Regulation is a somewhat fluid process that changes with input and over time. Nowhere is this truer than with the US organic food regulations to which certified organic processors and marketers are audited to.
Just two years ago Washington made it clear that “Made With”, (70% organic) products were to use the “Made with Organic Oils” claim on the principal display panel. They reversed this position last week stating that the phrase “Made with Organic Oils” may only be used if in fact, all the oils in the product are organic. NOP has ruled that there is no difference, for label purposes, between a base oil and an essential oil. Both are considered “oils”.
Upshot is, unless your essential oils are certified organic this “Made With” claim will have to be modified when you re-certify and reprint your labels. Products can make up to three organic ingredient claims ie “Made with organic aloe, coconut and Aphrodite oil”. Or simply, “Made with organic palm oil”.
Vermont Soap will pre-proof our customer’s labels for compliance at no charge. We also provide graphics services at $50/hour so you can get it done right the first time. Average label graphics cost is $200-$250 for the first label and much less for additional flavors.
You do not have to throw your labels away, just re-certify them with the new language on reprint. Vermont Soap will submit them for you if you use our VOF certifier.