fined to the “made with organic” (MWO)
level. Dr. Bronner’s does approximately
90 percent of its business in the current
NOP MWO space with products that do
not utilize synthetic preservatives or hydrogenated or sulfated ingredients, yet
we are willing to see the NOP MWO
space expand to include allowances such
as these that were worked out through
the NSF process. This standard represents a responsible compromise between
mainstream cosmetic industry interests
and organic consumers.
However, we are adamantly opposed
to private industry standards that seek to
permit such processing and synthetic allowances for products labeled outright as
“organic.” This space should be preserved for organic consumers who seek
organic personal care that complies with
basic organic consumer criteria; that organic products are free of hydrogenated,
sulfated and synthetically preserved ingredients.
We believe that the NOP could adopt
the NSF/ANSI processing and preservative allowances specific to MWO personal
care in the same way it made the synthetic sulfite allowance for MWO wine.
Proper annotation will ensure the USDA
NOP is not otherwise affected by allowances restricted to MWO personal
care.
Some feel that there should be no ex-
pansion of NOP for additional process and preservative allowances
for personal care, even if confined to MWO. They suggest that the
very fabric of the USDA NOP will unravel. Certainly I agree that
if the outright “organic” claim space was involved that would
be the case, but this is silly for the MWO space. A shampoo
based on permitted non-organic surfactants whose label says
“Shampoo Made with Organic Lavender Floral Water,” is making a straightforward claim that does not imply the shampoo
itself is organic. If, however, the shampoo label said “Organic
Shampoo” per a private standard, then that would be outrageous abuse of the “organic” claim and is exactly the problem
we are trying to solve. But this not the issue with an MWO
claim.
On the other side are private industry interests who argue
that no additional allowances can be made in the NOP for
personal care even if restricted to the MWO space, yet those
same interests advocate for private industry standards that
Barbara Robinson, deputy
administrator of USDA’s
Transportation and Marketing Programs and acting director of the NOP
(speaking at the 2009 NOSB
Spring Meeting)
“I did consult with our attorneys,
and asked if we had this jurisdiction.
And their reply was actually, yes, we do,
that these are merely processed products.
That's what they would be. And the
simple way to approach this, the way
that I came to understand it, was that
what we would be doing is basically expanding the National List for a broader
set of processed products—namely, personal care products that are largely agricultural in their origin, but require
additional synthetics in order to be finally produced, and then labeled under
our labeling scheme. So, for example,
you could take the NSF standard, the
ANSI standard 305 out there, give it to
the Board and say do you … want to
incorporate this by reference, and turn
around and make a recommendation to
NOP that we expand the National List
with all of these synthetics, and their
annotations, and proceed with rule
making to allow for these products to
come under the labeling scheme of the
NOP regulations.”
This mouthwash
product is one of the
first items to undergo
NSF certification.
permit these processes and synthetics
in the outright “organic” claim space.
Organic is organic, whether under
NOP or a private standard, and it’s
hypocritical and inconsistent to argue
against inclusion of processes and synthetics restricted to NOP MWO space,
but then say they’re fine in the “
organic” space under some other standard. As for the next steps to take, the
NOSB should immediately move to
regulate the outright “organic” personal care claim space under existing
USDA NOP 95-percent organic regulations. In the longer term, NOSB
should work to adopt allowances
worked out in the NSF/ANSI process
to apply to and comprehensively regulate products in the MWO space.
Sheila
Linderman
Organic product
and certification
consultant specializing in international
markets for food and
personal care.
Position Summary: NOP is
adequate for a limited number
of domestic products, but the
private standards are better
geared to a broader spectrum
of products that can be
marketed globally
It is my job to help my clients obtain organic certification. Until recently, all of my clients were food
processors. It has been, therefore, my
task to help them get certified to the
NOP, or whatever organic standard
prevails in the country of manufacture
or countries to which my client plans
to export. This has been fairly clear-cut. In the past year, however, most of
my new clients have been manufacturers of personal care products. For
those making and marketing their
products in the U.S. and Canada,
NOP certification has been fine. How-
