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.
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