Organic, non-GMO, halal and kosher supplement claims: match each mark to its rulebook
List every mark on each label with the rule or certifier behind it, and keep the organic calculation with the formula version it came from.
In Short
- Organic 95%; 'made with' 70%.
- BE disclosure is not a non-GMO mark.
- Halal and kosher: certifier rules.
Brand owners and contract manufacturers putting dietary or lifestyle marks on supplements need to know which are federal rules and which are certifier standards. Opened (current eCFR, up to date 1 October 2026): 7 CFR 205.300 to 205.307 on USDA organic labelling, and 7 CFR Part 66 on bioengineered food disclosure, including its definition, application, 66.5 exemptions and 66.6 list. Not opened: the rest of Part 205, including certification and handling rules, NOP guidance, the Non-GMO Project standard, halal and kosher certifier standards and state laws. It is orientation, not legal advice. Sources checked 5 Oct 2026.
Organic is a regulated term
7 CFR 205.300(a) says the term organic may only be used on labels and in labelling of raw or processed agricultural products, including ingredients, that have been produced and handled in accordance with Part 205, and may not be used in a product name to modify a nonorganic ingredient. Whether and how a particular supplement can be certified depends on Part 205 rules this guide did not open, so confirm it with your certifying agent before artwork is drafted.
Four composition tiers
Section 205.301 sets the tiers by weight or fluid volume, excluding water and salt: 100 percent organic needs 100 percent organically produced ingredients; organic needs not less than 95 percent; made with organic (specified ingredients or food groups) needs at least 70 percent; and products below 70 percent may only identify organic ingredients in the ingredient statement under 205.305. Section 205.302 calculates the percentage from the combined organic ingredients at formulation divided by all ingredients at formulation, and 205.304 limits a made with statement to no more than three ingredients or food groups.
Which organic tier? (7 CFR 205.301, simplified)
- Excluding water and salt.
Bioengineered disclosure is not a non-GMO claim
Part 66 defines bioengineered food as food containing genetic material modified through in vitro recombinant DNA techniques that could not otherwise be obtained through conventional breeding or found in nature, and not if the modified material is undetectable. It applies only to foods subject to the labelling rules it names.
Worked Example: Organic Share for Powder OP-77
| Ingredient | kg | Counted |
|---|---|---|
| Organic ashwagandha root powder | 60 | Organic |
| Organic rice flour | 25 | Organic |
| Vitamin premix (not organic) | 10 | Not organic |
| Salt | 5 | Excluded |
- Organic ashwagandha root powder
- kg
- 60
- Counted
- Organic
- Organic rice flour
- kg
- 25
- Counted
- Organic
- Vitamin premix (not organic)
- kg
- 10
- Counted
- Not organic
- Salt
- kg
- 5
- Counted
- Excluded
More on bioengineered disclosure is not a non-GMO claim
Section 66.5 exempts, among others, very small food manufacturers, foods where no ingredient intentionally contains a bioengineered substance (with up to 5 percent inadvertent presence per ingredient) and food certified under the National Organic Program. A non-GMO mark follows its own private standard.
Halal and Kosher Marks
This guide opened no halal or kosher law or standard, so it sets out none of their requirements. In practice these marks rest on a certifier's approval of named products, sites and ingredients.
More on halal and Kosher Marks
The common weak points are capsule shells, gelatin, processing aids, flavours and carriers that change when a supplier changes. Keep the certificate for each product and site, the certifier's approved ingredient list, and a change-control step that asks whether the certifier must approve a new supplier or formula before it is used.
One certification register
For each SKU, record every mark on the label, the scheme, the certifier, certificate number, scope by product and site, expiry, the approved ingredients and the lots it covers. Keep the organic percentage calculation with the formula version it was made from, and the bioengineered assessment with the ingredient records it relied on.
Certification Register Entry
More on one certification register
A formula, supplier or site change reopens each affected entry. Your team and your certifiers decide; the register shows what each decision rested on and when it was made.
Questions
What percentage makes a product organic under USDA rules?
Under 7 CFR 205.301(b), not less than 95 percent organically produced ingredients by weight or fluid volume, excluding water and salt.
Is a made with organic claim limited?
Yes. It needs at least 70 percent organic content under 205.301(c), and 205.304 limits the statement to no more than three ingredients or food groups.
Does having no bioengineered disclosure mean a product is non-GMO?
No. Part 66 has its own definition, scope, list and exemptions. A non-GMO mark depends on its certifier's standard, which this guide did not open.
Does V5 certify products or approve labels?
No. V5 keeps certificates, approved ingredient lists, formula versions and label versions linked. Your team and your certifiers decide.
Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.
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