Our Proposed Standards
for Organic Personal Care Products

Contrary to popular belief, body care products are not regulated by the USDA's National Organic Program. At this time, anything can be poured into a bottle and labelled "organic." This isn't right.

The term "organic" describes the use of natural methods for growing and processing agricultural materials. This is the dictionary definition and the definition in the minds of consumers. It is also the legal definition. The USDA National Organic Program summarizes it this way: "As a general rule, all natural (non-synthetic) substances are allowed in organic production and all synthetic substances are prohibited."

The word "organic" does not apply to manmade substances or objects, such as computers, cars, pharmaceuticals or other synthetic chemicals. It also does not apply to naturally-occurring substances that are not biological in origin, such as water, salt or minerals.

Organic standards for body care products, currently unregulated, should follow the same guidelines as those established for food. Substances that are applied to the skin and hair follicles are absorbed into the body. Unlike food, however, the body does not have the opportunity to break down and detoxify such substances via the digestive tract; they are absorbed directly into the bloodstream. This is why drug patches and hormone creams are so effective. For this reason, standards for organic body care products should be every bit as strict as they are for foods, if not more so.

In the marketplace, there is a great demand on the part of consumers for truly natural products that are free of preservatives and other artificial ingredients. The demand is so great that the market for products labelled "organic" has been growing at 20 percent per year—a huge growth rate. In stark contrast, the market for personal care products overall remains at a relatively flat 2 percent per year. Due to the absence of regulatory restrictions, manufacturers have an overpowering economic incentive to maximize profits by selling inexpensive synthetic ingredients to consumers who are willing to pay top dollar for products that are misleadingly—some say fraudulently—labelled "organic."

The flooding of the marketplace with faux-organic body care products makes life very difficult for ethical manufacturers who seek to create products that do meet the high standards of the National Organic Program as they are written for foods. Ronnie Cummins of the Organic Consumers Association has wondered if one of their goals is to drive every honest company off the market.

Our Proposed Standards:

Synthetics, as defined in the NOP regulations, should not be permitted in any quantity, large or small, in any personal care products labeled "certified organic," "organic," or bearing a trade name which includes the word "organic" or "organics." To do so is misleading. Any legally allowable exceptions should be taken only from the list for foods, because body care products can be absorbed by the skin and taken into the body, just as foods are.

Synthetic ingredients, if they are formed by the interaction of two or more agricultural ingredients, are still synthetic, and should not be allowed. Oleochemicals—hydrogenated oils, for example—are not permitted in organic foods and should not be permitted in body care products labelled "organic."

Just as in the NOP regulations for food, water and salt should not be included when calculating percentages of organic ingredients, because, though natural, they are not biological in origin. The aqueous portion of organic infusions, hydrosols, floral waters or other colloidal suspensions should not be counted in organic percentages. The practice of using the water content of hydrosols and infusions to artificially inflate the "organic" content of body care products has become widespread and has resulted in condemnation from consumer groups and the media. It should not be permitted, particularly when the remaining ingredients consist largely of synthetic petrochemicals or oleochemicals, which is typically the case. This misleading practice should be banned.

Allowed, but not calculated, natural non-agricultural substances should be extended to include, besides salt, other naturally-occurring non-toxic minerals—clays, for instance. Titanium dioxide and zinc oxide should not be permitted because they have been found to generate free radicals when exposed to sunlight.

Regarding preservative systems, it is not necessary to have chemical preservatives in personal care products. There are other ways to maintain the stability of a formula—non-synthetic preservatives, for example, or "self-preserving" (FDA term) formulas. Even if chemical preservatives were necessary, that would not be sufficient reason to allow for their inclusion in a product described as "organic." Grapefruit seed or citrus seed extract should be prohibited because studies show that it works only because of the hidden chemical preservatives that it contains.

Products that fail to meet the standards outlined above should be prohibited from using the word "organic" as part of the company name or in any other misleading manner. Similarly, manufacturers whose facilities have received organic certification but are used to manufacture non-compliant products, however lawfully, should be prohibited from referring to such facility certification to give the misleading impression that non-compliant products meet organic standards. Furthermore, the use of the unrelated term "organic chemistry" or similar terms should be prohibited in labelling or promotional materials if it is likely to be misconstrued as referring to natural agricultural ingredients or processes by the average consumer.

As with NOP standards as set forth for foods, permitted processes should be essentially limited to mechanical or biological methods such as heating, drying, mixing, grinding, churning, separating, distilling, extracting, cutting, fermenting, dehydrating, freezing, chilling and packaging. Excessive application of heat, vacuum or pressure should be prohibited if it results in alterations to the input material on the molecular level exceeding normal changes that might be expected from a traditional cooking process.

The National Organic Program clearly defines a prohibited synthetic as any "substance that is formulated or manufactured by a chemical process or by a process that chemically changes a substance extracted from naturally occurring plant, animal, or mineral sources, except that such term shall not apply to substances created by naturally occurring biological processes."

In short, organic standards for "organic" personal care products should be the same as the standards as currently set forth for foods.