Food and dietary supplement pages often place “organic,” “non-GMO,” “natural,” “green,” and health-benefit language next to one another. They do not carry the same scope, evidence, or regulatory meaning. This reference page uses public U.S. rules as an example and helps teams map the product, formula, certificate, label, and customer-facing wording. Requirements for another market must be checked separately.

1. Separate the claim types before reviewing evidence

Organic claims concern the product or specified ingredients, the applicable organic program, certification scope, and label category. Under USDA organic labeling rules, “100 percent organic,” “organic,” “made with organic ingredients,” and ingredient-only organic identification have different composition and display rules. A certificate for one ingredient or supplier does not by itself establish that the finished product may be presented as organic.

Non-GMO is not a synonym for organic and should not be presented as a government certification unless the relevant authority actually provides that certification. Map the claim to the formula, ingredients, processing aids, suppliers, and lots. Keep supplier statements, specifications, purchasing and lot records, and the rules or authorization basis for any private verification program. FDA states that non-GMO and similar claims on food or dietary supplement labeling must be truthful and not misleading; the evidence and verification route depend on the claim and market.

General environmental language such as “green,” “eco-friendly,” or “sustainable” is a separate review. It cannot replace organic or non-GMO evidence. The FTC Green Guides warn against broad, unqualified general environmental benefit claims and call for clear, specific qualifications supported by competent and reliable evidence. A claim about one attribute should not imply that the entire product has no environmental impact.

Food and supplement nutrition, health, and structure/function claims need their own review. A health claim describes a relationship between a substance and a disease or health-related condition; a structure/function claim has a different scope and procedure. For dietary supplements, check the applicable FDA notification, disclaimer, and the boundary against diagnosing, treating, curing, or preventing disease. An organic certificate, laboratory report, or supplier brochure is not a substitute for substantiation of a health claim.

2. Build a claim–object–evidence register

Record the exact customer-facing sentence before editing it. Then identify whether it concerns the finished product, an ingredient, the package, or a production method; which country, channel, and language version it covers; which rule or program supports it; who issued the evidence and which entity and lot it covers; and whether qualifiers, marks, and placement match the evidence.

Useful fields include SKU, formula version, ingredient and supplier, lot or production date, target market, label version, page version, original claim, claim type, certification or verification program, holder or declaring entity, scope, certificate or file number, issue and expiry information, source link, reviewer, and review date. The existence of a certificate is not enough: compare the legal entity, product category, formula or ingredient, facility or handler, and transaction or lot scope with the current SKU.

3. Review the label and page by market

Do not treat a cross-market template as a regulatory conclusion. For the U.S. market, organic labeling must be reviewed alongside other food-labeling and food-safety requirements. FDA distinguishes health claims, nutrient-content claims, and structure/function claims. The package, detail page, product images, FAQ, advertising, influencer script, and customer-service wording can all shape consumer understanding, so they should use the same approved claim register.

Compare each version word by word. Does “contains organic ingredients” become “organic product”? Does evidence that specified inputs are non-GMO become a statement that the entire product is officially certified? Does a nutrient statement become disease prevention? Do “green,” “natural,” or “chemical-free” words hide a narrower, unproven meaning? If a certification mark is used, confirm its program rules, authorization, scope, and placement. Without verified authorization, do not place an official institution or certification logo in customer-visible artwork.

4. Give supplement benefit wording a separate substantiation review

A dietary-supplement structure/function claim may describe the role of a nutrient or dietary ingredient in normal body structure or function, but it cannot cross into a disease-treatment or disease-prevention claim. Retain the ingredient, amount, supporting research or other reliable basis, and any required notification or disclaimer. Phrases such as “clinically proven,” “boosts immunity,” “treats,” and “reduces disease risk” require more than a supplier brochure or a generic test report.

Conventional foods, dietary supplements, and drugs must not be collapsed into one compliance path. A change in formula, dose, serving method, or target consumer can change the claim analysis. State the conclusion narrowly: the current wording for the current version and market is supported, needs evidence, or remains unresolved. Do not state that it is universally valid, guaranteed to pass, or completed within a fixed period.

5. What to do when records do not match

Freeze the draft and artwork version first. Locate whether the mismatch concerns the entity, formula, label, certificate scope, lot, or page context. For unsupported wording, remove it or rewrite it with a verifiable qualifier; do not fill the gap with another regulation, another product, or another certificate. When the formula, supplier, package, or target market changes, reassess the affected claims and evidence rather than applying a universal “24-month validity” or fixed renewal window.

The final file should retain the original and revised wording, product and formula version, source evidence, market scope, manual review record, open questions, and owner. 绿色方舟（深圳）认证有限公司 provides evidence-organization and boundary guidance; it does not replace the final assessment of the destination-market authority, certification-program owner, or advertising counsel, and it does not promise certification, approval, listing, traffic, or sales results.

Sources

USDA AMS: Labeling Organic Products; FDA: Label Claims for Food & Dietary Supplements; FDA: Structure/Function Claims; FTC: Environmental Claims—Summary of the Green Guides. These sources frame the public-rule boundaries and are not legal advice for a specific product.