Submit Your Comment to NOP on Percentage of Organic Ingredients

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Date Published: 
January 17, 2017

Tell the National Organic Program (NOP) how significant proposed changes to calculating the percentage of organic ingredients could affect your products.

NOP has issued a draft guidance "Calculating the Percentage of Organic Ingredients in Multi-Ingredient Products (NOP 5037)" that is available for public comment through February 6, 2017.

If you do any of the following, this guidance could affect how the organic content of your product is calculated and require you to change labels or formulas:

  • If you add salt to your products or use ingredients that contain salt
  • If you add water to your products or use ingredients that contain water, including coffee, tea, juices, broth, stock, etc.; regardless of whether you purchase those ingredients yourself or produce them in-house
  • If you add water to any concentrated ingredient to reconstitute it or bring it to single strength
  • If you produce carbonated beverages

Do you know the exact weight of salt or water in the ingredients that you purchase? Are you able to provide information about Food and Drug Administration (FDA) standards of identity, brix levels, and soluble solids content of your products that contain water? If the guidance is finalized, you may be required to provide this information.

Be sure to send your comments to NOP to ensure your voice is heard before this draft guidance is finalized. Submit your comments via Additional information is available in the Federal Register notice informing the public that the draft guidance is open for comment. Refer to the NOP standards section 205.302 to see the original section of the regulation that this guidance addresses.