Progress Or Backslide?

Two weeks ago the Advisory Board (the NOSB) to the USDA-NOP passed a “recommendation” that the Dept. of Agriculture should regulate organic claims on cosmetics. Currently, the FDA regulates cosmetics labels, not the USDA-NOP. Then a bunch of “natural” food stores sent out policies or letters telling their vendors that, if they make an organic claim on a personal care item, they needed to get certified to the NOP. Spare me.
There are thousands of small companies all over the US and Canada that make uncertified “organic” claims on personal care items. Most of them do not follow the NOSB. Even in OTA, an organization that one assumes attracts dedicated “organic” businesses, in a recent survey discovered that only 9% of their personal care members are certified to the USDA-NOP. Again: nine percent!!!!
Why?
Cosmetics depend on synthetic ingredients to function well. There are simply not enough of the functional ingredients necessary to make a personal care product that performs well, which assures repeat sales. This means that conventional synthetics must be used.
How did we get to a regulation for organic food? The effort included 40-plus private certifiers serving the “organic” community from the 1960s until 2002 which created the momentum and infra-structure necessary to arrive at and support USDA-NOP certified food. It takes time to create a market and all the parts of the market necessary to make it work. (A factoid: Whole Foods profited for 24 years on non-NOP “organic” claims.)
Organic food contains certified agricultural ingredients. In cosmetics the “organic” certification of potassium cocoate, mono and di glycerides, and sucrose palmate is certification of non-agricultural ingredients. Is it best for all “organic” stakeholders to include the certification of “synthetics” under the Dept. of Agriculture?
This is what I see: people want the “organic” label to mean the same on all product categories, but it doesn’t and it can’t. I don’t want certified organic synthetic ingredients in my food. I want organic food to stay pure. I also want certified organic personal care products, but I know they need to be made using synthesized ingredients, and I want those ingredients to be synthesized out of organic raw materials. I also know putting this in place will take years.
The FDA and the NOP, under ideal conditions, cannot “enforce” a law until they have a law. First they have to agree to do this type of enforcement (remember, cosmetic labels are not currently reviewed). Then they have to either amend the Organic Food Production Law or pass a new law. Then they have to write the standard. I’d guess this could take 5 to 8 years. The NOSB seems to imply that they want enforcement now. It simply cannot happen – what do we do in the meantime?
We do what they did with food: use private standards. This could support the NOSB recommendation to the NOP and help make organic certification of cosmetics a reality. To tell companies that they “have to” get certified to the NOP when there are no safe preservatives, no mild surfactants, and no non-slimy emulsifiers is literally throwing the baby out with the bath water. We will end up back in the 1980s with an array of “natural” products and a very few “organic” products. Why can’t the NOSB support private organic cosmetic standards for now? At least people could be certified to something!
The Organic Food Production Act of 1990 was written expressly to certify AGRICULTURAL products. Personal care items are not food, I don’t want to eat them; I want them to work to clean my hair, sooth my skin, and keep my children from getting sunburned. That will not happen using a food paradigm. I want a strategic plan to get us from where we are now to that ideal certified organic cosmetic. The fact is that a number of people have made NOP PC shampoos and lotions and they do not seem to sell well. I suspect this is why we don’t see these products in Whole Foods and other “natural” stores. If we can’t get repeat sales, we can’t “grow” organic agriculture. And why would a store carry something that does not sell?
Isn’t that what this is all about? Increasing the market for organic ingredients? It won’t happen just because of the NOP seal. It will only happen if the products are good enough to create repeat sales. Shampoo is not an apple or cookies. The production of an organic apple cleans up the planet but it pretty much tastes and looks like a conventional apple. “Organic” shampoo under the NOP dries out my hair and I can’t use the lotion due to the alcohol preservative. They are not comparable to the more functional conventional versions. Darn it, I want organic versions.
Get real folks – we have a lot of work to do and it is important to do it but let’s use our brains and apply history. The NOSB’s message is well intended but poorly executed. As leaders of the industry, they should be able to supply a timeline, and a plan that will take us from 91% non-certified to 100% of players certified. Their recommendation does not do that. It just further confuses things and seems to be encouraging the removal of some pretty nice “organic” products that are not certified from the shelves. This move by the NOSB and some of the “natural” stores is a shame and diminishes the use of organic ingredients. I think we are backsliding, not making progress. What do you think?
Gay Timmons

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