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!!