by Derio Comar. BSc
The word "organic" is a widely used and abused label claim for foods and agricultural produce. In recent years it has become an increasingly common label claim on cosmetics. To some consumers the word organic conjures up a mystical purity associated with these products. However, few consumers understand the significance of the claim and the degree of marketing manipulation that occurs with the use of such terms. It is an emotive word and thus its marketing power has been fought over by commercial interests attempting to regulate its use. Organic means different things to different people and in its more traditional meanings indicates being of animal and vegetable origin, while in a scientific sense, organic refers to the chemistry of carbon and its molecules which constitutes all living matter, animal and vegetable. Organic chemistry is one of the major branches of chemistry which has contributed to our understanding of life, modern medicine and which effects almost every facet of our modern lives, from DNA technologies to plastic, paints and polymers. An additional and relatively new definition of the word "Organic" as it applies to food, has its origins in the concept of organic farming. That is, farming without the use of pesticides, herbicides and environmentally unacceptable chemicals and practices. In this sense "organic" by definition can only apply to agricultural products grown in accordance with these broadly based farming principles. To the average consumer this latter definition is likely to be their only understanding of the word. The use of the term organic to promote agricultural products has been extremely controversial over the last few decades and has been prone to considerable fraudulent activity. A variety of industry based and private organizations have evolved world wide which have introduced voluntary standards in an attempt to improve both the credibility of the industry and protect the organic farming industry from fraudulent activities. All "organic" standards and certification systems world wide have been spawned from the organic farming agricultural sector. Governments have generally remained out of this area and where involvement has occurred it has been as a consequence of industry pressure and the need to protect consumers from fraudulent claims. In some countries the labelling of agricultural products with the term "organic" is now regulated, despite the almost impossible task of policing or verifying the organic origin of a product. There are no laboratory based tests that can prove that a vegetable or fruit has been organically farmed. As one would expect it opens the door to any number of fraudulent scams. The food industry could only protect its credibility by developing accreditation systems whereby producers are inspected on a regular basis to ensure that their farming practices comply with the principles of organic farming. Thus the birth of the organic certification process for agricultural products. In the USA the USDA has introduced regulations and oversees the certification industry. However the certification of the farms and producers is almost exclusively undertaken by industry groups or private organizations. In Australia, as is the case in many countries, there are no regulations overseeing the labelling of agricultural products as organic. The Australian Quarantine and Inspection Service (AQIS) does require companies exporting agricultural products from Australia to undergo certification in accordance with their guidelines if they claim the product as being organic. The certification is undertaken by privately owned and controlled organizations. For the domestic market the system is not legislated and is totally voluntary. On both a global and a National level there are significant differences and discrepancies between the standards that the various organizations utilize for the purpose of certification. There is yet to be developed a harmonized standard not only at a national level but one that has broad international recognition. These organizations are privately owned businesses and compete vigorously for the business of potential clients needing to be certified. Furthermore in most countries these organizations have expanded their businesses to seek opportunities for certification outside of the traditional organic farming market. This has included cosmetics.
How do cosmetics fit into this model which had its beginnings in organic farming?
Organic claims associated with cosmetics is a totally marketing driven concept. Like all marketing driven concepts it has significant financial backing and is driven by the same organizations that certified organic foods. It has opened a new market for such organizations. It represents a new and lucrative market for this industry. Some organizations have linked the organic certification of cosmetics to that of the "Eco friendly" concept. None of this is Government driven and no regulations exist in respect of organic claims for cosmetics. The concept of "organic" cosmetics is not regulated in any country or market of significance. Despite this, the misconceptions in the market place and amongst consumers is alarming. These privately owned companies continue to call their cosmetic certification systems "standards". Whose standards? This new certification industry has had to adapt organic farming concepts and develop a range of additional criteria by which cosmetics could be certified. They have invented a completely new definition of "organic", which is significantly different to that of organic food. Unfortunately this "new organic" has not been widely explained to consumers who are still stuck on the food "organic". Furthermore the cosmetics organic certification is fraught with so many technical difficulties that there are differences between what each of these organizations deem to be an "organic" cosmetic. Consumers are totally oblivious to the machinations behind the scenes and the fierce competition between these organizations to dominate this market sector. The organic cosmetic certification "standards" have been a moving target for those seeking certification with consumers being none the wiser. Cosmetic ingredients unlike food ingredients do not all have their origin in agriculture or farming. If this was the case organic cosmetics would be edible like the food counterpart. A majority of cosmetic ingredients do not fit the organic model set by food.
Cosmetics contain a range of ingredients that are not of agricultural origin, the examples below being a very short list.
- Minerals (powders and colours)
- Kaolin
- Salt (including sea salts)
- Clays and muds
- Inorganic acids for pH adjustment
- Inorganic caustic for saponification (soap)
- Solvents and pigments
- Waxes and oils
- Water (the most significant ingredient)
Furthermore cosmetics need to be preserved for safety. A wide range of preservatives are used to prevent microbiological contamination. To this very day, there has been no satisfactory "organic" preservative developed that even closely complies with the concept of organic farming. Most consumers would expect that organic food should not contain preservatives. This however is not possible for cosmetics. Current preservatives do not have an "organic" origin.
The organizations attempting to offer certification services to the cosmetic industry have consistently been unable to agree on a unified approach to these issues. The standards that apply are significantly distant from the concept of organic food. This includes a list of allowable preservatives (based on whose judgement?), a list of allowable chemical processes, for example, the use of solvents. They have molded these standards to allow the practical manufacture of cosmetics. They have bent the food "organic" rules to suite the industry from which they are seeking to make a living. Thus allowing the industry to collectively dupe consumers with the "organic" claim. Governments have not intervened because there is no public health issue. In the USA the USDA which regulates organic foods has agreed to extend their standard to cosmetics. However they have no regulatory jurisdiction over cosmetics and thus this only extends to the use of the food USDA organic logo if the cosmetic meets their agricultural standard. To their credit, they have not altered the agricultural farming standard to try and fit cosmetics. Therefore if a cosmetic is made up exclusively of agricultural ingredients it can qualify as "organic", if the ingredients qualify as organic. In Europe on the other hand six of the major privately owned certification companies entered into an agreement to produce a unified standard for organic cosmetics under the banner of "Cosmos". This agreed standard is an attempt to remove all the discrepancies between the certification organizations and allow the cosmetic industry numerous products and processes that would not normally fall under the organic agricultural standards. As a unified standard it will also make it easier for the certification industry to subsequently seek Government support for legislation. The resulting standard is a farcical gimmick to allow cosmetics to become certified as organic, with minimal public or social merit. It allows products with as little as 20% organic content to be labelled organic. In the case of rinse off products at least 10% of the total product must be organic. Some ingredients are allowed simply because there are no "organic" equivalents available. Thus, rather than educate consumers in what is and what is not organic the consumer will be buying a product labelled organic with a predominantly non organic content determined by some totally artificial criteria. With intense marketing pressure what will "organic" mean in years to come. Maybe it is just too hard to tell consumers that zinc oxide sadly for consumers will never ever be "organic". Itâs "inorganic". There are numerous cosmetic ingredients that come from the agricultural sector. Such products can and should legitimately carry the label organic if they have been produced by organic farming principles. If a whole cosmetic is made up of such ingredients then it to should be capable of carrying the organic label. The trend to redefine organic is likely to undermine products that are of genuine agricultural origin and comply with the principles of organic farming. A cosmetic that uses some organic ingredients should not masquerade as being totally organic if it has a significant inorganic content just to satisfy a marketing need to manipulate consumers. Furthermore, the rules should not be altered to allow ingredients that are not of vegetable origin to be included and still call the whole product organic. Some of the new organic standards for cosmetics have bent the rules to a point where consumers are being sold a new "organic" definition without their knowledge. Most consumers would be horrified to read the list of permitted chemicals in these standards that can be incorporated into products labelled organic. For the more technically knowledgeable consumers the list of permitted chemical processes by which ingredients can be chemically modified makes fine reading. This is not to suggest that these permitted chemicals or processes are injurious to health or toxic, they are simply not organic. In one key standard chemicals with a petrochemical component are allowed in the absence of an organic equivalent and up until recently in another standard parabens were allowed to end up in a finished product via ingredients preserved with parabens. A devious way to add a non permitted preservative indirectly. Consumers have been none the wiser for many years while buying these organic labelled products. The meaning of organic with these certification standards is only truly understood by the organizations selling the certification and the companies wishing to promote their products with these labels. Unfortunately the consumer does not have the opportunity to read the fine print. The concept of organic has become commercialized and the term has been distorted for marketing reasons to fit the reality that cosmetics are not all made up of agricultural products. When consumer awareness of these standards becomes more widespread there will be a complete loss of confidence in this certification and like all marketing fads will pass on and fade in our memories.
Derio Comar has over 35 years experience as a microbiologist and industrial chemist. His work has been mostly involved with consumer products ranging foods to cosmetics, medicines and medical devices. A key scientific specialty is antimicrobial substances, antimicrobial processes, disinfectants, antiseptics etc. Derio Comar was the founder of Microtech Laboratories Pty Ltd which later became Silliker Microtech Pty Ltd. He was the CEO of this company and principal scientific consultant. The company operated the largest microbiological laboratories in Australia. The organisation now employs some 180 staff with laboratories in Melbourne, Sydney and Perth. Derio is now acting as a technical consultant and project manager. He has sat on various standards committees and industry organizations.
