Can I put any ingredient in the non-organic 5%?

No. It must be an agricultural ingredient that your standard permits in non-organic form, and usually only where no organic version is commercially available in the quantity and quality you need.

Do additives use up the 5%?

No. Non-agricultural additives and processing aids sit outside the percentage calculation altogether. They must still be individually permitted, which is a separate requirement.

Is "the organic version costs more" enough to justify using conventional?

No. Commercial unavailability means you cannot obtain it in the quantity and quality required. Price is generally not accepted on its own.

What if my product is 94.6% organic?

It is not eligible for an organic product claim. It falls into the "made with organic" tier, which allows naming the organic ingredients but not calling the product organic, and not using a certifier logo on the front of pack.

What may go in the non-organic 5% of a certified organic product

The non-organic portion of a 95%+ organic product may only contain agricultural ingredients that are listed as permitted in non-organic form under your standard, and usually only where no organic alternative is commercially available. It is a narrow, conditional allowance with an evidence requirement, not a 5% margin you may fill with anything convenient.

Last updated: 28 September 2026 · Written by Fliss Roberts, ANZOC

The misconception worth clearing first

The 95% threshold is widely read as "5% of the product can be whatever you like". It cannot. Two constraints sit on top of the arithmetic.

The substance has to be permitted in non-organic form. Standards maintain lists of agricultural ingredients that may be used non-organically — USDA NOP does this at 7 CFR 205.606, and the EU and NZ standards operate equivalent lists. An ingredient not on the list cannot occupy the 5% at any level.
Availability conditions usually apply. Most listings are conditional on an organic form not being commercially available in the required quantity or quality. If an organic version exists and you can buy it, the non-organic version is not permitted, however small the quantity.

What actually sits in the non-organic portion

Input	Does it use up the 5%?	Conditions
Non-organic agricultural ingredient	Yes	Must be on the permitted non-organic list; availability conditions usually apply
Non-agricultural additive	No — outside the calculation	Must be on the permitted additives list
Processing aid	No — outside the calculation	Must be permitted
Water and salt	No — excluded entirely	None
Anything prohibited	Irrelevant	Disqualifies the product outright at any level

Because additives and processing aids sit outside the calculation, the 5% is almost always occupied by ordinary agricultural ingredients — a spice, a starch, a minor fruit or vegetable component — that could not be sourced organically.

Evidencing unavailability

Where your standard conditions a non-organic ingredient on unavailability, the evidence is part of your file, not an argument you make at audit. Certifiers generally expect to see:

Which suppliers you approached and when, with their responses.
The quantity and specification you needed, and why a substitute did not meet it.
A search repeated at a sensible interval — an unavailability finding from three years ago is not evidence about this year.
Where a market check is expected, a record of it. The ANZOC producer directory is one place to run and date that check.

Working with a tight 5%

Design the margin in. A recipe that lands at 95.2% has almost no tolerance. One supplier substitution takes it under, and every pack printed for the organic tier becomes waste.
Watch seasonality. An ingredient that is organically available in March may not be in September. If your production runs across the year, check availability per run.
Re-run the numbers on every reformulation, however minor it looks. A change in the starch is exactly the change that moves 95.2% to 94.6%.
Track it by batch. The percentage is a property of what you actually made, not of the recipe you intended.

Questions people ask

Can I put any ingredient in the non-organic 5%?: No. It must be an agricultural ingredient that your standard permits in non-organic form, and usually only where no organic version is commercially available in the quantity and quality you need.
Do additives use up the 5%?: No. Non-agricultural additives and processing aids sit outside the percentage calculation altogether. They must still be individually permitted, which is a separate requirement.
Is "the organic version costs more" enough to justify using conventional?: No. Commercial unavailability means you cannot obtain it in the quantity and quality required. Price is generally not accepted on its own.
What if my product is 94.6% organic?: It is not eligible for an organic product claim. It falls into the "made with organic" tier, which allows naming the organic ingredients but not calling the product organic, and not using a certifier logo on the front of pack.

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.