ever, those clients wishing to market
organic personal care products in the
EU, or other areas where the NOP is
not recognized, have requested help
with certification to a private standard.
For this reason, along with several
others that I will lay out, I believe personal care products should not be regulated solely by the NOP. And, while I
have absolutely no problem with the
fact that some personal care products
can be certified to the NOP as it is
right now, I am adamantly opposed to
the modification of the NOP if it in-
bar soaps. However, it’s impossible to talk about more complex products without
also talking about synthetics. Such synthetics (e.g., saponified oils) are specific to
the personal care and not included on the National List(NL). Revising the NL to
include a list of personal care-specific synthetics is objectionable for a number of
reasons, not the least important of which is that the already-existing list of synthetics on the NL was meant to shrink, not grow.
Another reason why personal care should not be strictly under the NOP is because OFPA requires accredited certifying agents (ACAs) to demonstrate a certain
level of expertise in the areas where they certify. The ACAs are already burdened
“The NOP is a
regulation based on a
congressional act called
the Organic Food
Production Act of 1990.”
—Sheila Linderman
cludes addition of verbiage that refers
to personal care products or the incorporation of provisions set forth in standards such as the NSF MWO standard,
as has been proposed to the NOSB.
Here’s why:
First, the NOP is a regulation based
on a congressional act called the Organic Food Production Act of 1990
(OFPA). Adding personal care wording or standards would be a violation
of this law, in my opinion, because the
act does not provide for expansion beyond food. The USDA saying that personal care products processed in
compliance with the NOP may be certified to the NOP is already an exception, but adapting the standards to fit
the needs of the personal care industry would be too far removed from
OFPA’s original intent.
Secondly, the NOP is fine for a simple range of personal care products:
massage oils, certain fragrances and
