100% Organic vs. Organic:
Setting the Record Straight

By Sarah Fister Gale


UNLESS A PRODUCT IS MADE UP ENTIRELY OF 100 PERCENT ORGANIC INGREDIENTS, IT CANNOT WEAR THE 100% ORGANIC LABEL.

Pardon the yelling, but someone needed to set the record straight.

Even though it is going on two years since the National Organic Program (NOP) published regulations outlining the requirements necessary to use the various organic labels, processors are still perplexed over the difference between “organic” and “100% organic,” as well as exactly what needs to be done to achieve those standards.

The NOP rule regulating and defining what it means to be organic and what is required to put organic labels on products was a tremendous step forward for the organic industry. It took the guess work out of buying organic and legitimized an industry that was rapidly expanding into markets nationwide. However, it also added a layer of confusion for producers on how to determine just how “organic” their products are—or should be.

For many producers, the organic label, which certifies that a product is made up of at least 95% organic ingredients, is a great achievement. It proclaims to consumers that their products are healthy, safe and made with the highest organic production and handling standards. “It’s a great label,” says Grace Marroquin, president of Marroquin International, an organic ingredient supplier based in Santa Cruz, CA. “It represents a significant value and commitment to organics.”

The organic label is especially appealing for processors of multi-ingredient foods because they can achieve that label without compromising on consumer expectations of taste or structure, she adds. The label gives manufacturers the flexibility to use approved minor non-agricultural additives or processing aids that don’t hinder the organic integrity of the product.

But for some, the organic label isn’t enough.

What’s More Organic than “Organic”?
Included in the NOP rule are guidelines for a “100% organic” label, which indicates that a product is made up entirely of 100 percent organic ingredients. Processors, striving to meet the “more is better” attitude of American consumers are drawn to the 100% organic label, which promises to be even more organic than “organic,” but they are struggling to understand just what it takes to meet the standards.

What do you have to do to get the coveted 100% organic label on a product?
Part of the problem, say many experts, is that the verbiage of the original rule outlining the guidelines for organic labeling were somewhat vague. The body of the rule states that “a raw or processed agricultural product sold, labeled, or represented as “100% organic” must contain (by weight or fluid volume, excluding water and salt) 100 percent organically produced ingredients.” The confusion lies in what constitutes “100% organically produced ingredients.” Many processors assume that if 100 percent of their ingredients are certified organic than the product can be certified as “100% organic.” But they are wrong, says Marroquin. who finds herself routinely clarifying the 100% rule to new customers.

Because something labeled “organic” only needs 95 percent of its ingredients to be organic—assuming the rest of the ingredients are not available in organic form and are on the NOP’s approved non-agricultural ingredients list—products made using all “organic” ingredients can wear the organic label. While some ingredients, such as produce or meat, may in fact be 100% organic, it’s likely that other major or minor ingredients added, such as sugar or starch, are not. Even though they are “organic” and approved by the NOP, they don’t qualify as “100% organic,” and they may impact the organic percentage of the product if one is striving toward the 100% claim. In other words, if you use all “organic” ingredients to make a product, your product is still “organic 95%+.”

The “100% organic” label can only be used on products that are made entirely out of ingredients that have been certified as “100% organic.” There cannot be even the tiniest bit of non-agricultural additives or processing aids used in the making of a 100% organic product, since even a one-hundredth of a percentage point of a non-agricultural substance eliminates the possibility of using the label.

The guidelines for the rule are made clear in the preamble, which states that “this regulation allows a ‘100% organic’ label on: (1) agricultural products that are composed of a single ingredient such as raw, organically produced fruits and vegetables and (2) products composed of two or more organically produced ingredients, provided that the individual ingredients are, themselves, wholly organic and produced without any non-organic ingredients or additives. Only processing aids that are themselves organically produced, may be used in the production of products labeled ‘100 percent organic.’” But many users skip the preamble, leading to the need for clarification.

Marroquin feels that the 100% organic label has caused more trouble than its worth, sending processors on an organic wild goose chase for ingredients that don’t exist, and impacting the strength of the “organic” label. “‘Certified organic’ was pretty well understood until “100% organic” came along,” she says, exasperated by the misunderstanding it has caused and the loss of appreciation for the high value of the organic 95%+ label.

’t Be Done: But Should You Try?
On top of being confusing, many processors don’t realize how difficult or even impossible it is to make a “100% organic” processed product, says Chris Schreiner, quality control director for Oregon Tilth, an organic certifier based in Salem, OR. “Many multi-ingredient products qualify for the “organic” label but few can get the ‘100%’ label,” he says.

About 60 percent of the 360 handling and processing operations certified by Oregon Tilth process or handle 100% organic products, but most of those are single ingredient products, such as milled flour, juices, bulk milk and meat. “Most processed foods require non-agricultural ingredients as a key function of the formula, and as soon as one gets used it bumps down the organic percentage.”

That is the stumbling block for processors. It’s not difficult to find primary products that are 100% organic, but there are always one or two required ingredients that are simply not available in 100% organic form. Marroquin gets calls weekly from customers so excited that she has organic malodextrin because they think it will get them the “100%” label. When she explains the difference between “organic” and “100% organic” they get “so frustrated and disappointed,” she says.

Other commonly used products, such as sugar and starch, cannot yet be certified as 100% organic. There are few known organic processing aids besides organic rice hulls because most processing aids are non-agricultural. If a product is vitamin fortified it isn’t 100% organic, which eliminates low-fat and fat-free milk products. “A lot of manufacturers just don’t understand that the ingredients they need are just not available,” says Marroquin.

Unless you are selling raw agricultural produce, single-ingredient products, such as fresh pressed organic juices, or combinations of raw organic products, such as trail mixes, it is difficult to meet the 100% organic standards for consumer products. Even when processors do find organic options, such as organic corn starch or corn syrup solids, they may not be “100% organic,” which impacts the organic percentage of a product, if only by a tenth of a percent.

Until more organic alternatives are found, the “100% organic” label will continue to be difficult to achieve, says Andrea Caroe, who holds an environmentalist member position with the National Organic Standards Board (NOSB). Because the cost of developing new 100% organic ingredients or processing aids is significant, the market for such ingredients has to grow before the time and money is spent on research. “It has to be profitable so that researchers can recoup the investment,” she says.

Caroe hopes that as the industry grows and interest in both labels increases, it may trigger more research. “We see a lot of interest in creating organic yeasts, foaming agents and release aids for baking,” she says. But she admits that progress is slow. “Some ingredients are just never going to be organic until demand warrants the investment.”

More Trouble Than It’s Worth?
While some companies continue their struggle to find the perfect 100% organic formula, others forgo the label, even though it’s attainable for some of their products. The decision is usually because the combination of labels would confuse consumers, or the changes required to the formula would impact taste, color or clarity of the product.

Horizon Organic Dairy, maker of certified organic milk and dairy products in Longmont, CO, made the decision not to pursue the “100% organic” label for any of its products even though they have some dairy products and juices that would qualify. “We feel it is a disincentive for consumers if some of our products are labeled ‘organic’ and others ‘100% organic,’” says Kevin O’Rell, vice president of research and development and quality assurance and processor member of the NOSB. It is confusing, especially as it relates to milk products.

Horizon’s milk isn’t 100% organic because it is fortified with vitamin D, which drops it to 99.97% organic. Horizon could opt not to include vitamin D, which isn’t available in a 100% organic form, but it chooses to because of the benefits that vitamin fortification provides. “Consumer perception is that vitamin D is a good, healthy thing that increases calcium absorption. That’s more important than the label,” O’Rell says.

Horizon is also required to add vitamin A to reduced fat and fat-free milk products, according to federal regulations, which affects the organic percentage. Instead of explaining the percentage rule to consumers, who are already drawn to the milk’s purity, Horizon prefers to use the “organic” label for all of its products. “We feel being certified organic is a great thing,” he adds. “Feedback from Horizon consumers says the organic label means something to them.”

Similarly, J.M. Smucker Quality Beverages in Chico, CA, is cautious about pursuing the 100% organic label for its juices, even though it uses only 100% organic fruit, says Kim Dietz, the company’s human resources and regulatory compliance manager. Many of the juices include a small amount of ascorbic acid for color and enzymes for clarity. The additives drop the juices’ organic content to roughly 99.9%, which means they use the “organic” label, but it’s worth it, Dietz says, to make a better tasting product.

Unlike Horizon, J. M. Smucker, does have a handful of juices that wear the “100% organic” label. They are simple fresh pressed juices, that have no additives and use only organic rice hulls as processing aids. “I’ve always advised that if we can put a product in the 100% organic category we should,” Dietz says. At first the company didn’t think it would be a strong label with consumers, but they have since changed their mind and use it whenever it’s appropriate. “It gives our product a slight competitive advantage and makes it distinct to consumers.”

Do Consumers Really Care?
However, not everyone agrees with that theory. The “100% organic” label is not much of a selling tool, according to Michele Barry, vice president of qualitative research for The Hartman Group, a Bellevue, WA-based research consulting firm. Over the past two years, The Hartman Group has done seven studies on organic consumers, focusing much of their research on buying habits and response to labeling. According to the studies, the “100% organic” label, while seeming to give products a slight edge over the competition, doesn’t carry a lot of weight with most organic consumers.

Hartman breaks organic consumers into three categories, says Barry. “Peripheral” users, who make up 25 percent of the consumer market, are organic dabblers. They use one or two key gateway products, such as milk or produce but have no commitment to any product or company. “Middle” users, are the largest group making up about 65 percent of the consumer market. They are committed to using certain organic ingredients or products and are experimenting with others. They may one day become core users, but for the moment they go back and forth between organic and mainstream products. “Core” users are committed and consider themselves organic gurus. “They are the most educated about organic rules and labels and see organics as a complete lifestyle,” says Barry, who considers herself a core user. They make up only six to 10 percent of organic buyers.

Using these breakdowns, Hartman’s research shows that peripheral users have a difficult time understanding the differences between “natural foods” and “organic foods,” and see little distinction between the various organic labels. “They will typically look for a natural foods section at the supermarkets and sample a few organic products, often for their children,” Barry says. “They are not hung up on labels.”

“The middle group vacillates,” she admits. They have no idea whatsoever the difference between “organic,” “100% organic” and “made with organics” labels but they do know about genetically modified organisms (GMOs) and read ingredient lists on the Nutrition Facts Panel. She also says they are not committed to organics or whether one product is purer than another, instead they are more likely to make choices based on taste and price. They also put more faith in simpler organic products, such as produce, milk, or meat. “The more processed a product is the less of an organic connection is made for this group.”

The core users are very knowledgeable about the different labels, she says. “They know what the final rule is, they read labels and they are familiar with 100 percent organic products.” However, even this group is not guaranteed to choose “100% organic” products over “organic” products. “The organic lifestyle is about peace of mind not percentages,” she says. “Core users are often brand loyal and their choices are tied up with the values of the company and their ideology about how the world works.” This is especially true if they perceive the company selling “100% organic” products to be a large corporate entity, she adds. “Supporting local businesses and family farming is often more important than what the label says.”

In the end, even the core group will only choose a “100% organic” product if there are other factors to support the choice, such as brand loyalty, or its a tie breaker with an organic product. “The value to consumers of the 100% label is relatively low,” Barry says. “If anyone responds to it, it is the core users who make up a tiny percentage of the market, and even for them it’s a fairly benign label.”

That being said, Barry envisions a time when things could change and the 100% organic label would carry more weight. As time goes on and middle users become core users, she believes people will pay more attention to food safety and food labels. At that time the 100% label may become higher a priority, she says, but it may not happen for 10 years or more.

In the meantime, even though the demand for 100% organic products is small and the number of products with the 100% label limited, most experts agree that the label is a good thing because some consumers want the option to select ultra-pure products. “The ‘100% organic’ label has its place,” insists Caroe. “It was a sophisticated response to consumers who wanted a program tailored for both ends of the market.”

Sarah Fister Gale is Contributing Editor with Organic Processing Magazine.
Fister Gale can be reached via e-mail at sarah@organicprocessing.com.