Organic Red Tape

As I was checking over my list of requirements this afternoon, making sure we are doing everything by the book, I came across info about labeling a food product as “organic”.  Complex is an understatement.  I spent the rest of the afternoon on the phone trying to figure out what we can and cannot say.  The best part is that there is no right answer.  Not sure how we are going to figure this out, but I have less than 24 hours to do so.  Our dieline for our box has to be finished by Monday.  It doesn’t help that tomorrow is Friday!


After four phone calls, three hours of conversations, and reading and highlighting a 25 pg. PDF on “Organic Labeling”, the short version is this:


If you are using organic ingredients in your product you fall under one of the below categories:

“100% organic”- your entire product contains only organic ingredients.

“Organic”- 95% or more of your ingredients are organic.

“Made with organic ingredients”-70%-95% of your ingredients are organic.

“Less than 70% organic ingredients”- the category we fall into.


If you have 70% or more organic ingredients in your food product, and you want to make a claim on your package that you use organic ingredients, you have to get certified by the NOP (National Organic Program).  I don’t know what this entails exactly, but I do know that it doesn’t happen overnight.  You either have to find an agent in your state to work with, and there is only one agency in the state of MA, or you use a global agent. I hounded the agency in MA, and they were extremely helpful. I think they sensed the desperation in my voice…


You can only get certified through the NOP if your product is at least 70% organic.   Our product is not.  I honestly don’t know if this is a good thing or bad thing. It’s 65% organic for two of our flavors, and 61% organic for the other one.  We can’t even say, “Made with organic ingredients” or “Made with organic popcorn”. Coulter never wanted to list organic kernels on our front panel (PDP in industry speak), and it turns out that we couldn’t do this even if we had wanted to!


So those that have 70% or less organic ingredients in their product can pretty much only write the word organic in the ingredients section below the nutritional label.   We MIGHT be able to list organic kernels on our information panel, which is on the back of our box, but our safe option is to just list the organic kernels under our ingredients section. This safe option does not appeal to me!


I searched high and low for the best organic popcorn kernels, I found them, I am proud we are using them, and I want to display this on our informational panel.   When it comes down to it, our kernels are certified through the NOP, the farm is certified organic, they have been verified/certified through The Non-GMO Project, our bags are being filled on their site, in their facility! The family owned farm/business pretty much started the organic corn revolution! That all said, we should be able to clearly state that we are using organic corn kernels on our package!


Oh, we also can’t say we use “pure ingredients”… don’t get me started on this one. This is a post for another day!


The gist of all this is that I had no idea that we needed to get certified in order to make an organic claim on our package.  Since we actually can’t get certified, because we don’t’ fall under the 70% or more category, I’m not sure how this will end up.


We are almost done with our box, and will probably have an image for you early next week!  Thanks for all of your feedback and your support!!




  1. IAN wrote:

    Hey Kristy! love your website/blog posts. This one particularly struck a cord with me as I have been through the investigation of labeling my companys products organic as well. We actually made it 95% of the way until we we’re stopped by the fact that because the 2% of almond flour we use in our macaroon product is not organic (it’s non-gmo!) we could only claim “made with organic ingredients” on our packaging and not be allowed to use the USDA seal. The reason why we couldn’t state anything other than “made with organic ingredients” is because we could be using an organic almond flour but choose not to. Only catch for us is that the organic almond flour they told us to use is a course grind and not a fine flour… course grind does not work for our product. It wasn’t worth it for us after that. Instead, we chose to certify our products non-gmo – Check it out, it’s actually building itself up to be a viable certification seal. It was started by buyers/retailers, which I think is very neat and direct.

    do you know if you can say on your website “made with organic ingredients” just not on the packaging?

  2. Kristy wrote:

    Hi Ian,

    Thanks for the email and for the kind words! I think you guys would qualify for 98% organic. You can state that on the front of your package. Did you look into this?
    I would love to try your granola. Where do you currently sell it?
    We are actually working with the Non-Gmo Project in getting Quinn Popcorn verified. It’s a long process, and we probably won’t accomplish this until a year from now. We are using rBST free cheese, but our milk is not organic, and it’s not from grass fed cows. We have two options, go with organic milk, or go with grass fed cows. We are trying to figure both of this out right now! ( The good thing is that Quinn Popcorn is non-gmo, but we would just love to get that extra seal of approval!)

    Yes, you can say it anywhere on your website, and in your tear sheet, just not on the outside of any display packaging!

    Thanks again, Ian. Great to hear from you!