I have been doing a lot of reading lately about this subject, as I try to determine whether BumbleBee Lane SoapWorks should go through the process to be certified as an organic manufacturer, and this is what I’ve discovered along the way.
1) There is no single organization which certifies cosmetics as organic. While a company can apply to the USDA, (or their government body) for certification, the USDA does not control the certification process in general, and any company can set themselves up as a certification “body”. Since all of the requirements for organic certification exist officially only for food, each organization is free to adopt their own definition or interpretation of these requirements as they apply to cosmetics.
So, the first thing to consider when you’re assessing a certified organic product is who is doing the certifying. Look for a reputable company that has the resources required to adequately audit the manufacturing processes of the applicants, and read their specific requirements. Any company that has gone through the certification process should be happy to provide you with this information.
2) The USDA has identified three categories of labeling organic products, which most certification bodies adhere to. It is important to note that the only place where these are legally binding is in food production. At this point, the organic cosmetics industry is self-regulating, which means a company can market its products as organic with no certification in place.
100% Organic: Made with 100% organic ingredients
Organic: Made with at least 95% organic ingredients
Made With Organic Ingredients: Made with a minimum of 70% organic ingredients with strict restrictions on the remaining 30% including no GMOs (genetically modified organisms)
Products with less than 70% organic ingredients may list organically produced ingredients on the side panel of the package, but may not make any organic claims on the front of the package.
Seems pretty straightforward, doesn’t it? Not so much….
Where it gets tricky, and what many people don’t realize is that a 100% organic certification does not mean that the food has never been subjected to non-organic treatments, or that the cosmetic contains nothing but organic ingredients. Doesn’t even mean that the food or cosmetic contains no synthetic ingredients. Say what?
Every organic certification out there allows the producer/manufacturer leeway on certain ingredients or processes, if they are deemed to be necessary to the production of the item, and an organic alternative is not available. If you want to check out the full list of what is and is not allowed in organic products, you can find that here. Scroll down to Subsection G: Administration. For cosmetic purposes, we need to look at § 205.605 Nonagricultural (nonorganic) substances allowed as ingredients in or on processed products labeled as “organic” or “made with organic (specified ingredients or food group(s)).”
This is a list of all of the synthetic ingredients that are allowed to be in a product and still be classified as 100% organic according to the USDA. Of particular note is sodium hydroxide, more commonly known as lye. As I keep harping on, no lye=no soap. When I first started researching the subject, I couldn’t understand how soap could ever be certified as 100% organic. Even though there is no lye left in a properly made bar of soap, it was definitely a required ingredient. This list is the answer. So to be clear, 100 % organic means 100% organic plus anything on the list of allowed exemptions
So what does this mean? It means that 100% organic products may not be 100% natural. This was a shocker to me, especially when it comes to food. I thought the first criteria would be that the product was all natural, and that the organic label was an increased level of “goodness”!
So when you are bopping your way around the Internet looking for natural cosmetics, keep these things in mind.
Here is a ‘cheat sheet’ to use in evaluating claims you may find on cosmetic products:
a) Soap – can be “100% organic”, can never be “100% natural” or “all natural”
b) Emulsified lotions and creams (water as an ingredient) – can be “100% organic”, “100% natural” or “all natural” . CAUTION: this designation means they are not using a preservative, or they are relying on a form of natural preservative, or they are mislabeling their product. (See below)
c) Whipped butters and scrubs, balms, salves (no water included) – can be “100% organic”, “100% natural” or “all natural – these require no preservative as there is no water in them to provide an environment for yeast, mold, and bacteria to grow. However, many formulators, including myself, will add preservative to a product such as a scrub that is designed to be used in and around the bathroom, due to the high likelihood that you are going to accidentally splash or drip water into the container while using it. A tiny amount of water is all it takes to make the nasties happy!
A word on preservatives: To the best of my knowledge, there are no natural preservatives which have been proven to be effective in preserving a product for any significant length of time, so please be cautious. Do not expect that you will be able to identify when a product has “gone bad”. Yeast, mold and bacteria can multiply and thrive in your lotion with no visible signs. Do not expect to be able to treat an “all natural” product the same way you treat one with a synthetic preservative. A product made without preservatives may have a shelf life of up to 6 months IF IT IS NEVER OPENED, assuming that they used fresh ingredients. Ask the seller when it was manufactured. Once it has been opened, refrigerate it and toss it after a month. Don’t be deceived by the fact that it still “looks fine”! Take a look at it under a microscope and it could be teeming with life, and unfriendly life at that, such as staph, eColi or botulism….things that can make you very sick, or could kill someone with a weakened immune system. It is just not worth the risk.
Keep all of this in mind when you’re comparing products, and don’t assume a statement is accurate just because its coming from a name brand. I was shocked just this morning when I dropped by the Burts Bees website and found that they are marketing their soap as 100% natural! I guess they found some magical, natural lye to make their soap with, or they are basing the statement on the fact that there is no chemically identifiable lye left in the finished bar. That’s like saying there is no sugar or flour in a cake because you can’t see it! Nonsense….
As always, keep asking questions…..