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Organic Formulating General Question?
As you can see my name…I’m wanting to be as “organic” as possible in my formulations by following certain standards. Does anyone know if I must use Ecocert or COSMOS approved items at all times, or just generally speaking? For instance they approve hyaluronic acid from certain manufacturers, do I need to use the one only approved by those manufacturers or is it simply ok to use hyaluronic acid in general?
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18 Replies
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Let me give you some examples:In case of hyaluronic acid, it won’t be okay because traditionally/originally, HA was obtained from rooster crests. Though this might have been from organically raised stock, it wouldn’t comply with a vegan label. ‘Modern’ HA is usually microbe derived and hence would automatically be compliant with any vegan label.Levulinic and anisic acid, though originally isolated from plants, can be obtained through fermentation of sugar cane or isolated from star anise, respectively, or they may be fully synthetic. The former are automatically Ecocert/COSMOS compliant, the latter are not.Stearic acid is also an example which may come from petrochemistry (not compliant with any label of your interest), could be obtained from tallow (not vegan), from palm oil (which may be from ‘bad’ rainforest-devastating and child labour monoculture or from sustainable and ‘label compliant’ production), or from ‘good’ sources such as coconut or canola which are always Ecocert/COSMOS compliant.If you go by the Swiss organic label (Bio Knospe), no cosmetic product except unadulterated organic oils and traditional sodium and potassium soap are approved because all other types of cosmetics are regarded as not sustainable luxury goods and hence do not comply with the strict opinion regarding ‘organic’.The EU organic label on the other hand is so tolerant as to allow for a certain amount of necessary additives which can not be produced according to the organic concept (this includes mostly preservatives). This organic label is approximately as strict as the Swiss standard agricultural label for integrated production (IP is the label most Swiss farmers adhere to).Bio Knospe and EU organic both allow in different ways a certain visible declaration on the package if you use a mixture of organic and non-organic ingredients.You see, depending on what you have from where, an ingredient may or may not automatically be compliant with the label you want to have.
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The answer to your question depends on a couple of factors.
1. If you are selling cosmetic products in the US and you want to use the term “organic” you should follow the USDA NOP Organic standards. (https://www.ams.usda.gov/sites/default/files/media/OrganicCosmeticsFactSheet.pdf) If you do not, lawyers in California and around the country will likely sue you.
2. If you don’t want to follow the USDA standards, don’t use the term “organic.” Stick with “natural” or “green” or something like that.
3. If you are formulating natural, there is no standard legal definition for the term. This isn’t to say that there isn’t a legal definition. The FTC has fined companies for claiming 100% natural when they are using synthetic chemicals.
https://www.ftc.gov/news-events/press-releases/2016/04/four-companies-agree-stop-falsely-promoting-their-personal-care4. If your consumers find Ecocert or COSMOS certification compelling then they are worth following. The reality is that most consumers have no idea what Ecocert or COSMOS are. You could just as easily come up with your own standard, create your own graphic seal, and certify yourself following your own natural standard.
If you want to be as “organic” as possible the first step is figuring out what you mean by that. The reality is that cosmetics are not natural. Pretty much all of them require some kind of human processing and most require non-natural chemical reactions to produce functional chemicals like surfactants, thickeners, preservatives, colorants, etc.
Groups like COSMOS or Ecocert have relaxed their natural standards over the years so they allow some ingredients produced via synthetic chemistry. They had to do this to expand the number of customers who would certify products.
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@Pharma So I dont care about the Vegan label, only “organic” “natural” yes natural isnt always better, I get that…idk why I always feel the need to say these kinds of things here…maybe I feel like a bit of a fish out of water as I know many science minded people kinda giggle at us “organic” folks
But I digress LOL Is COSMOS and Ecocert vegan? My products will have honey, possibly even tallo in a lip balm. Im actually Muslim so Halal must also be a label I concern myself with.
@Perry Do you find USDA to be more strict then cosmos? I plan on being “made with organic materials”
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@Perry actually found a great post if anyone else asks. http://theorganictarian.com/discover-5-benefits-aco-usda-organic-standards-certification-products/
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@Pharma Thank you btw! very helpful. So if Im abiding by COSMOS but Im living in the USA should I not have the word “Organic” in my business name?
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No, COSMOS and Ecocert aren’t vegan, it was just an example. Like halal, you can have ingredients according to your religion (= halal) or you can get a ‘real’ Halal label (= no believe in Allah required), both are not necessarily the same although they should be interchangeable.@Perry is a fare better reference regarding US regulations.I’m from Switzerland, we do things differently. If you want to sell something with the name ‘Bio’ (=German/French for organic) on it, then it has to be 100% certified organic according to a label (with the label clearly visible) such as the countries official organic label (Bio Knospe). This goes so far, that traditional brands containing the word ‘bio’ in their company’s name or on a specific product line had to change/remove it because they weren’t organic. They weren’t even thinking about ‘organic’ since their name was older than the Knospe label itself.TBH, I think the US organic concept sucks/lacks big times because it’s not that organic after all. Well, it’s better than nothing and it’s certainly more affordable than Swiss organics which costs approximately 3-5 times more than ‘normal’ stuff with a few exceptions at only 1.5-2 times the price.
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PeaceLoveOrganics said:@Perry actually found a great post if anyone else asks. http://theorganictarian.com/discover-5-benefits-aco-usda-organic-standards-certification-products/
This article is terrible and should be ignored. Anyone who claims this…
“You are what you absorb, so why is the average woman putting 120 chemicals on their bodies every day? Most of them untested. Many linked to cancer or reproductive issues.”
…is misinformed at best and lying at worst. I wouldn’t trust them to walk my dog.
Most of the chemicals that that average woman puts on her body HAVE been safety tested. They have not been linked to cancer or reproductive issues. Here’s a simple thing you can do if you are skeptical of my claims.
1. Get the ingredient list of a standard cosmetic product.
2. Count how many ingredients there are
3. Look up the safety information about each ingredient on the Cosmetic Ingredient Review site. https://cir-safety.org
4. See how many are not listed (I bet pretty much all are except maybe the natural extracts).The things that haven’t been tested are not commonly used in cosmetics. The fact that other countries ban ingredients is only a result of the fact that they ban ingredients that no one uses in cosmetics. Jet fuel is banned from cosmetics in the EU but not in the US. It’s a pointless ban. but I digress…
USDA is the most strict standard. It’s also the hardest to follow if you want to make functional cosmetic products that people want to use.
But if you want to make the claim “made with organic materials” you better follow the USDA NOP guidelines (at least if you are going to sell in the US).
https://www.ams.usda.gov/sites/default/files/media/OrganicCosmeticsFactSheet.pdf
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@Perry
I’m curious about your comment Perry said:But if you want to make the claim “made with organic materials” you better follow the USDA NOP guidelines (at least if you are going to sell in the US).https://www.ams.usda.gov/sites/default/files/media/OrganicCosmeticsFactSheet.pdf
Does this mean that the claim “made with organic…” can never be used, or can never be used with the implication that it was the USDA that certified it? On their USDA link it says “”USDA has no authority over…[products that]…do not make any claims to meeting USDA organic standards”.
Similarly, if a product is manufactured whose agricultural producer and product handler are USDA certified, but the cosmetic manufacturer is not, can the product claim “made with organic ingredients” as long as it does not mention the USDA? But if that is allowed, can you support your claim by showing the USDA certification of the raw materials, or is that now “claiming” USDA certification even though its not on the packaging?
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@RDchemist15 - great questions.
My advice to follow USDA guidelines if you are making the claim is strategic. I’m not a lawyer and this is not a question of science or chemistry.
What I do know is that California has a law related to the labeling of the term “organic” as used in cosmetics. Their law is enforceable.
http://www.fdalawblog.net/2012/08/california-labeling-requirements-for-organic-cosmetics-not-preempted/The California Organic Products Act of 2003 (“COPA”) prohibits any product handled, processed, sold, advertised, represented or offered for sale in California from being sold as organic unless it is labeled with terminology similar to terminology set for in the regulations by the National Organic Program (“NOP”). COPA specifically applies to cosmetic products sold or labeled as organic or made with organic.So, if your product ends up for sale in California (whether you brought it there or not), you better be following the COPA labeling rules or face a fine. There are lawyers in California who specifically look for products that use the term organic. They will sue you and you will have to prove that you are following the USDA organic product rules.
You’re right the USDA does not have authority over cosmetics. They have created guidelines for companies who want to make organic claims for cosmetics. The FDA says “Cosmetic products labeled with organic claims must comply with both USDA regulations for the organic claim and FDA regulations for labeling and safety requirements for cosmetics.”
https://www.fda.gov/cosmetics/cosmetics-labeling-claims/organic-cosmetics -
@Perry
Excellent comments. This was more a thought investigation as opposed to claims I’m currently pursuing but I know something in this vein will come up one day. Sounds like a lawyer would certainly be required trying to navigate this.
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We are formulating and reformulating all of our products to COSMOS Natural standards. The only reason is we sell our products in Australia, and Australia’s definition of what is and what is not natural is extremely restrictive. They consider orange oil that has been mechanically pressed to be natural, but a steam distilled essential oil is not.
The sole reason we took this route is that we are not claiming natural, but we are using someone else’s trademark and audit process to say we meet their standards - In essence, it is a low risk claim that actually isn’t a claim.
As many have pointed out to me, if you want to claim natural you can just make up your own definitions. If you want to claim organic - you must meet the organic definitions and certifications of that particular body - Soil Association in UK, NOP in USA etc.
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@Perry HaHa I will def take that into account about the blog post. I didn’t mean the post all together but her description of the organic standard for each label.
Now I know your not a lawyer but you dont think complying with COSMOS guidelines would help get me out of any issues with labeling “Made With Organic Ingredients” Obviously Im not claiming my product is 100% Organic nor do I plan to use the USDA logo. I was hesitant to use “Organics” after watching one of your lectures, but when I decided to follow COSMOS standard I thought that would help to justify the “Organics” in the name. All oils, butters, Essential Oils, and even extracts, when I can, are labeled Organic from the suppliers and many USDA Organic. So most all of the agriculture ingredients I use are organic. I guess my confusion would come into play with the actives, emulsifiers, gums etc….I’ve not really seen the label “organic” with these, rather many come from natural sources.
The document you sent seems very vague as it states I can say “made with organic materials” when its at a 70%. USDA deff is in my opinion not realistic for cosmetic formulation.
If my business got to a stage where I could afford, and it would be worth it to get Cosmos certified, would this protect my business in the states? Of course that’s thinking optimistically. Hey I think I have a good concept and nich so who knows, maybe Target will like me haha
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@PeaceLoveOrganics - no, being COSMOS certified will not mean anything legally in the US. It’s an EU standard. But you can test the legal system. Get a good lawyer, make your case and maybe you’ll win. It’s not a risk I would take but as I said, I’m not a lawyer.
Yes, USDA standards are not realistic for the vast number of cosmetics. Cosmetics are different from food. They are not natural.
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@Perry Im launching in a couple months so I did spend the $50 to buy web domains
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@Perry Well I went ahead and threw the $50 in the trash to say the least. Ive lost much more doing business. Im officially Peace Love Naturals haha. Thanks for the chat. I should have considered this better. Thankfully though I was able to get peacelovenaturals.com verse the organics I could only get the .org .net .us. But I cant seem to change my username on this forum.
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Well, better to only lose $50 than lose your house in a lawsuit.
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@PeaceLoveOrganics - send me a message and let me know what the new name you want. I can change it.
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@Perry Thanks so much, sent
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