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 Advertising, Labeling and Formulation Division (ALFD) FAQsOrganic AlcoholOA 1: I understand the United States Department of Agriculture (USDA) finalized regulations relating to the National Organic Program at 7 CFR part 205. How do these regulations affect the organic alcohol that I produce? A: These regulations create standards for the production, handling, processing, labeling, and marketing of all organically produced products. The regulations also create four categories of organic classification and identify specific substances that cannot be used in the production of organically made products. To obtain more information about the National Organic Program and to view a full text of the regulations, please visit the Agricultural Marketing Service Web site at http://www.ams.usda.gov.
OA 2: What is an Organic Claim? A: If a bottler or importer uses the word “Organic” in any fashion likely to be perceived as claiming that a product or anything associated with it is organically produced, contains organic ingredients, or was processed in an organic manner or facility, TTB will consider this an organic claim and apply the requirements outlined by the United States Department of Agriculture’s National Organic Program (NOP) at 7 CFR part 205.
OA 3: What type of Organic Claims Exist: A: The four basic National Organic Program Organic Categories for alcohol beverages are as follows:
OA 4: When I submit a label application for a label with an organic reference, what additional documentation must I submit? A: Several types of organic claims exist that require more or less information depending on the circumstances. However, a majority of claims will require you to submit the Processor/Handling Operation Certificate and Accredited Certifying Agent Preview .
OA 5: What information must appear on the Processor/Handling Document? A: The Processor/Handling Document must specifically state compliance with the National Organic Program (NOP) standard and not to the EU/EC standard. It must also list the product, state an effective date, and must be currently valid. Certifications in a foreign language must be translated into English, although usually NOP certifications are provided in English. If your certification is not in English you should verify that it is the appropriate certification.
OA 6: My imported wine has organic documentation from the European Union/European Commission; will this documentation be sufficient to support my organic claim? A: No. Other nations have similar regulatory bodies that certify products on an organic level; however, in order to import the product into the United States the handling/crop certification must clearly attest that the grapes used to produce the product comply with the National Organic Program (NOP) requirements. If this clear declaration does not appear on the original document, the product may not be imported into the United States.
A: A USDA Accredited Certifying Agent (ACA) is an organization accredited by the USDA and charged with certifying both foreign and domestic organic farms, facilities, and handling operations to the USDA’s National Organic Program standards. All organic labeling applicants whose handling operations are certified by an ACA and would like to make an organic claim other than an ingredient statement must obtain their ACA’s preview and approval of their organic alcohol beverage labels prior to submission to TTB. The ACA Preview must show actual images of the labels along with a stamp or signature of the ACA to verify that the product label complies with the appropriate standard. The National Organic Program maintains a list of both foreign and domestic Accredited Certifying Agents at http://www.ams.usda.gov.
OA 8: Where do I obtain the Accredited Certifying Agent Preview and Processor/Handling Certificate for imported products? A: The producers of imported alcohol products are the responsible party for supplying copies of the required documents. The importer should request the documents from the producer or the producer’s wholesale distributer for submission with your Certificate Of Label Approval application. The National Organic Program maintains a list of foreign Certified Accredited Agents at http://www.ams.usda.gov.
OA 9: What documents must be provided if I want to state, “Made with Organically Grown Grapes?” A: To use “Made With Organically Grown [Ingredients]” on a wine label, submit the following with your application:
OA 10: What else must I know if I want to state, “Made with Organically Grown Grapes?” A:
OA 11: What is a “Certification Statement,” and where must it go on a label? A: The statement, “Certified Organic by---“, or similar phrase, followed by the name of the USDA Accredited Certifying Agent (ACA) must appear directly below the bottler or importer’s name and address statement with no intervening information. The organic certification statement must appear under the importer's name and address on imported products if the foreign producer/bottler's information is not present. We will accept the certification statement beneath either the importer’s or the foreign producer/bottler's information when present on imported labels. Certifying information may include the business address, internet address, or telephone number of the certifying agent. ACA acronyms are acceptable in certification statements; however, logos or seals do not fulfill this requirement.
OA 12: I have a crop certificate, but the producer is not a certified organic handler. What type of organic claim can be made on the label? A: The only organic claim that can be made on the label is in an ingredient statement.
OA 13: What else must I know if I only want to state that my product contains “Organic” ingredients? A:
OA 14: If the vintage date changes on my approved organic label, do I need to submit it for reapproval? A: Yes, organic products must have the label and accompanying paperwork approved each vintage year. Organic products are required to maintain and prove their certified status with regular renewals of their certifications.
OA 15: What are some common mistakes made when submitting organic labels? A: The lack of supporting documentation for organic claims creates the greatest delay in label processing. In a majority of situations, a valid Processor/Handling Certificate and Accredited Certifying Agent preview satisfy the requirement. A second, common mistake occurs when submitters do not closely check the supporting documents to ensure that information listed on the product corresponds to the associated paperwork. Expired documentation, documents citing the wrong product, and date conflicts represent common reasons why applications are returned.
OA 16: My Organic Wine predates the introduction of USDA’s National Organic Program (NOP), is my wine still considered “Organic,” and what must I submit for label approval? A: Yes, TTB allows organic claims on wines pre-dating October 2002 as a courtesy to handling operations that still have organic grapes or agricultural crops harvested prior to implementation of the NOP. Applicants must provide valid organic certification dated before October 21, 2002. The effective date of the organic certification must correspond with the vintage date of the wine. Approved labels are given an expiration date not to exceed one year, but may be renewed annually until such time as all pre-NOP crops are exhausted. TTB reserves the right to discontinue this policy at any time. |
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