# Can I call my product organic? A decision tree for New Zealand

> You may call a product organic in New Zealand if it is certified by a recognised certifier and at least 95% of its agricultural ingredients by weight are certified organic, excluding water and salt. Between 70% and 94% you may say "made with organic [ingredient]" but not call the product organic. Below 70% you may only name organic ingredients in the ingredient list.

Source: https://anzoc.co.nz/resources/can-i-call-my-product-organic-nz
Published: 2026-09-28 · Last updated: 2026-09-28 · Author: Fliss Roberts, ANZOC

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## Five questions, in order

Each question gates the next. Failing any one of the first three means the answer is no regardless of the percentage.

1. **Is the production site certified?** An organic claim covers the process, not just the inputs. If the site where the product is made is not certified — including a contract manufacturer — the product cannot carry an organic claim.
2. **Is every ingredient you are counting as organic covered by a current certificate?** The certificate must name the product you are buying, and must be current on the date of delivery.
3. **Is every additive and processing aid permitted?** A single non-permitted substance disqualifies the product from every organic tier, whatever the percentage says.
4. **What is the organic percentage of agricultural ingredients by weight, excluding water and salt?** This determines the tier.
5. **Does the claim you want to make match that tier, in every market you sell to?** The tiers are not the same everywhere.

## What each answer lets you say

| Your situation | What you may say | What you may not say |
| --- | --- | --- |
| Certified, 95% or more organic | "Organic [product]", "Certified Organic", certifier logo on front of pack | Nothing further restricted |
| Certified, 70–94% organic | "Made with organic [named ingredients]" on front of pack, organic ingredients named in the ingredient list | "Organic [product]" in the product name; certifier logo on the front of pack |
| Certified, under 70% organic | Organic ingredients identified in the ingredient list, e.g. "organic cane sugar" | Any front-of-pack organic claim; any organic logo |
| Not certified, any percentage | Nothing that represents the product as organic | "Organic", "certified organic", "made with organic", organic logos, and imagery or wording that implies certification |

> **The most common breach** — Putting "Organic" in the product name when the product only qualifies for the 70–94% tier. A 92% product is not an organic product; it is a product made with organic ingredients, and the distinction is enforceable.

## What if I am not certified yet?

Until the National Organic Standard becomes mandatory on 31 March 2028 there is a widespread assumption that organic claims are unpoliced. That is not right. The **Fair Trading Act 1986** already prohibits misleading representations, and an organic claim you cannot substantiate is a misleading representation today, with or without the new regime.

What you can do while certification is in progress is describe what is true and verifiable: name the certified organic ingredients in the ingredient list, state factual production practices you can evidence, and avoid any wording, colour scheme or imagery that implies a certification you do not hold.

## Land in conversion, and products from it

Land moving from conventional to organic management goes through a conversion period before its output counts as organic. Produce harvested during conversion is not organic and cannot be counted in the organic portion of your percentage, although some standards permit a specific "in conversion" descriptor under defined conditions. Your certifier will tell you which descriptor, if any, is available to you and exactly how it must be worded.

## Questions people ask

**Can I call my product organic if all the ingredients are organic but my factory is not certified?**

No. Certification covers the process. An uncertified site cannot produce a certified organic product, regardless of how the ingredients were grown. Either certify the site or use a certified contract manufacturer.

**Is 94% organic enough to call a product organic?**

No. The threshold is 95% of agricultural ingredients by weight, excluding water and salt. At 94% the product falls into the "made with organic" tier, which does not permit "organic" in the product name or the certifier logo on the front of pack.

**Can I say "made with organic ingredients" generically?**

Not in the United States, where the claim must name the specific organic ingredients and may name no more than three. Treat the generic phrasing as unsafe: name the ingredients you mean.

**Does the Fair Trading Act apply before 2028?**

Yes. The Fair Trading Act 1986 applies now and always has. The 2028 date is when the National Organic Standard becomes mandatory, not when organic claims first become regulated.

**What about "natural", "spray-free" or "chemical-free"?**

None of these are organic claims and none of them are certified terms, but all of them are still representations under the Fair Trading Act and must be substantiated. "Chemical-free" in particular is very hard to substantiate for any food.

## Sources

- [Fair Trading Act 1986 — New Zealand Legislation](https://www.legislation.govt.nz/act/public/1986/0121/latest/DLM96439.html)
- [Organic Products and Production Act 2023 — New Zealand Legislation](https://www.legislation.govt.nz/act/public/2023/0053/latest/whole.html)
- [MPI — Organic product requirements in NZ](https://www.mpi.govt.nz/agriculture/organic-product-requirements-in-nz)

## Related

- [How to make a certified organic product in New Zealand](https://anzoc.co.nz/resources/how-to-make-a-certified-organic-product)
- ["Made with organic": what the claim allows in NZ](https://anzoc.co.nz/resources/made-with-organic-claim-nz)
- [What you may print on the pack, word by word](https://anzoc.co.nz/resources/organic-label-wording-rules)

This page is general guidance, not certification advice. Your certifier makes the final decision.
