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Organic Labeling in Personal Care Products

Consumers often pick up shampoo or soap with the term “natural” or “organic” hoping for a guarantee that the product is free of harmful ingredients. Unfortunately in the personal care industry, it is not that simple. The term “natural” has no legal meaning. And natural does not necessarily mean safe, after all tobacco is a “natural” ingredient and many toxic chemicals are “derived” from naturally occurring substances. The term natural has been around for many years and most consumers have learned to ignore it, so the personal care industry has focused on the word “organic.”

Unlike the food industry, there are no regulations in the personal care industry around the term “organic”. You can name your company Suzie’s Organics without a single organic ingredient. So many in the industry has been clamoring for certification rules to separate the “real organics” from the “imposters”.

But the issue is extremely contentious. For one thing, organic does not necessarily mean healthy (as evidenced by the organic Poptarts at Costco.) Nor are organic compound necessarily nontoxic. “Organic” compounds are produced by living or formerly living things that contain carbon which means that petrochemicals, human waste, horse manure, compost and Mercury can also be considered “organic.”

To confuse matters even more rules for organic certification were written for the food industry. Manufacturers are restricted to using food ingredients so most traditional emulsifiers and preservatives can not be called organic. But personal care products require preservatives to prevent contamination.

Cosmetic companies are responding differently. Some companies are sticking with their existing formulas insisting they are safe. Some are slapping organic on their labels hoping consumers don’t know any better. Others are creatively modifying ingredients, in some cases eliminating safe, effective ingredients in order to adhere to the ever changing certification standards. A few have come out with 100% organic, preservative-free products but these generally contain warnings to keep the products out of high heat and direct sunlight and avoid placing unclean fingers in the product. This can be a tough sell for lotions and soaps that are applied with fingers and get stored in gym bags.

Many companies have been lobbying to change or reduce standards to meet the needs of the industry. Products can now be certified organic if they contain 70% organic ingredients. Some companies have figured out how to manipulate the percentages by using organic “teas” or “juices” as their base instead of water (which can not legally be included in the percentage calculation.) Hopefully, all this upheaval will lead to genuinely safer products in the long run. In the mean time consumers are left confused, and often misled, by all of the marketing hype.

So if we can’t rely on terms like natural and organic, how can we determine the relative safety of our personal care products? Most consumers assume that the FDA provides some level of guarantee for our products. But the FDA does not regulate personal care products the way they regulate food and drugs.

The FDA granted self-regulation to the cosmetics industry back in 1938. This ruling has never changes. Products can be marketed without testing or government approval of ingredients. The cosmetic industry will tell you that their ingredients have been used safely for years. But nobody has tested the long-term affects of our continuous exposure to an average of nine personal care products a day, with roughly 120 chemicals spread among them.

Scientists have found many common cosmetic ingredients in human tissues, including industrial plasticizers called phthalates in urine, preservatives called parabens in breast tumor tissue, and persistent fragrance components like musk xylene in human fat. Do the levels at which they are found pose risks? For the most part, those studies have not been done. All we have to go on are animal studies or industry reports of workers with high-level exposure.

Europe, Canada, Japan and many other countries have taken a cautious approach in recent years, banning ingredients where the existing data was compelling enough for their panel of scientists. They have also recently passed a law that will force cosmetic companies eventually to prove the safety of their products. In the United States we have no such laws so several consumer advocacy groups such as the Environmental Working Group have tried to make the issue more transparent by compiling toxicity studies from publicly available databases around the world. They have rank ingredients, as well as some branded products by their perceived hazard based on existing studies.

What can you do to ensure the safety of your products for now? Unfortunately, there are no short cuts, no simple labeling words that ensure the safety of a product. Be informed and know the facts, however frustrating they may be. Ignore the marketing fluff and look at the ingredients list. Avoid products which don’t give a full listing of ingredients. Terms like fragrance and preservative are a cop out. A great resource is to use the Environmental Working Group database to look up your products and to research common ingredients found in products.

Where do we stand on organics? We will advise you to buy as much organic food and cotton as your budget will allow. When it comes to personal care products, ignore the fluff and check the ingredients. Though the majority of our organic ingredients are certified, as a manufacturer (read mixer, pourer, and bottler) we have to go through our own certification process in order to be able to sell our products as certified organic. We hope to be able to sell many of our products as certified organic by the end of the year.

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