"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

    How an 85% organic product may be labelled by market
    MarketTier recognised?Permitted front-of-pack claimLogo
    New ZealandYes, 70–94%"Made with organic [ingredients]"Certifier logo not permitted front of pack
    AustraliaYes, in practice via certifier standards"Made with organic [ingredients]"Bud logo not permitted below 95% organic (ACOS 3.5.15)
    United StatesYes, 70–94% under USDA NOP"Made with organic [up to three named ingredients]"USDA seal prohibited
    European UnionNo such tierNo front-of-pack organic claim at allEU leaf prohibited
    An 85% product that sells happily in New Zealand cannot carry any organic claim on the front of an EU pack. This is the single most expensive surprise in organic export.

    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:

    1. Find a certified source for the largest conventional ingredient. One substitution often moves a recipe several percentage points.
    2. 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.
    3. 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.
    4. 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

    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.

    Related

    Find out which tier your recipe lands in

    The calculator applies the exclusions for you and returns the tier for each market you sell to.