Every few years I realize anew that this organic cosmetic thing is a bit confusing. Many of you are being your lovely, creative selves and are unaware of the politics, laws, and philosophies that have evolved around using “organic” claims.
Let’s lay out the legal part with respect to “organic” cosmetic labeling:
You must be certified by a USDA Accredited Certifier if:
- If you sell a finished cosmetic product that is labeled as “USDA Organic” .
- If you sell wholesale ingredients (oil, sugar, whatever) in packages that you create labelled as “organic”, 100% organic”, USDA Organic, or “certified organic”.
If you make cosmetics and call them “organic”, you are under the authority of FDA and you need not be certified for those retail products to the USDA law. If you re-package organic ingredients and sell them you are under the regulatory authority of USDA.
You may want to look at the products you sell and your web site and make sure that a consumer could not be confused by the way you present the product. If you are referring to certified organic ingredients in a whole product, part of which is not from organic ingredients, make sure that is clear.
Make sure you have a a certificate(s) from the entity you purchased your ingredients from, than you can prove that those ingredients are organic and therefore that label claim is truthful.
Also – if you manufacture in the State of California and you call a cosmetic “organic” you are required by law to be registered with the Calif. Department of Health as an organic handler. Not terribly expensive so look into it.
So for the philosophy part of this blog, let’s talk about why labeling and the laws are important: integrity.
A label is a promise to a consumer. The word “organic” only has meaning (aka integrity) if 1) the label is truthful and 2) there is a direct link back to a certified ingredient source. The organic agricultural industry started because people wanted to validate that they were being good stewards of the earth. Oh – and they wanted clean, safe food for their bodies and for the planet. Then a bunch of us decide to evolve that whole organic thing into the cosmetic world.
I once had an experienced regulator tell me about labels: “you can state anything that is TRUE. Just make sure it is true. I’ve always added (in my head) that I’d need to be able to prove it to a judge – and this means documentation!
Keep the value in the word organic. Know the laws. Be a good steward of the word “organic”. Be true to your school (Okay – only people of a certain age will get that).
Hugs to all of you creative, inspired folks!
Indulging my love for period art…in this case, justice may be blind but judges are not.