Do additives count towards the organic percentage?

No. Non-agricultural additives and processing aids are excluded from both sides of the calculation. They still have to be individually permitted under the standard you are certified to, which is a separate test.

Is citric acid allowed in organic food?

It depends on the standard, the production method and the function it performs. Fermentation-derived and synthetic forms are not always treated the same way. Check the permitted list for each market you sell into, and confirm with your certifier before use.

If a processing aid does not end up in the finished product, does it matter?

Yes. Processing aids are assessed on use, not on residue. A non-permitted aid is a non-compliance even if none of it remains in the product.

Can my certifier approve something that is not on the list?

No. Certifiers apply the standard; they cannot extend it. They can be stricter than the standard, and sometimes are, but they cannot permit what the standard does not.

What if an ingredient contains an additive I did not add?

It still counts as used in your product. Ask every supplier for the full composition of what they sell you, including carriers and anti-caking agents, and record it in your input register.

Is this additive allowed in organic food? How to check

An additive or processing aid may only be used in certified organic food if it appears on the permitted list for the standard you are certified to, and only for the purposes and under the conditions that list specifies. Being outside the organic percentage calculation does not make a substance allowable — permitted status is a separate test, and it differs between New Zealand, the EU and the USDA.

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

Two separate tests, often confused

Every non-agricultural input faces two independent questions, and passing one says nothing about the other.

Question	What it decides	Where the answer lives
Does it count in the organic percentage?	Whether it affects your 95% or 70% tier	The calculation rules — additives and processing aids are excluded
Is it permitted at all?	Whether the product can be certified organic at any tier	The permitted substances list for your standard

A non-permitted processing aid disqualifies the product even though it contributed nothing to the percentage. This is the failure mode that catches technically-minded teams who have done the arithmetic carefully and never checked the list.

Where the authoritative lists are

Standard	What to consult	Notes
New Zealand	The National Organic Standard issued under the Organic Products and Production Act 2023, and the organic notices made under it	Mandatory from 31 March 2028; your certifier applies it now
European Union	Regulation (EU) 2018/848 and its implementing regulations, Annex V	Strictest of the three for additives; also no "made with organic" tier
United States	USDA NOP National List, 7 CFR 205.605 (non-agricultural substances) and 205.606 (non-organic agricultural substances)	Entries are frequently annotated with conditions of use
Australia	Your certifier's standard, e.g. the Australian Certified Organic Standard	Australia has no single mandatory domestic standard
Your certifier	The certifier's own input approval process	This is the decisive one. Certifiers may be stricter than the standard and their approval is what your audit checks

The categories that cause the most trouble

Acidity regulators. Widely used, widely assumed to be fine, and treated differently between standards depending on how the substance is produced.
Raising agents. Some forms are permitted, some are not, and the permitted form is often the more expensive one.
Carriers and anti-caking agents in other ingredients. These arrive inside a bought-in ingredient and never appear on your own batch sheet. Ask suppliers for the full composition, not the marketing sheet.
Enzymes and fermentation aids. Permitted status can turn on the production organism and whether it is genetically modified.
Filtration media and release agents. Classic processing aids: they do not appear in the finished product, they do not affect the percentage, and they can still fail an audit.
Flavourings. Composition is often proprietary, which is exactly why certifiers ask for a full declaration before approval.

What to record for each input

Your input register is the document an auditor will ask for first. For every non-agricultural input, record:

Substance name, INS or E number where one exists, and the supplier.
Function in your process, described in the same terms the permitted list uses.
Source and production method, including whether any GM organism is involved.
The list entry it relies on, by standard, for every market you sell into.
Any conditions or limits attached to that entry.
Date your certifier approved it, and the approval reference.

Questions people ask

Do additives count towards the organic percentage?: No. Non-agricultural additives and processing aids are excluded from both sides of the calculation. They still have to be individually permitted under the standard you are certified to, which is a separate test.
Is citric acid allowed in organic food?: It depends on the standard, the production method and the function it performs. Fermentation-derived and synthetic forms are not always treated the same way. Check the permitted list for each market you sell into, and confirm with your certifier before use.
If a processing aid does not end up in the finished product, does it matter?: Yes. Processing aids are assessed on use, not on residue. A non-permitted aid is a non-compliance even if none of it remains in the product.
Can my certifier approve something that is not on the list?: No. Certifiers apply the standard; they cannot extend it. They can be stricter than the standard, and sometimes are, but they cannot permit what the standard does not.
What if an ingredient contains an additive I did not add?: It still counts as used in your product. Ask every supplier for the full composition of what they sell you, including carriers and anti-caking agents, and record it in your input register.

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.