A task force of industry reps and consumer advocates will release the first draft of standards for organic personal care products by mid-2007, insiders say.

The standards, for voluntary adoption, would serve "companies that are interested in the proper labeling and identification of certified organic ingredients and organic personal care products" ranging from makeup to shampoos to toothpastes, according to Morris Shriftman, senior VP-marketing at Avalon Organics.

Considerations of how organic personal care products are manufactured, and which ingredients are permissible, also will be addressed, all in the interest of establishing a defined set of criteria for products aspiring to make an organic label claim.

Once issued, the draft standards will be subject to public comment and industry review.

Craig Minowa, an environmental scientist for the Organic Consumers Association (OCA), noted: "It will be the first completely written standard [of its kind] here within the U.S. that has been put together by a somewhat diverse group of organic experts and then opened up to public comment."

The task force - headed by the National Standards Foundation, an independent, not-for-profit organization accredited by the American National Standards Institute that develops standards for food, water, air and consumer goods - intends to submit the finalized standard to the federal government for possible adoption by a regulatory body.

The task force will meet next in March at the Natural Products Expo West in Anaheim, Calif.

Closing The Regulatory Gap

Currently, many organic personal care products fall into the gap between USDA's enforcement of organic standards for food and FDA's jurisdiction over personal care products.

"The USDA has to regulate [food products] all the way across the board but the USDA doesn't regulate personal care products - that's the realm of the FDA," Minowa observed.

In essence, personal care products that are labeled "organic" by the manufacturer but do not have USDA organic certification are largely free of scrutiny as to the validity of their claims. This situation has implications for consumers.

"Although there are dozens of personal care products on the market advertising themselves as 'organic,' unless they have the USDA Organic Seal, it's next to impossible for a consumer to tell which ones are really organic," OCA notes.

According to Shriftman, the proposed labeling standards for organic personal care products will be modeled after those established for food by USDA, so that products will fall into three categories - 100 percent organic, 95 percent organic, or "made with" organic ingredients.

Under a 2005 ruling, some products, such as lip balms, may already qualify to carry the USDA organic seal on their packaging if they meet the National Organic Program's (NOP) standards for food (¹ 'The Rose Sheet' Aug. 29, 2005, In Brief).

The ruling represented a reversal of a 2004 NOP guidance document excluding personal care products from the USDA organic program because they fall under the jurisdiction of FDA (² [A#02250190009], p. 8).

Other products cannot be certified 100 percent organic under food standards due to the presence of crucial synthetic components.

For example, no sunscreen can be labeled "organic" because active ingredients such as titanium dioxide and zinc oxide are synthetics.

The National Organic Program maintains a list of non-organic and synthetic ingredients permitted in food labeled 100 percent organic. The task force may draw up a similar list for synthetic ingredients in personal care products, Shriftman said.

The issue has created some contention within the task force around "what is the highest good."

From a purist perspective, the presence of synthetics in any concentration makes a product ineligible for the "100% organic" tag; others are prepared to forgive an inoffensive dose of synthetics.

"If you have the most stringent ingredient standards, you will have only a handful of products that are truly certifiable as organic, either at the 95 percent level or the 100 percent level," Shriftman said.

"Then you will have a lot of products that theoretically would fall into the 'made with' category. And that's okay, because it's a reflection of what is the current reality," he added.

Soliciting Consumer Input

To give the task force a better idea of how consumers interpret organic labels on personal care products, OCA posted a consumer survey on its Web site Jan. 16 after it was distributed to the organization's mailing list, Minowa said.

"We wanted to do this survey to have the public input prior to the draft standards being completely written up, because these types of standards are incredibly complicated," Minowa said.

"For the average person reading it, the standard is just a bunch of mumbo jumbo and it's really difficult to comment on."

The survey, generated by the task force, is designed to uncover consumer expectations related to organic certification and regulation and the presumed organic constitution of a product labeled as such.

Shriftman pointed out that people can be confused by products that bill themselves as organic but do not actually contain a majority of organic ingredients.

Simply Organic has suggested that its organic ties have more to do with a lifestyle being promoted than with the formulation of its hair-care products, which - in addition to organic ingredients - contain an amount of non-organic essential oils, preservatives and chelators (³ Also see "Simply Organic Rolls Out Hair-Care Line In The States, Educating As It Goes" - HBW Insight, 22 January, 2007., p. 10).

Given the liberal use of the term "organic" in the personal care marketplace, the survey asks questions like, "If you saw a food product labeled as 'Made with Organic Ingredients,' what portion of organic ingredients would you expect in that product?"

Survey respondents also are asked whether it is true or false (or uncertain to them) that all "organic" labeling of products in the U.S. is regulated by the government.

Additionally, "if a personal care company uses the word 'Organic' or 'Organics' in [its] company name ... how should the laws apply to [its] products?" the survey queries.

Other questions focus on organic purchasing and use habits.

Another probes for knowledge as to whether it is true or false that "some ingredients in personal care products can be absorbed into the bloodstream through the hair follicles and/or through the skin."

The survey results ideally will allow the task force to design standards that address any misconceptions consumers may have about organic products, Minowa explained.

In addition, the survey seeks to gauge the level of trust consumers put in the USDA certified organic seal versus products that are declared organic by an independent certification body.

The initial survey results have found that respondents believe products that undergo independent certification are "more organic" than ones with the USDA label, Minowa said.

He maintained, however, that the USDA is the "gold standard" of organic certification.

The Organic Trade Association began work on an organic personal care product standard in 2001 through its Personal Care Organic Standards Task Force (⁴ Also see "Organic Personal Care Standards To Be Developed By OTA/NSF" - HBW Insight, 23 August, 2004., p. 8).

It devolved responsibility for the effort to NSF/ANSI when the foundation acquired the organic certifying body Quality Assurance International.

Whole Foods Market, Avalon Organics and Dr. Bronner's Magic Soaps are among the companies on the task force.

OCA is the lone participating consumer organization, Minowa said. No representatives from FDA or USDA are involved.

- Molly Laas

Task Force To Release Standards For Organic Personal Care Products In 2007

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