Retail establishments that sell private label organic products do not have to be a certified retailer, but the contract organization that manufactures or packages the products must be certified by an USDA accredited certifying agent. These products must be packaged prior to being received by the retailer, and remain in the same package or container and not be further processed by the retailer.

Retailers which process and sell off-site to other retail stores must be certified as well. For instance, an in-store bakery that bakes organic bread products and sells to other retail stores must have the bakery department certified in order to label the bread as “100% organic, “ “organic,” or “made with (organic ingredients or food groups).”

Retail establishments that process and sell their own private label organic products on-site do not have to be a certified retailer, but cannot represent the product as “certified organic” or use the USDA organic seal on their products. The USDA labeling rules listed in Section 2 (Labeling) must be followed.

Cleaning and Sanitizing

• Store cleaning materials away from food products and preparation areas. Never store these materials above a sink or preparation area.
• Always clean and thoroughly rinse all sinks, tubs, preparation areas and utensils before using these for organic products.
• Use only department approved cleaning materials.
• Complete any written documentation of your cleaning activities when needed.
• Clean up spills when they occur.

In Store Private Label Receiving 

• Always verify products ordered matches what is delivered and what is written on the invoice/bill of lading
• Always look for clear organic labeling and certifying agent seal on incoming bulk containers
• Place any bulk item in a quarantine area that does not meet USDA labeling rules. Get any missing information from supplier.

In Store Private Label Storage

Products from broken or open bags/containers can be accidentally mixed with non-organic products. Proper labeling is key to prevent non-organic products from being used to fill containers that will be labeled “Organic.”

• Have separate storage areas for organic and non-organic products.
• Label organic and non-organic storage areas.
• All open bags must be closed tightly, taped or twist-tied, and clearly marked. Have these supplies readily available to all employees in the storage areas.
• All packaging materials must be free of dyes and fumigants which pose a risk. You can ask your supplier to verify that no fumigants are used in your packaging.
• If contamination does occur, the product must be sold as non-organic.
• Clear signage is paramount to ensure no commingling or contamination. Have “Organic” stickers readily available in the storage area for employees to easily affix on storage containers if the label may be difficult to see.
• All organic back stock should be clearly marked organic, especially when the same non-organic product is being offered.
• Any issues should be brought to the buyer’s attention.
• Place bulk bags and boxes on storage shelves in a way that the organic label is easy to see.
• Tubs, counters, scoops and other items used to repackage foods must be thoroughly cleaned and rinsed between organic and non-organic products.

Labeling In Store Private Label Products

In Store Private Label labels and signage must meet the labeling criteria in Section 2 (Labeling).

• Always use clean containers for organic products
• Use distinctive labels to differentiate organic and non-organic products. Different color backgrounds make it easy for the consumer to pick out the organic product.
• Scoops for packaging product should be designated separately for organic and non-organic items or washed thoroughly before use for organic items.
• If contamination does occur, the product must be sold as non-organic.