In India, "organic" on a ghee label is a regulated claim. Under the Food Safety and Standards (Organic Foods) Regulations, 2017, organic food must comply with NPOP or PGS-India, and certified organic food carries FSSAI's Jaivik Bharat logo; exemptions cover only direct sales by small producers and their aggregators. It is a farm standard, not a statement about breed, A2, bilona or the fat in the jar.
At a glance
- FSSAI's Organic Foods Regulations were notified on 29 December 2017; an amendment in force from 14 October 2021 exempts aggregators selling small producers' organic food direct, without the logo.
- The NPOP 8th Edition, 2024, requires ruminants to get at least 85 per cent organic feed on a dry-matter basis, and lets milk from newly introduced cattle sell as organic after six months.
- Under NPOP, allopathic drugs and antibiotics are allowed only for treatment under a veterinarian, with the withdrawal period doubled and never under 48 hours, and never for prevention.
- Organic food must meet insecticide residue limits of 5 per cent of the ordinary maximum, or the level of quantification, whichever is higher.
- A 2016 meta-analysis of 170 studies found more omega-3 in organic milk and attributed it to grazing and forage intake, not to the label.
What does "organic" legally mean on a ghee label in India?
It means the ghee was produced under one of two named systems, and that someone checked. Regulation 3 of the Organic Foods Regulations, 2017 forbids selling or importing organic food without complying with the regulations, and regulation 4(1) requires organic food to comply with the National Programme for Organic Production (NPOP) or the Participatory Guarantee System for India (PGS-India).
The regulation defines organic food as "food products that have been produced in accordance with specified standards for organic food production". Regulation 7 keeps every ordinary FSSAI standard in force, except that insecticide residues may not exceed 5 per cent of the usual maximum limits, or the level of quantification, whichever is higher. Organic ghee must still be ghee under the standard in our article on what a ghee label must show.
Who certifies organic food: NPOP or PGS-India?
Two bodies, by two methods. NPOP is third-party certification: an accredited certification body inspects the farm against the National Standards for Organic Production, and the Jaivik Bharat portal counts 28 such bodies. PGS-India is a participatory system under the agriculture ministry that "operate[s] outside the framework of third party certification", through 562 regional councils.
Who can sell organic ghee without certification?
Small producers selling direct and, since 2021, the aggregators who sell for them. Regulation 4(2) exempts organic food "marketed through direct sales by the small original producer or producer organisation, as determined by the Food Authority from time to time, to the end consumer". The 2021 amendment added regulation 4(3) for aggregators selling such food direct.
Exempt aggregators must keep traceability records, and their food "shall not carry Food Safety and Standard Authority of India's organic logo". FSSAI's standard operating procedure for them limits the exemption to aggregators with an annual turnover of Rs 50 lakh or less who do not engage in "manufacturing, processing and private labelling". On our reading, that covers a farmer selling ghee from their own herd direct, if FSSAI counts them as a small producer, not a brand making ghee from bought milk, which is processing.
What does NPOP require of an organic dairy farm?
Organic feed, access to grazing, restricted veterinary inputs and a conversion period. The NPOP 8th Edition, 2024, lists the principles of organic livestock production: natural breeding, animal welfare, "fed with organic feed and fodder", "access to grazing in organic fields", natural behaviour, and "prohibition of use of chemically synthesized allopathic veterinary drugs, antibiotics, hormones, growth boosters, feed additives etc".
- Feed. Animals must be fed "at least 85% for ruminants and 80% for non-ruminants calculated on a dry matter basis" from organic sources, land growing their fodder must be organic, and a substantial share of a herbivore's daily ration should be roughage, fodder or silage.
- Grazing and housing. Where the climate does not allow easy access to pasture, cattle may be fed certified organic feed instead, provided a dairy cow gets at least 6 m² indoors and 4.5 m² of outdoor exercise area.
- Veterinary inputs. Vaccinations required by law are permitted. Where no permitted alternative exists, veterinary drugs may be used "under prescription and supervision of a registered veterinarian", with the withdrawal period for allopathic medicines and antibiotics doubled and at least 48 hours. Their use "for preventative treatments and for enhancing productivity or fertility is prohibited".
- Conversion. Land for feed and pasture must itself be certified organic, which for annual crops takes at least two years. Where the land is already organic and non-organic cattle are brought in, their milk products may be sold as organic after six months, counted "from the date of first inspection".
Breeds should suit "the local climatic conditions" and show "vitality and resistance to diseases"; no breed is named.
What should a certified organic ghee label show?
The Jaivik Bharat logo, and the mark of the system that certified it. Regulation 5(1) allows a certification mark of NPOP or PGS-India "in addition to the Food Safety and Standard Authority of India's organic logo", and the Labelling and Display Regulations, 2020 make that logo mandatory (regulation 5(7)(e) and Schedule I).
FSSAI's consumer guidance lists what to look for on an NPOP product: the FSSAI logo and licence number, the India Organic logo, the word "Organic" for a single-ingredient product, and the "Name and logo of the Accredited Certification Body & Accreditation Number". A farm still in conversion may label its product "In-conversion to organic" with the year, and it "shall not carry" the FSSAI logo.
How do you verify an organic claim on the Jaivik Bharat portal?
Search the database for the brand or its licence number, then check the label against the record. FSSAI describes the portal at jaivikbharat.fssai.gov.in as "an Indian Organic integrity database jointly developed by FSSAI, APEDA and (PGS-India)".
- Take the FSSAI licence number off the jar. It identifies the business.
- Search the portal. The home page searches by product, company or licence number; the results page filters by certifying system, PGS-India or NPOP.
- Match the certifier. An NPOP label names the certification body and its accreditation number; the portal links APEDA's list of accredited bodies.
- Check the words. "Organic" or "PGS-Organic" means certified; "In-conversion to organic" or "PGS-Green" means not yet; an exempt aggregator's product carries no logo.
What does organic not tell you about ghee?
It tells you how the farm was run, and nothing more about the ghee. The NPOP text we read never mentions A1 or A2 milk protein, curd churning or any particular breed, and the organic regulation adds no composition test of its own. Four common label words certify different things.
| Word on the jar | What it certifies | Who checks |
|---|---|---|
| Organic | The farm's method: organic feed, grazing access, restricted veterinary inputs, a conversion period, traceability | An accredited certification body (NPOP) or a regional council and peer group (PGS-India); nobody for exempt direct sales |
| Grass-fed | The maker's description of feed; our grass-fed ghee article found no FSSAI definition | Nobody, beyond the general FSSAI rule that claims must be truthful and not misleading, as that article sets out |
| A2 | A claim about the beta-casein in the milk; not an FSSAI category | Nobody; it is the seller's claim, covered only by the general labelling rules in our article on what a ghee label must show |
| Agmark | The finished ghee's composition and purity against one of three grades; our Agmark ghee article gives the limits | An authorised packer with an in-house laboratory under the Ghee Grading and Marking Rules, 2024 |
Nor is organic a purity test: the certificate covers the farm and the handling chain, not the jar in your hand. A batch laboratory report is the evidence for that, which is why every Himdhara jar carries a batch code with its report published before the batch ships.
Does organic milk have different fat?
On average yes, but the evidence credits grazing, not the certificate, and none of it is a health claim. A 2016 systematic review and meta-analysis in the British Journal of Nutrition pooled 170 published studies comparing organic and conventional cow's milk and found no significant difference in total saturated and monounsaturated fat, but more omega-3 fatty acids in organic milk.
It estimated omega-3 fatty acids higher by 56 per cent and conjugated linoleic acid by 41 per cent, with iodine and selenium lower. The authors' redundancy analysis of a cross-European survey "indicates that the higher grazing/conserved forage intakes in organic systems were the main reason for milk composition differences".
The studies measured milk, not ghee, so no figures for organic ghee follow. A composition difference is not evidence of a health effect: organic is a production standard, not a nutrition claim. If you are choosing a fat for a medical reason, follow your doctor's advice, not a logo.
Our A2 bilona ghee is sold on what its batch report shows and on the method on its label, not on a word.
The short version
In India, organic is a certified production standard. The Organic Foods Regulations, 2017 require organic food to comply with NPOP or PGS-India and to carry the Jaivik Bharat logo, with exemptions only for small producers and low-turnover aggregators selling direct. Under the NPOP 8th Edition, a dairy herd must get at least 85 per cent organic feed, have access to grazing, receive allopathic drugs only for treatment under a veterinarian, and spend six months in conversion. The word says nothing about breed, A2, the bilona method or the fat in the jar.
Sources
Further reading behind the figures above. Himdhara's own numbers — yields, batch results — come from our production records and the batch reports on the lab reports page.
- Food Safety and Standards Authority of India (2021). Food Safety and Standards (Organic Foods) Regulation, 2017, compendium Version I (22.10.2021). FSSAI.
- Agricultural and Processed Food Products Export Development Authority (2024). National Programme for Organic Production (NPOP), Eighth Edition: 2024. Department of Commerce, Ministry of Commerce and Industry.
- Food Safety and Standards Authority of India. Jaivik Bharat: Indian Organic Integrity Database. FSSAI.
- Food Safety and Standards Authority of India (2021). Standard Operating Procedures for Aggregators or Intermediaries facilitating sales between Farmers/ small original producers and producer organizations and end consumers - Exempt Entities. FSSAI.
- Średnicka-Tober D, Barański M, Seal CJ, et al. (2016). Higher PUFA and n-3 PUFA, conjugated linoleic acid, α-tocopherol and iron, but lower iodine and selenium concentrations in organic milk: a systematic literature review and meta- and redundancy analyses. British Journal of Nutrition.