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.
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
