standard. It seems like a great waste of energy to develop competing private standards that create confusion and inconsistency in the meaning of “organic personal
care.” Some have advocated for a pre-NOP type of unregulated environment for
organic personal care. Do we really need an environment in which “my standard is
better than their standard” is how products are presented to consumers?
In addition, some want to be able to include synthetic preservatives and make
organic claims when raw organic ingredients are chemically transformed to synthetic substances that are typically found in conventional personal care products.
I feel that such substances may be petitioned to be added to the lists of allowed
substances in the NOP; however, the NOSB is the official body that must approve
the addition of such substances.
I view the NOP as the solution because it
has a labeling category for every type of
product and has an open, public process of
making changes to the regulations. Any proponent of changes may petition the NOSB
to adopt those changes. The alternative is
chaos and confusion that will harm the
whole organic industry. Because the USDA
Organic seal is the most recognized indicator of organic, if it’s used on personal care
products then it should be the only standard
for organic personal care products.
The biggest criticism of using the NOP
for certification of personal care products is
that personal care products require synthetic ingredients that are not allowed in
food. However, other people see that restriction as the biggest argument in favor
of using the NOP—because they don’t think such synthetics belong in organic
products. It appears that private standards are being proposed by those who want
the benefit of making organic claims without being required to make significant
changes to their product formulas.
Some people criticize NOP regulation of personal care because they say it’s a
just food standard and that it’s not applicable to personal care products. However,
I see the NOP as an organic standard that reflects the qualities that consumers expect to find in any product that makes an organic claim.
“I see the NOP as an
organic standard that
reflects the qualities
that consumers expect
to find in any product
that makes an organic
claim.”
—Sam Welsch
Pro-NOP Regulation
Horst Rechelbacher, founder, Intelligent Nutrients, a
USDA Organic-certified personal care line, and founder
and former CEO of Aveda
“Personal care products are digested in the body like food, except they
are absorbed through the nose, lips, mouth and skin. If we are going to
call something that people put on their skin, or spray in the air “organic,” it should be safe
to eat. Will I say that creating a line of high-functioning products that meet the NOP food
standards was easy—no! It took a lot of time and money. It’s not easy, but it can be done. I
have proven that. Organic farming is not as easy as conventional either but we support it
because it is the right thing to do. There should not be any organic regulation changes
made to accommodate the cosmetic industry. By weakening the current regulatory standards, we will weaken the organic industry. People need to live up to the standards. If we
strive for the highest standards, the NOP food standards, we we will end up developing
healthier, better products in the long run.
Only one simple step needs to be
taken immediately. Change one word
in the current NOP policy on organic
personal care products from “such
products may be certified under the
NOP,” to “such products must be certified under the NOP.”
The NOP policy also has a long-term plan: “If additional rulemaking is
required for such products to address
additional labeling issues or the use of
synthetics in such products, the NOP
will pursue such rulemaking as expeditiously as possible.”
David
Bronner
CEO of Dr.
Bronner’s Magic
Soaps,
manufacturer of
NOP-certified
personal care
products; member
of NSF committee
Position Summary: Personal
care products claiming to be
“organic” should be regulated
under the current NOP standards, however, it’s acceptable
to create a separate section
within the NOP MWO regulations for additional allowances
restricted to personal care.
Dr. Bronner’s is in entire agreement with the recent recommendation set forth in the NOSB discussion
document “Solving the Problem of
Mislabeled Organic Cosmetics & Personal Care Products,” submitted at the
NOSB 2009 Spring Meeting. This recommendation suggests making the
NOP standards mandatory, not simply
voluntary, for cosmetic/personal care
products that make organic claims.
Organic integrity in body care
means that a product that claims to
be “organic” is composed of organic
ingredients produced with minimal
processing in compliance with USDA
