Category Archives: “Natural” Cosmetics

“Natural” Documents – MiniBlog

Have you defined what NATURAL

means to you?

If you use the term “natural” to describe your ingredients or your finished products you may want to consider writing a definition of “natural” on your web site.

First, let’s make clear that a synthetic, in my world, means a human has made a new molecule.

What? New molecules? Well, oil, for example is naturally occurring in seeds and nuts and the molecules that make the oil is not changed when it is pressed out of the seeds. A simple example of a new molecule is soap: oil and lye are reacted. The mixture gets hot, a new molecule is formed and, violá, you have soap or Potassium Cocoate (made from Coconut Oil plus Lye – for example this is how they make Dr. Bronner’s soap).

I further categorize synthetics as good chemicals or bad chemicals. Good chemicals are made using a renewable resource plus using the Principles of Green Chemistry (see previous mini-blog for the reference to this paper). Bad chemicals are everything else and usually bad for the environment and most living creatures.

A “natural” ingredient is extracted from a plant using mechanical means like pressure, steam, or water extraction. This definition is published in the EPA regulations, although people seem to believe that “there is no legal definition of natural”. Wrong, it is in our existing laws.

Different companies define “natural” different ways – but you need to be clear. If you can verbalize a definition to your consumers, the courts are more likely to support you. Also – if you can’t explain it, how can you mean it?

For more on definitions, check our Definitions & Links page.

My Product is Certified Natural – Isn’t It “All Natural”?

The problem with “All Natural” or “100% Natural” claims

There is some confusion about the claim “All Natural” or “100% Natural” or even just “natural” by
companies that are certified to a “Natural” standard.

This is how it works: both the natural and the organic cosmetic standards allow the use of
synthetics (human made molecules), however they need to be made using plant based feed stocks and the Principles of Green Chemistry*. This means that people use ingredients that are “allowed” because they meet these rules but they are synthetic ingredients. They also use natural ingredients that are not synthesized like oils and waxes and plant extracts.

Example – the Principles of Green Chemistry allow hydrogenation as long as the molecules are fully saturated (not trans-fats). That means we are allowed to use vegetable waxes in COSMOS (formerly EcoCert) products if they meet the requirements of the standard. But they are still synthetic. Another example is plain old Castile Soap: coconut is reacted with potassium hydroxide to make “potassium cocoate”. Clearly a “chemical” even when “made from organic” ingredients.

In summary, companies claim “All Natural” because they are certified to a natural standard but
they clearly list synthetic ingredients on their ingredient list.  This is confusing to the consumer. It also means the Brands don’t really understand the standard they are using. Sometimes it means the Brand may be sued by mean attorneys who give nice attorneys a bad name and harass sweet brand owners. (Okay – I’m defensive.)

Synthetics are not “bad” if they are made from renewable inputs using safe methods and resulting in safe chemicals.

If you have been threatened by one of these suits and need a referral, let us know.

* The 12 Principles of Green Chemistry defined by: Anastas, P. T.; Warner, J. C. Green Chemistry: Theory and Practice, Oxford University Press: New York, 1998

Mislabeling: The FDA and the The No-No Words

A lot of cosmetic brands seem to have a “No-No List” of ingredients. I think it is time for a list of “No-No” words – because, you know, FDA and “mislabeling”.

The basic thing you need to keep in mind is that unless you are selling a registered, approved DRUG, you may not any use words that promise a medical outcome. That is considered mislabeling and mislabeling is against the law. So – here is a partial list of “No-No” words:

  •    HealMislabeling
  •    Healing
  •    Anti-inflammatory
  •    Anti-microbial
  •    Anti-bacterial
  •    Cures
  •    Penetrates to (heal, sooth, etc.)
  •    Stimulates circulation …
  •    Treats
  •    Alleviates eczema, rosacea, scarring, acne, etc
  •    Improves circulation
  •    Minimizes
  •    Improves the skin’s immunity
  •    Boosts collagen
  •    Protects from UV Rays (this = sunblock – and must be registered with the FDA)
  •    Protects against infection
  •    Cellular regeneration

Oh, I could go on. What these all have in common is what the FDA calls a “structure-function claim”.  Structure = a body part (skin, muscle) and Function = changing the physiology of that body part. These sorts of claims = DRUGS and are seen is mislabeling by the FDA. The USDA-FDA makes a lot of money approving drugs so if you have not sent them a couple 100,000 dollars, you are probably not selling a drug.

Look at your website – are you making structure-function claims? If so – use that wonderful, free thesaurus on Google and fix it before you get a scary letter from the FDA. You can “change the appearance of”, you can “sooth the symptoms of” you can do all sorts of things, but no structure function claims! You do not want a letter from FDA accusing you of mislabeling.

The organic and natural cosmetic industry needs to look good in the eyes of the law. We do not need big manufacturers telling the FDA that we should be heavily licensed or regulated. We need room to grow. Know the laws. Respect them. Do good work.

Hugs                   Resources:    Choose Your Words                          Link to FDA Article

 

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

Ingredient Transparency and Quality for Your Products?

 

Getting Transparent About Your Ingredients
Castor Oil – I think it is beautiful!

 

We only sell organic and sustainable ingredients. It seems pretty dumb to do anything else (hello Hurricane Harvey, Irma, and the gang) – agriculture adds about 50% of all un-sequestered carbon to the atmosphere. Organic agriculture helps solve that problem. We want you to have full transparency about the ingredients you receive from us.

Over the past 20 years we’ve developed a group of people who call to find ingredients. The job tends to be split between two major types of inquiries:

1 – Chemists who have no idea or concern about where an ingredient comes from but “a customer (Cosmetic Brand) wants xyz in their product. Do you have it?” and,

2 – Brand Owners who are serious about their brand and work with us because they know we care and that we will not sell them something just to sell it. We are not a web sales site, we are people who work with ingredient manufacturers so we can give our customers as much information as possible.

 

Examples of Ingredient Requests

Here are a few examples of requests I’ve recently received for you all to think about over this hot, holiday weekend.

#1 – Recently a chemist with a private label lab wanted to purchase organic bergamot oil from fruit – not from the peel.

We know most of the legitimate EO suppliers and we couldn’t find anyone that offered this EO.

This implies a few things:

a) the brand developer bought something from a web site and did not ask for a certificate that disclosed what the oil was made from or

b) they assumed that they could get an organic version commercially but…they originally used a non-organic version or

c) they found a good product but it is so rare that it is NOT consistently & sustainably available.

 

#2 – A customer told me they had purchased oil from a web site. The site operator would not supply his organic certificate because “he did not want anyone to know who his supplier was” – this means he was not certified to re-package and re-label (handle) organic products. The oil lost it’s organic claim when he changed the package and label. If you bought it and used an organic claim on your product you would be in violation of Federal Law.

 

#3 – A large and reputable company offered to sell me some organic sunflower oil – I always look at production dates. It was a year old. I refused to buy it because it was expired – they probably could have re-tested the product and extended the life for 6 months, which can work with food. People use food far faster than they use up cosmetics. We won’t do that.

The Bottom Line on Ingredient Knowledge

Working with a supplier who will help you understand the ingredients you are buying and the documents that explain the quality of the ingredients is so important. “Transparency” tells you where they come from, what they are made from, and how they are made.

Ingredient quality is always on our mind. We throw product out when we don’t have enough shelf life, we test our oils for freshness and double-check our suppliers because we care and we are always transparent.

 

Happy Labor Day! Stay cool, stay safe, get out of your car. and walk on the planet