Definitions & Terms Industry Standards

What is “Natural”?

In my initial meetings with my clients I will ask them routinely to describe the product that they would like to design. Oftentimes they will state “I want it to be Natural.” I will then counter with “What is Natural?” At this point I generally get the answer “Natural, you know, natural.”

This really reinforces the dangers of using “Natural” and “Organic” as undefined terms. At this point they become marketing terms and of very little real scientific value. Under the FDC Act which regulates Cosmetics there is no legislated definition of “Natural” or “Organic.”

Organic and Natural Cosmetics are a hot topic in the Cosmetics Market. According to market researcher Freedonia, the Cosmetic Market in the United States is expected to rise by an average of 4.9{2f217b6ef4e944ec449aa2c625e1f0e1f43c0ee840d0a16b8bf46c3ef1173473} per year up to a total projected level of $9.4 Billion Dollars in 2016. Natural and Organic products are some of the fastest growing segments. These products also appeal to the Cosmetic entrepreneur as they can be easily sold through local markets as well as Wholesalers such as Whole Foods.

small-organicOrganic Cosmetics are defined and regulated under the USDA National Organic Program (NOP) While this is generally a standard for foods, it also applies to Cosmetics. If a cosmetic, body care product, or personal care product contains or is made up of agricultural ingredients, and can meet the USDA/NOP organic production, handling, processing and labeling standards, it may be eligible to be certified under the NOP regulations. Under this program a product must contain at least 95 percent organically produced ingredients (excluding water and salt) to be labeled Organic and to use the USDA Seal. Products containing at least 70{2f217b6ef4e944ec449aa2c625e1f0e1f43c0ee840d0a16b8bf46c3ef1173473} Organic materials may be labeled “Of Organic Origin” but the seal may not be used.

The one and only way (at this time) for a body care or cosmetic product to be certified and more important, regulated, as USDA certified organic is if the product contains or is made up of mostly agricultural ingredients, and can meet the USDA/NOP organic production, handling, processing and labeling standards.

Unfortunately we have a great deal less guidance in regards to the term “Natural.” Our greatest concern MUST be in learning the basics of the numerous Natural standards and to accept and follow one that is viable in your Market. Here in the US we are starting to see a shift to the National Sanitation Foundation (NSF) Standard (

Why should we endorse and follow a standard? Simply this will give you clear outside guidance to what you may consider “natural” and can assist you in developing your product. Without this standard there can be a wide variation in what is considered Natural. I have seen lines take a mainstream product such as a sulfate based shampoo, add a smattering of Botanicals, redesign the packaging to appear more “green” and then market this as a “natural” product. Conversely I have worked with small Formulators who presented with such “chemophobia” that they have severely limited the performance of their product. With a set standard we can get everyone on the same footing and produce more transparent products for our clients.

Under the NSF standard the product must contain at least 70{2f217b6ef4e944ec449aa2c625e1f0e1f43c0ee840d0a16b8bf46c3ef1173473} “Organic” materials. An “Organic” material must have a “Certificate of Organic Origin” and this certificate must be registered with the USDA NOP. This is important since I have seen several certificates filed internally with the companies Quality Assurance Department and not centrally registered.

Does complying with the ingredient requirements make a product “Natural” on its own? No. While complying with the materials will ensure a product complies, your manufacturer must be certified as well. The USDA and NSF grant Certification to manufacturers once they have policies in place and after a site visit is completed. The policies will entail writing and enforcing an “Organic Material Handling Program.” This program sets up procedures that ensure that the Organic materials will not be intermingled or adulterated in the receipt, storage, manufacturing and packaging of the materials and finished products. Once a Manufacturer has achieved this certification they may state that they are a “Certified Organic Handler.”

It is very important to remember that the FDA does not regulate these terms and essentially we must self police our Industry. Because of this lack of clarity in the laws and regulations surrounding organic body care, cosmetics and personal care products, a less than reputable manufacturer can create a body care product, label it as “organic” and there’s no one around to regulate if that product is actually organic or not. To an individual who creates a line of organic body care products, this may sound like an opportunity. You can market your product as natural, true or not, and few people will try to stop you. You don’t have to get officially certified, you don’t need to keep organic records – all in all, it’s pretty darn easy to manufacture body care products as falsely “natural.”

Why then even try to comply with the standards and not just keep natural as Marketing?
• It is extremely unethical. Hijacking and abusing this term does not do anything to advance the Natural Market.
• You can be called to terms by other lines and consumers for the discrepancies in your ingredient selections. Consumers are becoming increasingly more sophisticated in these standards.
• While the FDA does not identify these terms many retailers have begun to address this issue through their own stringent standards. Failing to comply can lock you out of these lucrative markets.

Remember, there is no shame in making a well performing product that delivers strong claims and performance to the consumer YET is not natural. Not everything can or should be created under a natural standard.

In summary, the Natural Market in the US is at a critical juncture. The demand for Natural products has and will continue to skyrocket. We are operating under very immature standards which leave a great deal of room to abuse these terms. When I began working with Natural products in 2007 the clients were very forgiving. A “Natural” product could cost much more and fall short in regards to performance when compared to a mainstream (“synthetic”) product as long as it avoided certain “bad” materials. As the market has evolved and material suppliers have stepped up to offer more “raw materials” for these products the gaps in price and performance have significantly narrowed. Today’s consumer knows the standards and is more informed (not always correctly) on the materials in these products. They will not accept “greenwashing” (building natural value through marketing only). They are now much more demanding and a product must more closely match a mainstream in price and performance.

The general consensus of the future of this market is that Performance has and will continue to become more important. Address the natural standards and comply BUT your product must work. That will be the real challenge for our market in the upcoming future.

~ Written by Mark Fuller

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