# "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. Source: https://anzoc.co.nz/resources/made-with-organic-claim-nz Published: 2026-09-28 · Last updated: 2026-09-28 · Author: 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* | 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 | 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. > **The logo trap** — Certifier logos, the USDA seal and the EU leaf are all reserved for 95%+ products. A "made with organic" pack carrying any of them is non-compliant even when the words are perfect, and this is the error that most often gets caught at the border rather than in the studio. ## 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](/resources/organic-ingredient-rules-what-counts). 4. **Unpack your compound ingredients.** A bought-in blend recorded as one conventional line may be 80% organic itself. [How compound ingredients work](/resources/compound-ingredients-organic-percentage). ## 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](https://www.ams.usda.gov/rules-regulations/organic/handbook/5032) - [USDA AMS — Labeling organic products](https://www.ams.usda.gov/rules-regulations/organic/labeling) - [Regulation (EU) 2018/848 on organic production and labelling](https://eur-lex.europa.eu/eli/reg/2018/848/oj) - [Organic Standards Regulations 2025 — New Zealand Legislation](https://www.legislation.govt.nz/secondary-legislation/pco-drafted/2025/197/en/latest/) ## Related - [Can I call my product organic?](https://anzoc.co.nz/resources/can-i-call-my-product-organic-nz) - [Thresholds by market: NZ, AU, EU and US](https://anzoc.co.nz/resources/organic-product-multi-market-thresholds) - [Organic logo rules by market](https://anzoc.co.nz/resources/organic-logo-rules-by-market) This page is general guidance, not certification advice. Your certifier makes the final decision.