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Organic and Natural: Caveat Emptor

By: David C. Steinberg, Steinberg & Associates
Posted: January 25, 2010, from the February 2010 issue of Skin Inc. magazine.

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These standards describe five categories of ingredients: water, minerals, physically processed agro-ingredients, chemically processed agro-ingredients and synthetic materials. The draft details what materials are and are not allowed. It is interesting to note the chemical reactions that are and are not allowed (see COSMOS Chemical Reactions).

Under Appendix II of the COSMOS standard, the following synthetic ingredients are allowed: benzoic acid, benzyl alcohol, dehydroacetic acid, denatonium benzoate, heliotropine, salicylic acid, sorbic acid and tetrasodium glutamate diacetate. The second part of Appendix II lists the mineral origin products allowed—which contradicts the initial five categories of organic ingredients listed since “mineral” is included one of the organic ingredient categories.

California Organic Program (United States): Products sold in California must comply with the 2003 COPA Act10 to be labeled organic. These products also must be at least 70% organic, not including water and salt content. Like the USDA program, this program attempts to apply a food law to cosmetics. All organic ingredients used in organic products must be certified by one of the organizations listed by the USDA. There are additional registration fees and other labeling requirements.

Organic and Sustainable Industry Standards (OASIS, United States): OASIS was developed and is observed by major cosmetic companies in the United States such as L’Oréal and Estée Lauder. This standard certifies products at two levels—organic or made with organic. The made with organic designation requires 70% minimum organic content with additional criteria for the remaining 30% of ingredients. The organic label claim will require a minimum of 85% organic content until January 2010, at which time it will increase to a requirement of 90% minimum organic content; the minimum requirement will increase a third time to 95% by 2012. Products that cannot achieve a 95% organic level, such as soap, must use the made with organic claim.

This interval approach takes into consideration the fact that at least two years are necessary for surfactant and emulsifier manufacturers to put enough products into the commercial stream to supply the industry with organic versions of functional ingredients. Since one of the goals of OASIS is to promote the development of more raw materials developed from organic starting materials, this approach works with chemical manufacturers to achieve these goals.11