"Made with organic": what the claim allows in New Zealand
"Made with organic" is the labelling tier for products whose agricultural ingredients are 70% to 94% certified organic by weight, excluding water and salt. It permits naming the specific organic ingredients on the front of pack — "made with organic oats and apples" — but not calling the product itself organic, and not the certifier logo on the front. The European Union does not recognise this tier at all.
Last updated: 28 September 2026 · Written by Fliss Roberts, ANZOC
What the tier is for
Most real products sit between 70% and 94% organic. A sauce needs a stabiliser that has no certified organic source at commercial volume; a baked good needs a raising agent; a beverage needs an acidulant. The 70–94% tier exists so those products can tell the truth about their organic content without either overstating it or hiding it.
The trade-off is precision. At 95% you get to describe the product. Between 70% and 94% you only get to describe the ingredients, and you have to name them.
The same product, four markets
| Market | Tier recognised? | Permitted front-of-pack claim | Logo |
|---|---|---|---|
| New Zealand | Yes, 70–94% | "Made with organic [ingredients]" | Certifier logo not permitted front of pack |
| Australia | Yes, in practice via certifier standards | "Made with organic [ingredients]" | Bud logo not permitted below 95% organic (ACOS 3.5.15) |
| United States | Yes, 70–94% under USDA NOP | "Made with organic [up to three named ingredients]" | USDA seal prohibited |
| European Union | No such tier | No front-of-pack organic claim at all | EU leaf prohibited |
Getting the wording right
- Name the ingredients. "Made with organic oats and sunflower oil", not "made with organic ingredients". The United States explicitly prohibits the generic form and caps the named ingredients at three.
- Keep it smaller than the product name. The phrase must not exceed the product name in font size.
- Do not let it read as the product name. "Organic Muesli — made with organic oats" makes an organic product claim in the name and fails, even though the qualifier below it is accurate.
- Name only ingredients that actually are certified organic. If the sunflower oil is conventional, it cannot appear in the claim.
- State the percentage where required. Some standards require the organic content percentage to be stated when a "made with" claim is used. Check which applies to your markets before artwork.
Getting from 85% to 95%
If the EU is a target market, the 70–94% tier is not a destination — it is a problem to engineer out. The usual routes, in order of how often they work:
- Find a certified source for the largest conventional ingredient. One substitution often moves a recipe several percentage points.
- Reduce the conventional ingredient rather than replace it. A stabiliser at 0.4% instead of 1.2% may be a formulation question, not a sourcing one.
- Check whether the ingredient is agricultural at all. Non-agricultural additives and processing aids sit outside the calculation entirely, so removing them from your mental arithmetic sometimes reveals you were already above the line. What counts in the calculation.
- Unpack your compound ingredients. A bought-in blend recorded as one conventional line may be 80% organic itself. How compound ingredients work.
Questions people ask
- Can I use "made with organic" in the European Union?
- No. The EU organic regulation has no 70–94% tier. An EU pack either qualifies for a full organic claim or carries no front-of-pack organic claim at all; organic ingredients may still be identified in the ingredient list.
- How many ingredients can I name in a "made with organic" claim?
- Up to three under USDA NOP, and the generic form "made with organic ingredients" is not permitted. Naming the specific ingredients is good practice in every market regardless.
- Can a "made with organic" product use the certifier logo?
- Not on the front of pack. Certifier logos, the USDA seal and the EU leaf are reserved for products at 95% or above. Australian Certified Organic sets this out explicitly at ACOS 3.5.15 for the Bud logo.
- Does the 70% threshold include water and salt?
- No. The percentage is calculated on agricultural ingredients only. Water and salt are excluded from both the organic weight and the total weight, so a heavily watered product is not penalised — or helped — by its water content.
- Is "made with organic" worth doing, commercially?
- It depends entirely on the market. Domestically it is an honest and defensible position. For EU export it is a dead end, because the tier does not exist there, so the packaging and claim work has to be redone.
Sources
- USDA NOP 5032 — Products in the "Made with Organic ***" labeling category
- USDA AMS — Labeling organic products
- Regulation (EU) 2018/848 on organic production and labelling
- Organic Standards Regulations 2025 — New Zealand Legislation
This page is general guidance, not certification advice. Your certifier's decision is the one that counts — check anything that changes what goes on a label with them before you print.