Organic Cosmetics Labeling Requirements – Understanding the USDA Organic Label
Using “Organic” On your Product Label
You see just how popular “organic” products are as soon as you walk into any grocery store, big box store, local coop or salon, etc. Organic is everywhere and that’s a good thing. With the organic personal care market expected to grow to $15B annually by 2020, this is a hot market section; it’s good for skin and good for you – bottom line, but… Organic Certification isn’t as simple as it might appear!
Not all organic products are created equal. You’ll find that some cosmetic and skin care companies claim their products are organic even when those products have not been certified under programs such as the USDA National Organic Program under the organization of Oregon Tilth.
Label Options for USDA Certified Organic Products
The below information is from the US Department of Agriculture’s documentation on Organic Standards for personal care products. Any cosmetic, body care product, or personal care product that does not meet the production, handling, processing, labeling, and certification standards described below, may not state, imply, or convey in any way that the product is USDA-Certified Organic or meets the USDA Organic Standards.
- “100 percent organic”–Product must contain (excluding water and salt) only organically produced ingredients. Products may display the USDA Organic Seal and must display the certifying agent’s name and address.
- “Organic”–Product must contain at least 95 percent organically produced ingredients (excluding water and salt). Remaining product ingredients must consist of nonagricultural substances approved on the National List or non-organically produced agricultural products that are not commercially available in organic form, also on the National List. Products may display the USDA Organic Seal and must display the certifying agent’s name and address.
- “Made with organic ingredients”– Products contain at least 70 percent organic ingredients and product label can list up to three of the organic ingredients or “food” groups on the principal display panel. For example, body lotion made with at least 70 percent organic ingredients (excluding water and salt) and only organic herbs may be labeled either “body lotion made with organic lavender, rosemary, and chamomile,” or “body lotion made with organic herbs.” Products may not display the USDA Organic Seal and must display the certifying agent’s name and address.
- Less than 70 percent organic ingredients– -Products cannot use the term “organic” anywhere on the principal display panel. However, they may identify the specific ingredients that are USDA-certified as being organically produced on the ingredients statement on the information panel. Products may not display the USDA Organic Seal and may not display a certifying agent’s name and address. (Water and salt are also excluded here.)
NSF/ANSI 305: Personal Care Products Containing Organic Ingredients
In 2009, NSF, in conjunction with ANSI, created this standard specifically for personal care products. To become certified to this standard, products must undergo a thorough review by an independent organic certification organization, such as Oregon Tilth, to verify that a manufacturer’s product formulation contains at least 70 percent organic content by weight.
This program differs slightly from the USDA Certified Organic program. One such difference is that NSF/ANSI 305 allows for some limited chemical processing necessary to create personal care products. For example, soaps containing organic ingredients are permitted to undergo chemical processing known as saponification, without which these products could not lather. However, such processing would not normally be permitted under traditional organic regulations.
Essential Can Help you Get USDA Organic Certification
Essential has been a USDA Certified facility since 2009. We are certified by Oregon Tilth and our customers can work with us to obtain the USDA Certified Organic designation or the NSF “Contains Organic Ingredients” certification, also through Oregon Tilth.
The potentially confusing reality is that just because we are a certified facility, not all our products can be certified. Only those products whose ingredients are, or can be, certified to match the standards, may carry the seal or designation “organic.”
When you work with Essential’s Private Label group, you’ll have access to our compliance team to help navigate the process. We’ll work with you to help select ingredients that meet the standard, and will help you submit your label for approval from Oregon Tilth. Once you’ve passed that step, we can manufacture, fill and label your products.
Please let us know if you have any other questions or comments. We’re here to help!
Other Essential Blogs on USDA Certified Organic Skin Care
- Demystifying USDA Organic Certification Qualification
- USDA Certified Organic – Does it Matter?
- Essential Wholesale Labeling Guidelines
Resources Around the Web
- Natural Organic Program Fact Sheet – USDA
- Organic Labeling and Composition Guide
- Personal Care Product Organic Certification – Oregon Tilth
- Whole Foods Organic Body Care Standards
- Organic Certification – NSF