating the NOP.

In this post, we’ll look at requirements for growing and handling organic crops and livestock and learn about substances that may and may not be used in and on organic food. A separate post will examine USDA Organic categories and labeling.

Prior to slogging through organic food regulations, I thought of organic mostly in terms of whole fruits and vegetables and packaged items like peanut butter. As it turns out, a large chunk of the regulations apply to livestock animals such as cows, chickens, and pigs, and animal products like meat, eggs, and milk.

Allowed and Prohibited Substances, Methods, and Ingredients

NOP regulations stipulate the following substances, methods, and ingredients may not be used to produce or handle organic products, except as noted on the National List (which we’ll discuss later):

  • Wood Crates Filled with Peaches - Photo: USDA NOPSynthetic substances are prohibited except as allowed on the National List.
  • Non-synthetic substances are allowed except as prohibited on the National List.
  • Non-agricultural substances are prohibited except as allowed on the National List.
  • Non-organic agricultural substances are prohibited except as allowed on the National List.
  • Excluded Methods are prohibited, except vaccines as allowed on the National List.
  • Ionizing radiation is prohibited.
  • Sewage sludge is prohibited.

Interestingly, one must delve into section 205.2 Terms Defined of the regulations to learn that genetically modified organisms (GMOs) are prohibited under Excluded Methods.

Organic Production Requirements

Organic production pertains to farms and ranches that grow crops and raise livestock.

The intent of organic production is to improve and maintain the quality of the land, water, and air, avoid using synthetic substances, and provide livestock animals with food and habitat conducive to their health and wellbeing.

Soil and Seeds

Seedling Just Sprouting from Soil - Photo: USDA NOPThe condition of the land used to grow food for people and livestock is an essential element in organic farming. For at least 3 years immediately before harvest, no prohibited substance may be applied to land used to grow organic crops. In addition, buffer zones are required to prevent unintended application of prohibited substances from adjoining land that isn’t under organic management.

Instead of applying synthetic fertilizers, soil fertility and health is sustained by selecting plants appropriate to the area, rotating crops, planting cover crops (to provide soil nutrients like nitrogen), applying plant materials, and spreading animal manure (usually composted).

Organic seeds, seedlings, and planting stock are required, with a few exceptions.

Pest, Weed, and Disease Management 

Orchard Trees in Bloom - Photo: USDA NOPHealthy soil contributes to minimizing pests, weeds, and disease. Pests are controlled by planting a variety of crops together (less food for specific pests), introducing pest predators, and using lures and traps. Mulching, mowing, weeding, and livestock grazing keep weeds down. Applying non-synthetic biological, botanical, and mineral inputs suppresses the spread of disease.

When the preferred prevention and control practices are insufficient, an allowed substance from the National List may be used, provided that it is documented in the organic system plan each certified operation is required to submit annually.

Livestock Origin, Feed and Health Care

In order to sell livestock as organic it must be under continuous organic management from the last 1/3 of gestation or hatching, except organic management must begin on the 2nd day of life for poultry, and dairy animals must be under organic management for 1 year prior to production of milk or milk products.

Feed for livestock follows the same requirements as food crops. Certain practices are prohibited such as:

  • Administering drugs or hormones to promote growth.
  • Feed supplements above those needed for animal nutrition and health.
  • Feed containing plastic pellets, urea, manure, slaughter by-products, or antibiotics.

Beef Cattle Grazing in Pasture - Photo: USDA NOPRuminants (cows, goats, and sheep) are required to have access to pasture grazing for not less than 120 days a year and must receive at least 30% of their dry food from grazing.

Yards, feeding pads and feedlots may be used temporarily and under certain circumstances like bad weather, for milking or shearing, to treat illness, and to sort for shipping. Ruminants that are grain finished, meaning they are fed grain instead of pasture just prior to slaughter, may not spend more than 120 days or 1/5 of their life in a feedlot.

Livestock health care focuses on providing nutritious food, maintaining sanitary conditions, allowing for exercise and freedom of movement, providing access to shelter, fresh air, and clean water, and administering vaccines and non-synthetic medications allowed on the National List. Medical treatment may not be withheld from an animal to maintain its organic status, however livestock treated with prohibited substances may not be sold as organic.

Organic Handling Requirements

A handling operation receives, processes, packages, stores, and distributes organic products. Key requirements include:

  • Coffee Beans with Coffee Scoop - Photo: USDA NOPMechanical and biological methods are to be used to process and preserve organic food, such as cooking, roasting, slaughtering, freezing, and canning to name a few.
  • Pests are controlled using methods similar to those used by producers.
  • Organic products must be kept separate from products not produced organically, including storage containers and packaging materials.

National List of Allowed and Prohibited Substances

The National List of Allowed and Prohibited Substances, known as the National List, is a list of synthetic substances that are allowed and non-synthetic substances that are prohibited from use to produce, process, or handle organic agricultural products. The National Organic Standards Board recommends additions and deletions to the National List for approval by the Secretary of Agriculture.

Criteria used to evaluate substances and ingredients include:

  • Substance cannot be produced from a natural source and there are no organic substitutes.
  • Substance’s manufacture, use, and disposal do not have adverse effects on the environment and are compatible with organic handling.
  • Nutritional quality of food is maintained and substance itself or its breakdown products do not have adverse effects on human health.
  • Substance’s primary use is not as a preservative or to recreate or improve flavors, colors, or textures, or nutritive value lost during processing.
  • Kid in Garden at Academy for Global Citizenship - Photo: USDA NOPSubstance is listed as generally recognized as safe (GRAS) and contains no residues of heavy metals or other contaminants in excess of tolerances set by the FDA.
  • Substance is essential for handling of organically produced agricultural products.

Substances on the National List are divided into several categories specific to crops and livestock. The National List details the circumstances under which an allowed substance may be used, frequency of application, and any limitations, say to a specific crop or animal. A few examples are noted below.

  • Pineapple Growing in Pineapple Field - Photo: USDA NOPSynthetic Substances Allowed for Crops – include copper sulfate, hydrogen peroxide, boric acid, elemental sulfur, and sodium silicate.
  • Non-synthetic Substances Prohibited for Crops – include substances that occur naturally but shouldn’t be used on food like arsenic and strychnine.
  • Synthetic Substances Allowed for Livestock – include biologic vaccines and chlorine for disinfecting equipment and facilities.
  • Non-agricultural (non-organic) substances allowed in or on processed products (not allowed for 100% organic products) – include calcium carbonate, agar-agar, ascorbic acid, xanthan gum, and potassium chloride.
  • Non-organically produced agricultural products allowed as ingredients (not allowed for 100% organic products) – include celery powder, pigments from fruits and vegetables, gelatin, cornstarch, and fortified cooking wines.

Summary

Hopefully after reading this post you feel more informed about how organic food is grown and what substances may and may not be used in and on it. In the next post, we’ll learn about USDA Organic categories and what the USDA Organic label means.

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Organic Food – USDA National Organic Program

The 15 people sitting on the National Organic Standards Board control what goes in and on food sold as USDA Organic in the U.S. That’s a lot of power.

I’d never even heard of the National Organic Standards Board until a month or so ago. It all started, as many things do, at the dinner table.

Ever since my spouse and I decided to make a conscious effort to eat food we feel is healthier for us and the planet, USDA Organic food has increasingly found its way into our shopping basket and on to our table.

Bunch of Organic CarrotsOne night during dinner, my son and I were having a friendly debate about organic food. “Is it really better for people and the environment?” “Is a benign pesticide even possible?”

Suddenly it struck me. I didn’t actually know what the USDA Organic label meant. Now I had to find out.

I decided to investigate organic food and share what I learned. My search began with a look back at the roots of organic food which led to the first post, Organic Food – History. This post will briefly look at the Organic Foods Production Act and delve into the framework of the National Organic Program. Another post will deal specifically with what the USDA Organic label means.

Organic Foods Production Act of 1990

After several decades of growing public concern about the environment and food safety, and increasing interest in organic farming and food, the U.S. Congress passed the Organic Foods Production Act of 1990 as part of the Food, Agriculture, Conservation, and Trade Act of 1990 (commonly known as the Farm Bill).

The purpose of the law was threefold:

  1. To establish national standards for organic agricultural products (food and non-food crops and livestock).
  2. To assure consumers organic products meet a consistent standard.
  3. To facilitate interstate commerce of organic food.

The law’s main provisions are summarized under the National Organic Production Program section:

  • It authorized and required the Secretary of Agriculture to establish a national organic certification program.
  • It permitted each state to implement a state organic certification program that could be more stringent as long as it complied with federal requirements.
  • It established a National Organic Standards Board and a National List of Allowed and Prohibited Substances.
  • It directed the Secretary of Agriculture to implement the program via certifying agents which could be state representatives or private entities.

National Organic Program

The National Organic Program (NOP) resides under the USDA’s Agricultural Marketing Service (AMS). It is overseen by the AMS Administrator and run by the NOP Program Manager.

Old Creek Ranch Organic Farm

Organic production is defined as: “A production system that is managed in accordance with the Organic Foods Production Act and regulations to respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.” 1

National Organic Standards Board

The National Organic Standards Board (NOSB) is responsible for proposing substances to be included on or removed from the National List of Allowed and Prohibited Substances, and advises the Secretary of Agriculture on other aspects of the NOP.

The 15 people who make up the Board are appointed by the Secretary of Agriculture and serve for 5 years. The NOP stipulates the Board makeup as follows:

  • People in a Meeting at Conference Table4 – people who own or operate an organic farm
  • 2 – people who own or operate an organic handling operation
  • 1 – person who owns or operates a retail establishment with significant trade in organics
  • 3 – people with expertise in environmental protection and resource conservation
  • 3 – people who represent public or consumer interest groups
  • 1 – person with expertise in toxicology, ecology, or biochemistry
  • 1 – person who is a certifying agent

Proceedings of the NOSB are regulated by the Federal Advisory Committee Act which requires meetings be open to the public, committee procedures be documented, meeting minutes be taken and published, an officer or employee of the federal government be present at all meetings, and the Library of Congress retain at least eight copies of all reports.

In theory anyone can nominate themselves or anyone else for a vacant Board member seat, however the practice seems to be new members are invited by the current Board.

I looked up the bios (probably self-written) of the current NOSB members. They appear to be educated people with organic experience, but in some cases their areas of expertise did not seem to match the position they held on the Board.

National List of Allowed and Prohibited Substances

The National List of Allowed and Prohibited Substances, known as the National List, is a critical component of the NOP. This National List identifies which synthetic substances may be used and which natural substances may not be used to grow crops, raise livestock, and process packaged foods.

The National Organic Standards Board develops a proposed list of substances for inclusion and removal from the National List for review and approval by the Secretary of Agriculture.

We’ll look at the details of the National List in a future post.

Accredited Certifying Agents

The AMS Administrator accredits domestic or foreign certifying agents who in turn certify organic production and handling operations.

Certifying agents must demonstrate expertise in organic production and handling, have sufficient and adequately trained staff, maintain records for 5 years, respect client confidentiality, and prevent conflicts of interest

Once approved, accreditation is for a period of 5 years and can be renewed indefinitely as long as the agent complies with the NOP, pays an annual fee, and submits an annual report.

Certified Production and Handling Operations

A production operation is a farm or ranch engaged in growing or producing food,  livestock, fiber, feed, or other agricultural products. A handling operation receives organic agricultural products then processes, packages, and stores them (this does not include retailers who do not process products). A producer may also be a handler.

Certification requirements include:

  • Burlap Sack of Organic Coffee BeansDemonstrate ability to comply with NOP and organic standards.
  • Establish, implement, and annually update an organic system plan that describes how the operation is run, lists each substance used, and documents monitoring and recordkeeping practices.
  • Permit on-site inspections and testing of samples.
  • Maintain records for at least 5 years.
  • Notify the certifying agent of application of prohibited substances or issues with compliance.

After initial approval, certification continues as long as the operation complies with the NOP, and on an annual basis pays a fee, submits required documentation, and passes an on-site inspection.

Any production or handling operation that sells agricultural products as “organic” in the U.S. must be certified unless their gross income from organic sales is $5,000 or less.

Domestic and foreign production and handling operations wishing to label products as USDA Organic may apply for organic certification.

A database of USDA certified organic operations is available on the NOP website.

Compliance and Violations

Judge's Wooden GavelAt the top of the food chain so to speak is the National Organic Program’s Program Manager who has the authority to inspect and review certified operations and certifying agents and initiate suspension, revocation, or other proceedings if they believe there is a violation.

The NOP Program Manager oversees compliance of accredited certifying agents who in turn ensure compliance of certified operations.

A certifying agent whose accreditation is revoked cannot reapply for 3 years.

If a certified operation has its certification revoked it cannot reapply for 5 years. In addition, anyone who knowingly labels or sells a product as organic that isn’t, faces a civil penalty of up to $11,000. The financial penalty seems miniscule, especially for a huge company, but perhaps the threat of having ones certification revoked for 5 years helps keep companies in line.

Any person who suspects a violation of NOP regulations may file a complaint via the NOP website.

Summary

We’ve learned about general requirements for becoming an accredited certifying agent or certified organic operation, the makeup and role of the National Organic Standards Board, what the National List is, and what happens to those who violate the NOP.

The next posts in this series will take a more in depth look at organic production and handling requirements, the National List, and USDA Organic labeling.

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References:

  1. U.S. Government Printing Office – Electronic Code of Federal Regulations – National Organic Program – Section 205.2 Terms Defined

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