Labeling as organic without mistakes: a practical guide for companies

Organic, in Italy and in Europe, has by now become a structural segment of the agri-food sector, with increasingly complex supply chains and a system of regulatory oversight that, precisely because it is stringent, is in fact part of the market value. In Italy, organic agricultural area exceeded 2.5 million hectares in 2024 according to SINAB/ISMEA data, confirming a sector that continues to consolidate and that now has a significant impact on the overall SAU.
In this scenario, the label is the point where technical aspects, compliance and reputation meet. It is also the point where a graphic error can become a legal error. For companies, especially those that process, correctly designing organic labeling means safeguarding the product, the communication and the relationship with the inspection and control chain.

Reference standards: what makes a product organic also on the label

The central reference is Regulation (EU) 2018/848, which governs organic production and labeling and which replaced the previous regulatory framework. The main rule is simple and very concrete: the terms organic, eco and other references to organic may be used only for compliant products and must not appear, even indirectly, on non-compliant products or in a way that could mislead.
For the food industry, the most frequent issue concerns processed products. If a processed food wants to present itself as organic also in the sales name, it must meet the threshold: at least 95% of the agricultural ingredients by weight must be organic, in addition to compliance with the specific production rules. If, instead, the organic share is below 95%, the reference to organic is permitted only in the ingredients list and only in relation to the ingredients that are actually organic. In other words: below the threshold the product is not presented as organic, but it is stated that some ingredients are.
A delicate chapter is conversion. The regulation clarifies that products obtained during the conversion period cannot be labeled or advertised as organic. There is, however, a specific possibility for plant reproductive material, food and feed of plant origin, which can be indicated as in conversion if they meet precise requirements. It is a point to handle with caution because it directly affects claims and layout and because, in practice, an ambiguous message can become an element of dispute.
Alongside the terms, the second major block is the EU organic logo. Regulation (EU) 2018/848 establishes when and how it may be used and also notes that it cannot be used for certain categories of processed products and for products in conversion. When the logo is present, specific obligations apply: the indication of the origin of the agricultural raw materials must appear in the same field of vision as the logo with standard formulas such as EU Agriculture, non-EU Agriculture or EU/non-EU Agriculture. The European Commission’s organic logo user manual adds fundamental operational guidance for those doing the layout, such as minimum dimensions and the rules for monochrome versions, outlines and proportions.
At national level, Italy has two useful references to frame the system. Law No. 23 of 9 March 2022 defines the framework for promotion and development of the sector, while Legislative Decree No. 148 of 6 October 2023 aligns national legislation with 2018/848 and the system of official controls, defining the control architecture and the scope of sanctions. Translated into practice: the organic label is verifiable information within a control system and not only (or not merely) a commercial promise.

How to build the label: operational guidelines for an approvable pack

To build a correct organic label, it is worth thinking like an auditor would: first you define the product’s status, then you translate the requirements into graphic and textual elements, and finally you secure the internal approval flow.
The first step is to decide whether the product is organic in the full sense or whether it contains organic ingredients. If you are above the 95% threshold of agricultural ingredients by weight, you can use references to organic also in the sales name and build the pack identity around that positioning. If you are below the threshold, the label must avoid any construction that makes the product be perceived as organic as a whole: the reference must be confined to the ingredients list, consistently and without graphic emphasis that could be misleading.
The second step is to correctly manage what, when the logo is used, must coexist in the same field of vision: the EU logo, the code of the control body and the indication of the origin of the agricultural raw materials. This field-of-vision rule and the standard origin formulas are a key point and, in our experience, also one of the most overlooked in pack drafts. At the layout stage, it is worth setting up from the outset a graphic grid that guarantees the coexistence of these elements without forcing, because making changes downstream often produces compromises that are not very effective and, above all, risky.
The third step is to remember that organic labeling does not stand alone. It must be consistent with the general food labeling regulations, therefore with the sales name, ingredients list, allergens, net quantity, minimum durability date or use-by date, responsible operator, lot, origin when required, nutritional declaration if applicable. Controls do not look at the label in separate compartments: a graphically dominant organic indication that is poorly supported by the overall information framework increases the likelihood of observations.
The fourth step is to avoid creative formulas that are not provided for or potentially misleading. A recurring example is the use of absolute wordings such as 100% organic, which in several contexts is discouraged because it can suggest the existence of different levels of organic and therefore reduce transparency towards the consumer. Before approving absolute claims, it is always worth assessing whether they are founded in regulatory terms or whether they are simply pushing the message beyond the permitted perimeter.
The fifth step, often decisive, is the internal process. The most common risk is not intentional non-compliance, but information asymmetry between departments: a graphic review can reintroduce an error that has already been corrected, or move mandatory elements outside the required field of vision. A good practice is to treat label files as regulatory documents: versioning, change traceability, justification for interventions, final validation anchored to the requirements of 2018/848 and to the applicable indications of the logo manual and the guidelines of the control body.