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How do you validate ingredient claims?

How do you validate ingredient claims?

I once asked an FDA inspector what her basic rule was for ingredient claims and she said, “tell the truth”. That means, you need to know what the truth is.


Ask for certificates. If it is organic, you are required by law to be able to prove it with a certificate. If it is Non-GMO you should have a certificate from an EU Certifier or from the Non-GMO Project in the US. If it is Fair Trade or Fair for Life, you should have a certificate. Be aware – some certificates are generated by laws (the USDA-NOP for example) and some are private (COSMOS or NATRUE). Also, the standard is separate from the certifier: the USDA has 80 or so accredited certifiers. COSMOS has 5EcoCert is one of their certifiers, not the standard. We are certified by Oregon Tilth or “OTCO” as it says on our certificate.


Some things are not certified but people have policies. “Black Lists” may be part of a policy. There should also be a way to validate that the black list is enforced. A policy should be in a manual or written on someone’s web site. For example, we have a policy about testing the oils that are currently open and on the floor of our warehouse. It is in our Good Manufacturing Practices Manual. We send copies of it all the time!

Flow Charts

This shows how something is made – like an extract or a refined oil or a synthesized surfactant. There should be enough detail that you know how it is made. If you don’t know what all the words mean, never be afraid to ask questions.


Analytical tests show scientifically measured data – usually to match a specification. If our spec is that lavender oil should have between 40 and 44% linalool, we should have a document that shows it was measured to meet that level.

Composition Statements

This shows everything in an ingredient and should total 100%.

Common Sense

Sometimes I look at things and just wonder how the heck they made it work. Like a water-based material that has no preservative. Maybe it has a very low or high pH (self-preserving mostly) but I ask the supplier.

Most important rule: there are no dumb questions – there is stuff you know and stuff you don’t know and that is how the world works. ASK QUESTIONS!

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