Tag Archives: Non-GMO

3 Things to Know about Ingredient Quality

Organic Ingredient: Castor Oil
Castor Oil – I think it is beautiful!

You probably use a number of ingredient suppliers…


1 – When buying organic ingredients, always ask for a Specification from the supplier. This describes the physical and chemical characteristics of what you bought. Like: Color, Aroma, Form (liquid, solid, etc.), pH, and so on.


2 – Okay – you just received the ingredient shipment. You asked that it be sent with a C of A (Certificate of Analysis). This is the proof that the product meets the requirements described in the Specification. First, compare the C of A to the Spec. and make sure the C of A meets the description in the Spec. Now look at a small sample of the ingredient. Does it match the description on the Spec? See the example below.


3 – Small companies (us included) have neither a chemist nor the equipment in-house to test the product. If you compared the physical characteristics and they all passed, then you can trust the chemical characteristics EXCEPT: you should have a program that specifies that you send samples to a testing lab on some schedule.


Every other month we sent samples of at least 3 of our oils and other ingredients out for various types of tests. Since we sell oil, we like to know what the Peroxide Value is. This tells us if the oil is “stable” and not going rancid. We usually test the peroxide value and compare it to the Specification to assess the quality.


Sometimes we’ll send samples of our ingredients out to test for bacteria, yeast and mold. Although – oils do not support microbial growth so we’ve never had a positive.


You don’t need a full lab to assess quality. You need eyes, nose and commons sense and a written procedure to randomly test your ingredient quality at a reliable analytical lab.


If you need help finding a lab, let us know. We may be able to refer you to one near you. If these documents are still a mystery, come take a class. See the classes listed in this site: http://ohohorganic.com/class-description/


For more information about why this issue is important, check out: https://www.beautyindependent.com/gay-timmons/


Plant a tree, start a compost pile, smell the glorious roses. Join www.nohba.org

Choose Your Cosmetic Claims Carefully

Is Your Product “Organic”, “Natural”, or “100% Anything”?

In a quick Google search there were at least 12 cosmetic companies involved in class action law suits over the past 9 months for using the word “natural” to describe a cosmetic or some aspect of a cosmetic. There are a number of others law suits based on other cosmetic claims. Are your cosmetic claims** verifiable and truthful?

We went down this path with the claim “organic” a number of years ago and now the class action suit attorneys have found a new piggy bank – small “natural” cosmetic companies. I’m so sorry.

As my mom used to say, “Being sorry doesn’t change it.”. It is time solve this problem.

When this issue comes up we often hear: there is no FDA definition of “natural”.

True – there is no legal FDA definition of natural or organic cosmetics. However, there is a way to publicly define the word “natural” for cosmetic companies. Below is a short history of the organic food industry; think of it as a model, a potential path to a solution.

A Possible Model:

The history of the USDA- NOP* seal and standard is a great model for how laws get written.

– 1970s: Multiple organic farm certifiers came into existence. They evolved to add food processors by the early 90s.

– 1990: The Organic Foods Production Act was passed in the Federal Legislature (Yeah Senator Leahy).

–  Mid-1990s – There were over 45 certifiers, each with their own private organic standard.

– 1990s: The Organic Trade Association created a harmonized version of these Standards that most of the largest certifiers signed on to.

– 1998: USDA-NOP came out with the first (reviled) version of the NOP regulation. It was amended after over 350,000 Americans wrote in to the USDA. The final regulation was passed in 2001.

– 2002: The Final Rule was implemented and the NOP Food Standard became law!

Contained in the very brief review above is the fact that a large industry had to work together over a 30-year period to 1) establish a recognizable market place for “organic” food and then 2) come to sufficient consensus about what “organic” meant so that the government felt justified in creating a law and then the regulations to implement the law. Please note: we do not need to create a law about “natural”.

What Can We Do?

We, as the “organic and natural” cosmetic industry need to carve out definitions for these words and we need to work together to establish consensus. Got that? We’ll need to agree to abide by the definitions we settle on. Consumers deserve consistency and the attorneys can go jump in a lake.

We can use private standards and we can work in a Trade Association to show a united face to consumers and to the government.

For now, educate yourself. I encourage anyone using organic and/or natural claims to become familiar with the Calif. Organic Products Act language on cosmetics, look at the COSMOS and NSF 305 Standards and, even if you don’t want to become certified, use them as a guideline. Then join the Natural and Organic Health and Beauty Alliance and work on “best practices” with us for using these terms.

We need to do this together. That means public conversations, people working on committees and patience. Lots of patience.

*NOP – National Organic Program

** This is a link to an FDA article on cosmetic claims**.

Graphic Logo for Oh Oh Organic

Non-GMO & RSPO vs. Organic Label Claims

We receive weekly requests for “Non-GMO” verification or “RSPO” (Sustainable Palm) certification. I continue to have to explain why “organic” certification is a more rigorous and legally accountable regulation and that our organic certificate includes both “Non-GMO” and “Sustainable” claims. Here are some details.


How the Organic Regulations Work:

Certified Organic products must meet the requirements of laws*.

These laws were proposed, revised, and fought over for 12 years and, I believe, are pretty good at protecting the environment and consumers. You buy a product that has been inspected annually (as required by law), the soil, water and air impacted by the farming portion of the supply chain is improved (as required by law), and the label on the package is approved by an accredited certifier (as required by law) protecting the consumer. If someone commits fraud they can be hauled into court and fined or jailed (it’s happened!). Additionally, in the State of California, organic operations are subject to spot inspection and testing including additional GM testing.

In the US, Canada, and the EU, these the organic regulations are almost identical and they have legal reciprocity: if it is certified to Canadian or EU Organic Regulations in Canada or an EU Country it is allowed to be sold in the US as “Organic” and the same goes for American goods sold in Canada or the EU.


How Non-GMO and the RSPO Labels Work:

The Standards that these two projects use are PRIVATE – a non-profit owns and implements the Standard. The Non-GMO Project, for example, has applicants fill out paperwork and, for the most part, asks them to “tell the truth” – whether they know it is true or not is a different question. They only do on-site inspections if they feel there is cause (for example if it is an ingredient made from soy or corn) so the level of scrutiny is fairly low. Many applicants use Non-GMO certification because it s easier to get than the “Organic”. “Non-GMO” does not exclude pesticides, synthetic fertilizers or synthetic food additives – it ONLY excludes GMO produced inputs .

The Non-GMO Project is a great idea in principle but, not so great in practice – they are so busy that they rarely answer the phone. Unlike the USDA-NOP, there is no transparency, no over-sight and. . .they certify things that could never, ever be from GMO crops (like water or hydrogen peroxide. Really, when was the last time you saw that hydrogen peroxide farm?). In my humble opinion, certifying “Non-GMO Water’ falls into the category of consumer deception: there is no such thing as GM water – genetic engineering happens with plant crops and some micro-organisms.

As to the RSPO palm folks – they are trying to say they are sustainable without becoming organic. Many of them are swapping carbon credit type values in order to claim that they are sustainable. Again, somewhat deceptive and neither clear nor transparent with consumers.

The only way you get guaranteed transparent information about how agricultural products are grown and processed is from certified organic producers.


Bottom Line:

Organic laws hold people and corporations accountable and there are fines and jail time for violators. There really are people who’ve gone to jail in the US for violating the laws under the USDA National Organic Program.

If, however, you are “certified” to the Non-GMO project or the RSPO Standard for Sustainable Palm, there is little accountability for either the Certifier or the Applicant using the label claim.

Laws governing organic prohibit the use of GM sourced inputs and define sustainability in law and require one to “improve” ones environment as part of ones “organic management plan”. Then they require you to prove that you are meeting the regulations by the way the “plan” is implemented.

Why would anyone value a Non-GMO or RSPO Cert above an Organic Certificate? Probably because they really don’t want you to look too closely at their products. Organic certification is your only assurance of enforceable environmental management and safer farming and production techniques.

If you have any questions about anything I’ve said here, please write or call. I feel passionately that consumers and the planet need regulated protection – greed, sadly, has too strong of a pull on some people and we need the force of law to protect us all. Buy organic!


* CFR 7, Part 205 based on the Organic Food Protection Act of 1990 plus the California Organic Products Act of 2003.