Organic Farming Editing and Proofreading Services

Ninety-five percent is the line between two different labels. Under 7 CFR 205.301(b), a product sold as "organic" must contain, by weight or fluid volume and excluding water and salt, "not less than 95 percent organically produced raw or processed agricultural products."¹ A multiingredient product that reaches 70 percent but stays below 95 comes under 205.301(c), and may be sold as "made with organic (specified ingredients or food group(s))."¹ The regulations attach a different set of label provisions to each of those two categories.

Four categories set by one number

The composition figure sorts a product into one of four groups. At 100 percent, again excluding water and salt, 205.301(a) sets the composition required of a product labeled "100 percent organic."¹ The two middle groups are the ones named above. Below 70 percent, 205.301(d) requires the organic ingredients of a multiingredient product to have been produced and handled under subpart C.¹

What each group may print is set out separately. Section 205.304(a)(1)(i) allows a "made with organic (specified ingredients)" statement provided it "does not list more than three organically produced ingredients."² Paragraph (a)(1)(ii) allows a "made with organic (specified food groups)" statement naming no more than three groups from a closed list.² Where a food group is named, "all ingredients of each listed food group in the product must be organically produced."²

A product below 70 percent "may only identify the organic content of the product by" two means, and the second depends on the first.³ Paragraph (a)(1) covers identifying each organically produced ingredient in the ingredient statement, with the word "organic" or with a reference mark defined below that statement.³ Paragraph (a)(2) then allows the percentage of organic contents on the information panel, "if the organically produced ingredients are identified in the ingredient statement."³

One fraction, applied three times

Three provisions set the same typographic limit. For a product labeled "organic," 205.303(a)(2) covers the percentage of organic ingredients on the panel. The size of that percentage statement "must not exceed one-half the size of the largest type size on the panel on which the statement is displayed."⁴ Section 205.304(a)(1)(iii) requires the "made with organic" statement to appear "in letters that do not exceed one-half the size of the largest type size on the panel."² Section 205.304(a)(2) applies the same fraction to the percentage statement on a "made with organic" package.² Two govern a percentage and one governs a form of words, and all three measure it against the largest type on the panel.

What may go anywhere, and what may not

The main placement rules are permissive. Section 205.303(a) provides that an "organic" or "100 percent organic" product "may display, on the principal display panel, information panel, and any other panel of the package," the items listed there.⁴ Section 205.304(a) opens comparably, allowing a "made with organic" product to "display on the principal display panel, information panel, and any other panel."²

Two provisions do fix a location. The first is 205.303(b)(2), which requires the certifying agent to be identified on the information panel, below the information identifying the handler or distributor.⁴ The name is "preceded by the statement, 'Certified organic by * * *,' or similar phrase."⁴ The second is 205.303(b)(1), which reads on products labeled "organic" and fixes the ingredient statement as the place where each organic ingredient is identified.⁴ It adds that water or salt included as ingredients "cannot be identified as organic" there.⁴

Which packages may show a seal

The USDA seal is available to two of the four groups, under 205.303(a)(4).⁴ Paragraph (a)(5) permits the certifying agent's seal or mark on two provisos. The handler must maintain records verifying organic certification of the operations producing the ingredients, and such marks must be "not individually displayed more prominently than the USDA seal."⁴

Two groups are shut out. Under 205.304(c), a "made with organic" product must not display the USDA seal.² Under 205.305(b), a product below 70 percent must display neither the USDA seal nor any certifying agent seal, logo, or other identifying mark "which represents organic certification of a product or product ingredients."³

The document behind the wording

One document governs the label without appearing on it. Under 7 CFR 205.201(a), an operation intending to label products in any of the three certified categories must develop an organic production or handling system plan.⁵ The plan is agreed to by the producer or handler and an accredited certifying agent, and the section lists six required elements.⁵ Among them are a description of practices and procedures, a list of each substance to be used as an input, and a description of the recordkeeping system.⁵

Where the reading stops

Composition, certification status, and whether an ingredient qualifies as organically produced are settled by the operation and its certifying agent. An editor is not the person to reopen any of them. Our reading covers the panels and the numbers printed on them. Setting a front-of-package claim beside the ingredient statement behind it shows where the two texts differ. Setting a percentage stated in one place beside the percentage stated in another shows whether they are the same figure. Confidentiality covers everything a client sends. When a panel is redrawn, the wording, the placement, and the type-size limits all have to be read again.