Guest Comment

Why the US needs private organic cosmetics standards

Related tags Organic food Personal care

Organic certification creates an even playing field for the industry, it provides answers for consumers, and it supports credible exports; broadening the marketplace for both American-produced cosmetics and for organic raw materials.

It allows clear education and communication and is vital to the development of new ingredients and technologies. It provides a platform that supports investment in this industry sector.

However, in a recent survey by the Organic Trade Association, 26 percent of its personal care members were certified to any standard, while only 8 percent were certified organic to the USDA National Organic Program.

Meanwhile, over 60 percent of European companies making organic claims are certified. This means that American companies are at a disadvantage in international markets and in their ability to answer US consumers' questions about organic claims.

Why USDA-NOP is not good for certifying cosmetics

The existing USDA-NOP works well for food, not for cosmetics. Cosmetics require synthesized chemicals (surfactants, emulsifiers, preservatives) for functionality.

As a result, the NOP rule has been used to certify as organic, non-food synthetics like soap (potassium cocoate) and mono-and di-glycerides. Synthetics are not “bad”, but they are very different from organic food.

Separate standards for cosmetics will channel the creation of cosmetic ingredients to an appropriate industry sector and protect organic food while supporting increased use of organically farmed materials.

In addition, the NOP must reconcile with the FDA how to regulate ‘organic’ cosmetics. This process will take many years. We are wasting time if we wait for it to become final.

Furthermore, the NOP program never fully included “sustainability” in processing standards as they did in farming.

Farmers are required to prove that they improve their environment as a result of farming, but processors are not required to meet these criteria.

We can have a better standard that includes sustainable practices for manufacturers and drives sustainability throughout the supply chain.

Role of retailers

Retailers did a great job supporting organic food certifiers in the 1990’s, but have seriously dropped the ball for cosmetics claims. In the mid-90s, one could not sell a food product labeled “organic” to a retailer unless one was third party certified to a private standard.

Today, instead of requiring this in the US, retailers are making up their own ‘standards’ that are only lists of ‘allowed’ ingredients and are not focused on ‘organic’ but exclusively support ‘natural’ claims.

In the 90s, we had the perfect confluence of private certifiers, market demand, and retailers demanding third party certification. This drove organic market innovation, supported consumers, and increased the demand for organically farmed products.

During this time the infrastructure of the organic food industry grew to support the need for the NOP. This model gave us a great food program. Retailers should once again support certification, not unverified ingredient claims. They should be the gatekeepers for all of the stakeholders.

Get off the Fence!

The personal care industry needs a clear, sustainable future; that future should give better products and better information to consumers.

As long as we avoid the responsibility for certification of organic claims, we can do neither. Avoiding certification causes us to lose out in our efforts to ‘grow’ organic farming, and few will invest in the future of companies making self-professed ‘organic’ label claims.

The European companies exhibit a robust market for investing in ‘organic’ companies, using private certification.

American personal care companies need to make a choice and get certified - to any of the organic standards.

Choose a standard and go with it

All of the ‘organic’ personal care companies should stop ‘waiting for things to settle down’ and commit to a standard, and tell the National Organic Standards Board to back off; the industry needs to try private certification in the marketplace.

Likewise, retailers should recognize and support the important role they play. As a result, all the stakeholders would benefit.

Fear of lawsuits and lack of market incentives and consumer understanding has effectively stopped the conversation about what defines an ‘organic cosmetic’.

Until we allow this conversation to move forward in the US, we will continue to deal with ‘wishful’ organic labels, an uninformed public and ‘organic’ retailers who support ‘natural’ cosmetics.

This is a betrayal of the original goal of the organic movement: to nurture and grow the organic market place for farmers.

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Posted by Fred Burmeister,

Dear Ms. Armitage,
Seems that I touched a nerve. Good!
You are correct only in your first assumption. I am a proud member of the Traditional Cosmetic Industry (TCI), having been employed in product development for over 42 years, I found it best to maintain an open mind to all trends including certified organic (CO) products, which I do not read in your commentary on my response. That said, it is interesting to note that Ms. Timmons has not responded to my post in 45+ days, nor has anyone else from the CO side of the fence...until yours!
Aside from my obvious orientation, you've misrepresented everything else in the response.
You don't recognize my agreement with Ms. Timmons on the issue of the misbranding of "swizzle dust" organic products as genuine organic. However, "certified organic" is only one of the restricted list of claims able to be applied to cosmetic products. A good one, at that, as it is based on the premise that certified organic ingredients are more "pure" than their non-certified counterparts that are routinely utilized in traditional cosmetic products. The assumption is that they are free of pesticides, toxins, and "chemicals," and thus CO is being proffered as more than a claim, but a path to a greater good, as if in
some way when we slather our bodies with these "organic" products we will lead a healthier, happier existance.
I was not arguing which aspect of the cosmetic industry was better, only that the adoption of USDA Organic standards, promulgated for food, does not represent the different technology required of cosmetics. But you chose to ignore that fact.
You cite numerous examples indicting the TCI of claims exaggeration, of duping their clients, of scientists and researchers finding ingredients to be "toxic,"that "major manufacturers" are adulterating products, "photo shopping" models and hiding behind "secrets."
Let's analyze some of those statements. I would like you to substantiate the most inflammatory of these, that major manufacturers are adulterating their products. Having been employed in the US by several of the best of these evil major manufacturers, I can categorically state that I have not witnessed the adulteration of any product nor has it been the policy of any to utilize adulterated ingredients.
You should review the definition of adulteration. You will find that adulteration is the serupticious addition of a substance to another substance to alter the value of the original substance. Case in point: the addition of Melamine to Wheat Gluten used in pet food that sickened and killed many domestic pets and worse, its addition to infant formula. Can you name any major cosmetic manufacturer that has deliberately added such substances to their cosmetics? (I specifically mean major manufacturerers)
The fact that TCI products may be found to contain "pesticides and toxins" is not adulteration but contamination. The FDA has allowed contaminants to be present in miniscule amounts and that has aroused the ire of many in the CO cosmetic field. Can these standards be tightened up? Certainly. Is this adulteration? Certainly not. Are there such contaminants in certified organic ingredients and products? Perhaps.
I also find it hard to believe that only the TCI giants "photo shop" models. They have been caught enhancing photographs. Are they alone? No. Are CO cosmetic manufactures also "photo shopping"? Perhaps.
Please do not try to tell me that Co manufacturers do not hide "secrets." EVERYONE has trade secrets.

To reiterate, the current state of affairs in CO cosmetics is a mess. Adopting standards based on faulty science and misinformation gleaned from internet searches and emotional issues does nobody any good. Timmons and "Fig + Sage" are attempting to establish their own standards and they should be allowed to fight it out. We can only benefit from their competition.
If your argument is that the implementation of ANY standard is better than what we have now, I cannot agree with you. But let those standards be based on solid science, much in the fashion of the Cosmetic Ingredient Review process and in line with the cosmetic standards issued by the FDA, and we can have some common ground. Until then, we can agree to disagree.

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Why the cosmetic Industry DOES need an "Organic" Standard

Posted by Karen Armitage,

I am guessing Mr. Fred Burmeister must be from the Traditional Cosmetic Industry.
He protests strongly against an alternative to synthetic chemical products.
The Organic Personal Care Industry is growing strongly because people want to avoid chemicals. This observation is highlighted by the number of manufacturers making unsubstantiated organic claims.
The fact consumers are continually duped by cosmetic manufacturers through their advertisements and claims is reason enough for it to be more than appropriate to demand a standard.
A standard lends strength and accountability to genuine organic formulations.
The ‘well founded science of today’s personal care industry’ has been criticized by scientists and researchers in animal studies and human trials, finding many ingredients used by the industry are toxic.
As to an alternative to ethyl alcohol as a preservative, please take a look at the legitimate organic products already on the market. Shelf life can be extended and microbial inhibitors can, and are found in blends of natural ingredients.
There are organic creams and lotions that are stable and shampoos not based on soap.
I am not sure what Mr. Burmeister means by ‘elegant’ but many natural, unadulterated, non-synthetic and nourishing raw materials have been used by people of various nations for thousands of years, well before ‘Cosmetic Science’
As to the “Organic” websites who use ‘misinformation’ … here lessons have been learnt from many of the major cosmetic manufacturers who photo-shop their models, hide behind secret, trademarked formulations/ingredients as well as the blatant over statements of results their products promise consumers.
To say the industry is not perfect is a gross understatement.
You are correct, Mr. Burmeister, market forces usually determine the fate or otherwise of any commercial endeavor. If recent history is an indicator, the Organic Personal Care Industry is here to stay.

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Why the Cosmetic Industry doesn't need an "Organic" standard

Posted by Fred Burmeister,

Look at the mess the "Organic" faction created when they promoted the use of USDA Organic rules, well intended for food, but totally inappropriate for personal care products. The restrictions the NOP placed on formulators promulgated a step backward from the unique and well founded science of today's personal care industry. To illustrate this point, try to find an effective preservative other than ethyl alcohol that would be acceptable under NOP. Better yet, try to find an example of a commercial "Organic" cream or lotion that is both stable and elegant, or a shampoo not based on soap! 300 year old technology is not a step forward.
As with the author, I don't side with marketers who lie about content or illegtimately manipulate the rules to make their products appear to be organic. By the same token, I don't side with OASIS or QAI/NSF who are using this issue to carve out a market for their businesses. The cosmetics market has and will continue to weed out the abusers of any claim. After all, "Organic" is merely a claim, not a way of life or path to a greater good as they would have you believe.
It's time to take a hard look at the "agents of Organic" that are attempting to manipulate the personal care industry and recognize them for what they are. Aside from the goodness and well intentioned (appearing) terminology in this piece, go to any "Organic" website to see the misinformation and otherwise negative "facts" they promote about anything "chemical."
As an industry, we're not perfect, and even after reading a recent and well-done article describing Cosmetic Science as bad science, I'll stay with Cosmetic Science over "Organic Science."
Market forces will determine the fate and direction of this very small portion of our industry. We all have too many other important issues to worry about to waste our time here.

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