Why does the EU not allow "made with organic"?

The EU organic regulation simply has no equivalent tier. A product either meets the organic threshold and may carry an organic claim, or it does not and may only identify organic ingredients in the ingredient list.

Is the 95% threshold the same in every market?

The 95% figure for a full organic claim is consistent across New Zealand, Australia, the United States and the EU, and all of them exclude water and salt from the calculation. What differs is what happens below 95%.

Can I use one label for all four markets?

Only for a product comfortably above 95% with no substances that are permitted in one market and not another, and even then the EU requires a control body code and origin statement that the others do not. Most exporters run market-specific artwork.

Does my New Zealand certification work in the EU?

Not automatically. EU market access runs through equivalence arrangements or additional certification. Ask your certifier which markets your current scope covers before you commit to an export plan.

Will my recipe pass in the EU as well as New Zealand?

Not necessarily. A product at 95% or more organic can generally be labelled organic in all four markets. Between 70% and 94% New Zealand, Australia and the United States allow a "made with organic" claim and the European Union allows none at all, so the same recipe carries an organic claim at home and no claim on an EU pack.

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

The comparison

Labelling outcome by organic percentage and market
Organic %	New Zealand	Australia	United States	European Union
100%	"100% Organic"	"100% Organic"	"100% Organic"	Organic claim
95–99%	Organic claim + certifier logo	Organic claim + Bud logo (ACO)	Organic claim + USDA seal	Organic claim + EU leaf, control body code and origin statement
70–94%	"Made with organic [ingredients]"	"Made with organic [ingredients]", no Bud logo	"Made with organic [up to 3 ingredients]", no USDA seal	No front-of-pack organic claim
Below 70%	Ingredient list only	Ingredient list only	Ingredient list only	Ingredient list only

Percentages are of agricultural ingredients by weight, excluding water and salt, in every market. The exclusions are the one thing that is consistent.

Three places recipes fail on export

The missing tier. An 85% product is a legitimate "made with organic" product in New Zealand and a completely unlabelled one in the EU. Discovering this after packaging is designed is the most expensive version of this mistake. More on the "made with organic" tier.
A permitted substance that is not permitted elsewhere. Additives and processing aids have different permitted lists in each standard. A product can be fully compliant at home and inadmissible abroad on one processing aid. How to check a substance.
Certification scope. Being certified by a New Zealand body does not by itself give you EU or US market access. That runs through equivalence arrangements or additional certification, and it has its own lead time. EU equivalence for NZ exporters.

Design for the strictest market you intend to enter

If the EU is on the roadmap at all, treat 95% as the floor from the first formulation, not as an optimisation to do later. Reformulating a launched product means new artwork, new approvals, sometimes new suppliers, and a period where two versions of the same SKU exist in the supply chain.

The cheaper discipline is to run the calculation once per destination market at the recipe stage, before any packaging spend, and to keep doing it on every reformulation.

New Zealand and Australia

Trans-Tasman is the easiest of the pairings, but "easy" is not "automatic". Australia has no single mandatory domestic organic standard, so the applicable rules in practice come from the certifier's standard — most commonly the Australian Certified Organic Standard — plus the Food Standards Code, which is shared across both countries.

For export from Australia, certification by an approved certifying organisation is required. For a New Zealand product entering Australia, your certifier will tell you which of your existing certifications are recognised and what, if anything, has to be added. Exporting organic from NZ to Australia.

Questions people ask

Why does the EU not allow "made with organic"?: The EU organic regulation simply has no equivalent tier. A product either meets the organic threshold and may carry an organic claim, or it does not and may only identify organic ingredients in the ingredient list.
Is the 95% threshold the same in every market?: The 95% figure for a full organic claim is consistent across New Zealand, Australia, the United States and the EU, and all of them exclude water and salt from the calculation. What differs is what happens below 95%.
Can I use one label for all four markets?: Only for a product comfortably above 95% with no substances that are permitted in one market and not another, and even then the EU requires a control body code and origin statement that the others do not. Most exporters run market-specific artwork.
Does my New Zealand certification work in the EU?: Not automatically. EU market access runs through equivalence arrangements or additional certification. Ask your certifier which markets your current scope covers before you commit to an export plan.

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.

Run your recipe against all four markets at once

One ingredient list in, four labelling outcomes out, with the reason for each pass or fail.