“We think most organic consumers would not mind shaking a bottle in
order to avoid synthetic emulsifiers. When we were kids, it was ok to have the
chocolate in our chocolate milk settle to the bottom. It was just accepted that
you had to stir it,” Valva says. “The problem is that today there are many con-
sumers—and even retailers—who would look at the product and think there is
something wrong with it.”
The way Aubrey Organics deals with this challenge is through education. A
key part of this is training retail staff. This is also one of the reasons why the
company chooses to sell only in natural stores and not in mass beauty chains.
In addition to organic-compliant emulsifiers, Valva would also add organic
surfactants to his ingredient wish list. “The only one that has been available is
castile soap, which is somewhat harsh.”
Organic manufacturers also don’t have much to choose from in the way of
preservatives. However, Valva says that Aubrey Organics has overcome this hur-
dle by approaching the preservative system differently. “Conventional compa-
nies create a product and then throw in the preservative at the very end,
whereas we create the product from the beginning to be self-preserving. This
may mean adjusting the pH by adding something like citric acid to move it out
of the middle range where bacteria thrive. Sometimes it is about better packag-
ing. The point is, when you are formulating without conventional tools you
have to approach it differently from the start.”
Until some of these tools are developed, though, Valva says that under cur-
rent NOP food standards it will be almost impossible to make some USDA Or-
ganic certified products—such as shampoos or firm hold hairsprays—that can
compete with other options on the shelves.
Certification Conundrum
Besides a limited toolbox, Valva says another challenge is the fact that personal care manufacturers have to choose from a multitude of organic and natural certifications, ranging from USDA Organic and NSF 305 “contains organic”
to European certifications like Ecocert and Na True. Unlike food, which has
one organic certification that is accepted in the United States, personal care
manufacturers have to weigh the expense, marketing benefits and restrictions
of all these labels. “Many companies don’t get certified at all because they don’t
know which is best and it’s too costly to certify to them all,” Valva says. “They all
have a wide range of requirements as well. Seeing that the NOP standards were
made for food, not personal care, they are most certainly the most difficult to
meet. But even the NSF 305 ‘contains organic’ standards, which many U.S. or-
What Is the NSF 305 Standard?
When the NOP was written, it was focused on food and didn’t really
address the needs of organic personal care manufacturers. As a solution, NSF 305 was launched in 2009 to establish materials, processes,
production criteria and conditions specifically for personal care products that are formulated with organic ingredients. This standard allows “contains organic ingredients” claims for products with organic content of 70 percent or more that
comply with all other requirements. The NSF 305 standard is a consensus-based standard, which means it was developed based on balanced participation from key stake-holder groups, including organic personal care manufacturers, trade associations,
regulators, organic program administrators, organic product retailers and other representatives from the organic products community.
ganic companies including Aubrey Or-
ganics helped develop, are more strict
than many other ‘organic’ certifica-
tions around the world.”
Still, Aubrey Organics has decided
to go with the NOP and NSF 305, the
labels that Valva believes will still be left
standing at the end. The products that
cannot be certified organic are certi-
fied natural through the Natural Prod-
ucts Association. So far they have
certified about 25 products to the NOP
and have yet to certify anything to NSF
305. However, Valva points out that the
NSF certification does allow more flexi-
bility with processes and ingredients
than the USDA Organic standard,
which in the end may encourage more
manufacturers to go organic.
“The hope is that the NSF standards
will eventually get absorbed into the
NOP regulation as a provision for personal care,” Valva adds.
Clearing Up Consumer
Confusion
With all the different seals on the
market right now, it can be a bit overwhelming for consumers to keep up
with what they all mean. Even more
confusing to consumers is seeing a
product boldly displaying “organic”
across the bottle, only to flip it over and
find that it contains little or no organic
ingredients. The problem stems from
the lack of regulation. While food is required to meet the NOP guidelines in
order to have the word “organic” anywhere on its label, for personal care,
NOP certification is still voluntary and
the use of the word “organic” is currently unregulated.
To bring some order to the claims
chaos, last summer Whole Foods sent
out a mandate requiring that all personal care products either certify to the
NOP or NSF standards or take “
organic” claims off their label. In its notice, Whole Foods states: “We believe
that the ‘organic’ claim used on personal care products should have very