I am speaking strictly from a certification point of view; marketing of organic is another matter entirely. I really don't know what consumers look at, or "trust", in terms of organic when they are purchasing and I don't really care. There will always be some "mistrust" of food companies by consumers, it is only natural because of consumer ignorance and the few bad apples in the industry.
And yes, pesticides and herbicides, among other things, can be used on organic crops / food, and in processing so long as they are on the NOP approved list AND used in the matter required on the NOP approved list. There is always a degree of "vagueness" with certifications and regulations which is on purpose to provide some "gray areas" to work within and just a matter of language as well.
Hi Ryan,
Returning to the OP, as I understand, for the product whose labelling/commercialisation is as described in the OP -
(1) Despite the inclusion of (stated) organic ingredients in the ingredients list, due ^^^(red) the final product avoids being regarded as "Organic" by USDA and therefore is automatically outside involvement in the USDA's certification program.
(2) Similarly the additional activities mentioned in the OP avoid being regarded as "handling activities" within the context of the NOP Program (subpart D)..
The only query therefore appears to be as to any necessary requirements related to the ability to refer to the listed ingredients as "organic" which are responded to in yr Post 5.
It would appear that to avoid fines Distributors of this final product will have to exercise extreme caution in any related Promotional activities.