I have so many feelings on this topic you guys. This is going to be a bit wordy but it's hard to find comprehensive info on the internet about it so I'm going to do the best to break it down for as well as share my experience of getting certified to be organic.
So, the basic situation for guidelines for organic beauty products are regulated by the USDA, not the FDA and the products have three main requirements:
*they must be produced without genetic engineering, ionizing radiation or sewage sludge (um, gross).
*there is a list of National Allowed and Prohibited Substances and the ingredient list of said product has to use the stuff that's allowed and not use the stuff that isn't allowed (the issue with this is that the ingredients are all based on food, the organic industry hasn't caught up yet with the beauty world so if you have Vitamin E in your product, for instance, you can't eat that so it's on the Prohibited Substance list - no bueno).
*the product must be overseen by a USDA National Organic Program (NOP) authorized certified agent, following all of the regulations. More on this in a sec.
Certified Organic products then they fall basically into three categories -
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100% ORGANIC- all of the ingredients must be CERTIFIED (we'll get to it) organic in this formula - every single one, processing aids have to be organic and they have to name their certifier on their label. These products may use the fancy USDA Organic Seal and they can say 100% Organic in the Title. All organic products must identify the organic ingredients in the ingredient panel. Very few cosmetic companies have products that are 100% Organic unless it is an oil or a hydrosol (fancy water).
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ORGANIC - so these guys are 95-99% organic so you can have a total of up to 5% of non-organic ingredients provided that they're still on the National Allowed List (excluding salt and water) and the organic ingredients have to be CERTIFIED (stick around) and you have to say who your certifier is. These products can also use the USDA Organic Seal and can say "Organic" in their title.
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"MADE WITH" ORGANIC - the rule is that these guys are allowed to contain 70-94% certified organic ingredients. The other 6-30% can be non-organic but, again, can't be on the Not Allowed list (like Vitamin E or like a Petrochemical). These products can NOT use the USDA Organic Seal and canNOT use the word "Organic" in the title. The ONLY place they can use the word "organic" on the front of the box/bottle is if they would like to say "Made with Organic"
after the title/name of product and then they can list up to three certified organic ingredients. They may also list the percentage of certified organic ingredients in the product on the front of the box/bottle and then they have to say who their certifier is. If your product is 69% organic or less then it's a no dice situation and you can just notate organic ingredients in the ingredient panel on the back.
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| Josie Maran is famous for bringing Argan Oil to the States - she's able to say "Organic Moisturizing Oil" on the front of the label because her product contains one ingredient - Argan Oil and hers is a certified organic ingredient. She did not pay to have the product itself as "Josie Maran's 100% Pure Argan Oil" (1.7 oz - $48) certified which is why she does not have the USDA Organic symbol on there. Acure DID pay to have their "100% Certified Organic Argan Oil" (1 oz - $12.99) tested, it passed, and, wherever the facility where it was packaged is, also passed an organic certification site-inspection. But the two products are essentially the same. In fact, the cheaper one is produced in a facility that works under a more strict guideline than the more expensive one which doesn't usually happen. |
So what's the story with these certifiers and all of this certification stuff - I'll tell you my experience as an example:
First off, the reason I would need Erin's Faces to have its own certification is because I jar and label items in my home/kitchen. Even if I purchase a formula that the labs and I have worked on, in theory, I could change (by adding additional ingredients, thus diluting its organic content) it once it got to my house so even if the lab is certified, because they aren't bottling it themselves,
their certification does not apply. Still with me? Okay -
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| Companies whose names/packaging imply natural ingredients - most of them DO actually have organic ingredients going on. For instance - The Body Wash from 100% Pure (genius name!) has six certified organic ingredients, three of which make up the bulk of the base of the product. The label says 100% Natural which has no actual meaning. Alba Botanical's SPF 15 looks super green right?! It IS a physical sunscreen (yay!) but out of over 45 ingredients only three are organic, one of which is Alcohol. Tata Harper's mask is listed as 81% organic on their website but because they're not certified they can't list it on the label, so they say 100% Natural which, again, is unregulated. Zoe Organics Diaper Balm is actually 100% Organic - every ingredient in there is certified. They just haven't paid to have the diaper balm itself certified which they discuss HERE. Instead they say "100% Organic Ingredients" on the front in a very small font (when you say "organic" it can't be bigger than half the size of the largest text and it basically has to be in black on the front panel - there are SO MANY RULES). |
I was getting new labels made for my skincare and my labs, whose formulas I work with, had given me a breakdown of the organic percentages for all of my products. The products I was looking to get certified were all in the "Made With" category and ranged anywhere from 70-92% organic in content. I thought it would be awesome to get an organic certification since my company's name does not imply a "green", "natural" or organic product as opposed to other lines who may or may not be certified but give you the impression that they are by the name Alba Botanica, Zoe Organics, etc. I also was excited about being able to list the organic percentage on the label as an added bonus and proof of goodness of the product in addition to giving a one ingredient shout out in the "Made With Organic" portion of the label (skincare labels are small so there was no room for three!).
There are TONS of Organic Certification companies in the United States and you basically pick one (some charge you for every organic product sold - a small percentage - and some don't). All charge an application fee, site inspection fee, processing fee and some other fees. Lots of fees. I ended up choosing a company called Eco-Cert as they said they could push my application through faster than anyone else could - thumbs up!
The application is a beast - you fill out what you wash your tools with (inclusive of ingredient lists), what you clean your surfaces with (more ingredient lists), what you use to protect against pests/rodents and draw a map of where all of that stuff is. You draw flowcharts of where the product comes in, where it gets processed, where it is stored, where you do your shipping packaging. You list all of your organic as well as non-organic (there's a fee for having both vs. just organic) products and you separate out all of the formulas, ingredients and finished products on clearly marked shelves with organic on top, non organic on the bottom. You keep logs on organic ingredient/product purchases and show sales records of them to prove that you're using the certified stuff and not something else when selling your proudcts. An inspector comes to your facility, or your kitchen if you're me, and checks all of that out, and makes sure everything is where it should be. In addition to following FDA cosmetic labeling rules you must get your labels cleared by your certifier since their name will literally be on them. They also look at your organic certifications - let's talk about those (you have documentation for
each organic ingredient certifying that it is indeed from an organic farm that has been certified by a third party certifier):
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The first version of the label - notice the 92% Organic, Eco-Cert Certification and "Made with Organic Aloe" Boxes
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| This is the revised version once I realized certification wasn't happening - we lost the %, the Eco-Cert symbol and cut "organic" out of the Made With statement. We did add the green to the organic ingredient in the ingredient list to help show the product was "green" and it actually ended up getting the "Certified Organic" back I just don't have it in this pic :). |
So - let's use my All-Natural (which is a totally unregulated word in the beauty world and kind of means nothing just to call a spade a spade - I'm using it since I can't say organic - more on this in a sec) Room/Linen/Body Sprays. They have a 91% organic ingredient list according to the lab that makes it for me. The lab has to produce a list of the certification of the actual ingredients - so, let's just use one ingredient - Aloe. So, they have to prove, annually, that the Aloe comes from a facility or from a farm that proves that it has been manufactured/farmed using all of those rules we talked about in the beginning. A certifier is a third party who comes in, checks all of that out and says yep, these folks are good - they're telling the truth. Great, so it's basically a paper chain of certifications from there. In Europe that's enough - the lab telling you that it's 91% organic. In the US that is not enough - you then have to get a third party certifier, like Eco-Cert for example, to take a sample of the Room Spray and verify that is is what they say it is. Only one of my labs did that - fun fact - the one that makes my Peptide Eye Cream. The rest did not which threw a wrench into the whole thing and ground it to a halt (as this was not information I was given in the beginning, only after I was nearly finished with the process). I could have paid to have each product tested (in addition to paying the $2200 fee) but ya'll, I was tapped out. Emotionally and financially. So after all of that it's a no go for now.
My lipbalms are a different story because the facility that I'm having them manufactured in (here in the US) has their own organic certification and the product ingredient deck is at least 95% organic - so we get to use the fancy USDA seal. They are also filling it and labeling it in THEIR facility. If I had my Peptide Eye Cream filled and labeled in my lab's facility (the one who can prove it IS a "Made With Organic" and whose lab is certified organic) then I COULD use the Eco-Cert name on the product as well as the organic % (since Eco-Cert is coincidentally their certifier as well) but that entails ordering about 1,000 eye creams at a time and I'm just not there yet.
Sidenote - a funny thing with the lipbalms is that I was looking at a non-organic and an organic formula. The organic formula was 25% more expensive than the non-organic. I asked what the difference was between the two and the answer was "nothing". So, I chose the organic, frankly because at that point I just wanted to be able to prove that SOMETHING in my line was organic, but I was paying for the certification fees (which is also why organic products tend to cost more - they cost the manufacturer more too).
My point in saying all of this is to read your labels. If someone says their product is organic but they don't have a certifier listed then they're uninformed (which I was in the beginning which is why you'll notice some product name changes) or they're being deceptive. If they're big enough to be in a store then they know better. Dr. Bronner's got fed up and filed a
suit saying that many lines, inclusive of Kiss My Face, Estee Lauder and more were touting their lines as green but using petrochemicals (on the Not Approved list). As a result Whole Foods now requires lines to follow the NOP standards for organic labeling but they are the only big company I know of who does.
It's a bit of a quagmire and even the certifiers gave multiple conflicting answers (for example, one person at Eco-Cert officially certified one of my products, sent the proof of organic paperwork and everything and then, days later, another person shot it down) so I'm still learning - kudos to you if you made it this far in the post :).
My two cents would be a vote for a more significant sliding scale of fees for third party certification of products qualifying to be organic and fees for establishing your facility as organic dependent on the scale of your business. They currently have a sliding scale for facilities but I don't believe there is one for certifying products. Think of how nice it would be to have proof that what you're buying from your favorite lines is legit organic! Instead of them trying to sell it to you in unregulated ways the imply it but can't prove it because the cost is too high. I support the paper trail and the jumping through of many hoops, just vote for lowering the cost (and putting Vitamin E on the "okay to use list"!).
Let me know if you have any organic questions and I'll answer them as best I can!
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