Definitions of Natural and Synthetic

 The food world has continued to struggle with many of the same issues that plague the personal care industry, in spite of having a fairly well-developed set of standards. The Organic Food Production Act, which generated the U.S. National Organic Program for foods, contains a definition of the word “synthetic” which is not without controversy. Because the word “natural” is even more fraught with problems, OFPA chose to use the term “non-synthetic” instead of “natural” (a linguistic sidestep that didn’t exactly solve any of these problems).

An example of how this affects the cosmetics industry is the certification of soap. Soap is made by reacting a fat or oil with an alkali such as sodium hydroxide, a “synthetic” material allowed by the NOP. Soap itself, in fact, is listed in the NOP’s National List as a synthetic material. If a company applies for certification of a soap and labels it as, e.g. “sodium cocoate” (nomenclature required by the cosmetic industry), this name implies a chemical reaction between the coconut oil and the sodium hydroxide, resulting in a new chemical compound, which fits exactly the NOP definition of “synthetic”. This synthetic material could not be certified to the NOP. If, however, a company describes a soap simply as a mixture of organic oils and the NOP-allowed synthetic sodium hydroxide, ignoring the chemistry, the mixture could be certified. This could be called this the organic food industry’s “don’t ask, don’t tell” policy.

These challenges, and the confusion created by them, have resulted in an almost continuous effort in the food industry to do a better job with the English language. A 2007 attempt to come up with a better definition of “non-synthetic” by the current National Organic Standards Board (NOSB) involved a new approach that unfortunately did not seem to address all the points previous boards had discussed, as well as introducing new issues. This recommendation was referred back to the NOP’s Handling and Materials Committees for more work, and OTA has formed a working group including current and past NOSB members and the trade to sort out and examine the issues. This work will certainly affect how the food world looks at the processing necessary to convert organic agricultural materials into organic personal care ingredients.

           
           
   

Organic Personal Care:
Developments Around the World

By Timothy R. Kapsner


The buzzword in most industries these days is “globalization.” Industries around the world are looking at the global marketplace as the place for growth and the personal care industry is no exception. This movement to globalize, along with the ever-increasing awareness of environmental and sustainability issues, places a high value on claims such as “organic” and “natural.” How these claims are perceived and regulated around the world has thus become of primary interest to every company that makes a personal care product.

In the 2007 April/June issue of Organic Processing Magazine, we chronicled the ongoing attempts to move the personal care industry through the era of confusion and conflict surrounding organic claims. Since then, more companies throughout the world are using various standards within the organic platform to introduce products or entire product lines.
In the United States, Origins has launched a nine SKU organic line, including six that bear the USDA logo. In Europe, the success of Sanoflore’s organic line brought them to the attention of L’Oréal. The European personal care giant bought the company in June 2007 for over 600 million Euros, more than 40 times the company’s annual sales. Stella McCartney, a UK designer fragrance brand, launched a skin care product line certified to the Ecocert organic standard. The success of the line in Europe has prompted the company to expand to the United States, beginning what will surely be a wave of certified organic personal care products coming to the United States from Europe.

U.S. Personal Care Standards
While the current U.S. organic personal care marketplace is chaotic with many products making a variety of non-verified organic claims, there have been many developments this year that will give companies several certification options to help lend credibility to their organic products. These developments also are a great opportunity for companies to get involved and support standards they feel represent their products and vision.

NOP. At one end of the spectrum, there is the National Organic Program (NOP), the most widely recognized organic certification, borrowed from the food industry. Companies like Origins, Dr. Bronner and Erba have created several popular products that bear the USDA seal, but because this certification was made for food, it never addressed many of the processing methods used to make personal care ingredients. In the past, the fact that the NOP did not address these methods left many personal care companies who wanted to offer a wider range of higher functioning organic products with no viable certification options.

NSF. The Organic Trade Association started a task force to address this issue and NSF International, a standards development organization, has since taken over this effort. The idea was to start with organic materials from the NOP food standards and determine what processes used to make cosmetic ingredients and products would fit into the organic philosophy.

The NSF standard that went into public comment earlier this year does allow a range of “green chemistry,” however, this standard can only be used to make “made with organic ingredients” claims. NSF certification applicants that want to have their finished products fully “certified organic” are referred by the NSF process back to the NOP food standards. This would effectively leave the U.S. marketplace unchanged with respect to making front label “certified organic” personal care product claims. Widespread recognition of the NSF logo on cosmetic products could at least potentially give legitimacy to “made with” claims and help sort out the current chaotic marketplace. The comment period for this standard ended March 3, 2008 and the NSF joint task force will take this feedback into account to modify the standard into one that can be forwarded to the NSF board for their consideration. If all goes well, NSF could have a standard ready for use by the end of this year.

OASIS. Another new U.S. organization is making an attempt to clear the smoke and lay the groundwork for a unified voice in this confusing world of organic and natural claims. OASIS (Organic and Sustainable Industry Standards) announced its genesis in the fall of 2007. Created as a non-profit industry trade organization, OASIS will focus on sustainability issues and standards. Its goals include communication, collaboration and education. Its stated mission is to provide “verifiable standards that support and promote organic and sustainable production for the health and beauty industry, utilizing principles of incremental improvement and continuous change.” The first OASIS standard has been created for organic personal care products. Unlike the NSF standard, the OASIS standard allows companies to make a “certified organic” front label claim, and products can display the OASIS “certified organic” seal on their product. The organic content requirement is significantly higher than what is required by the European Ecocert standard.

Unlike the NOP food standard’s “certified organic” claim, the OASIS standard allows and recognizes a limited amount of green chemistry to be used to make processed personal care ingredients, such as soap, fatty alcohols and esters, in products labeled “certified organic.” This is similar to the standards that have been developed by Ecocert and other organizations in Europe and elsewhere in the world. A growing list of companies have joined OASIS as founding members. The group has created its organic personal care standard and is expected to be opening its doors for certification in the U.S. marketplace in spring of 2008.

Natural Standards. Although the definition of “natural” is still somewhat vague in the eyes of the industry and the consumer, natural products have an important place in the world of organic. Natural product claims are considered by many to be the “entry level” into the organic world. Many companies start out making products with increased natural content, then move “up” to organic ingredients and products.

Like organic personal care processors, the natural industry is working to better define themselves. Burt’s Bees, along with the Natural Products Association, has been working on a U.S. standard for natural personal care product claims, and many organic companies including Dr. Bronner’s Magic Soaps, Aubrey Organics and California Baby, have joined the effort. The group has announced that a seal will be available beginning this April for companies that promise to adhere to the group’s standard.

European Standards and Harmonization
The latest developments in Europe are going more in the direction of harmonization and international standards. The European Natural and Organic Cosmetics Interest Grouping, also known as NaTrue (www.natrue.de), announced on its website that it will focus on “the concerns of natural cosmetics manufacturers with a view to future regulatory guidelines in Europe and worldwide.” They encourage all interested companies, organizations and institutions to join their process. Some of the members of this group are Logona, Primavera, Dr. Hauschka and Weleda.

In addition, at the Beyond Beauty trade show in Paris on October 2, 2007, Cosmebio held a conference to announce a program to create a harmonized organic and natural personal care standard. Cosmebio, a trade organization created in 2003 to promote and coordinate the Ecocert standard, has taken the lead in harmonization. In addition, other European organizations involved in this are Soil Association from UK, BDIH from Germany and AIAB from Italy. The group has announced plans to have a draft of its harmonized standard ready by June. This standard will have two levels. The lower level will require an as-yet unspecified level of natural content, and the higher level will require a percentage of organic content, this requirement increasing in intervals once the standard is introduced.

Conclusion
Currently, the personal care industry is struggling tremendously to reign in organic and natural claims that are simply not based on reality. In today’s undefined marketplace, unverified products are being sold with front label organic claims that have virtually no organic content and that use many petrochemically derived ingredients. In an effort to improve this situation, it may seem like new standards for organic personal care products are being created these days almost as fast as new products. This proliferation of standards may be challenging for the consumer for a short time, while manufacturers, certifiers, regulators and consumers themselves determine what platform will be used to create a level playing field for everyone.

Timothy R. Kapsner is a founding member of the Joint Committee on Personal Care, a founder of OASIS and a senior research scientist at Aveda Corporation where he develops products and explores raw materials including organic ingredients. He is also an instructor at the University of Minnesota, the author of seven patents and a contributor for several industry publications. He can be contacted at tkapsner@aveda.com.


 
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