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Why Some Products Can Never Be Organic–We’re looking at you, Water

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When it comes time to find organic ingredients and products, you’ll quickly see that there are a few things that are never (and won’t ever) be classified as organic. This can be frustrating when you’re trying to certify your product, but there’s no getting around the scientific reasons that prevent things from being classed as organic.  Science is science and no amount of wishing it were different will change that.  So for all those who want an organic shampoo — you’re pretty much out of luck.

That said, the USDA Certified Organic list of qualifying ingredients does allow certain non-organic ingredients–like water and salt, for instance–to constitute a large part of a certified organic formula. Same for the NSF 305 certification list.  However, the list of acceptable non-organic ingredients is relatively small.  To learn more about the difference between these two certifications, you can read more in our Organic Certification Choices – Which Is Best For Your Products blog.

To understand these rules let’s start with what organic means in a scientific context, in a cosmetic and agricultural context, and which items will never be considered organic.

The “Scientific” Meaning of Organic

In the most basic meaning, for something to be considered organic, it must contain a carbon atom. There are only very few classes of molecules that contain carbon that are not considered organic, but they are less common and we can ignore them for now (they include things like carbides and cyanides).

All known life that we have encountered uses carbon, which is why it is largely considered the building block of life. Thus we know that every plant-based product used in cosmetics must contain carbon, so in the strictly scientific case, they are organic material. To muddy the waters somewhat further, within the realm of organic chemistry you can have both organic natural and organic synthetic compounds—creating carbon-based compounds in the lab is considered organic synthetic.

Organic with the USDA & Cosmetics

So now we know what ‘organic’ means in the science world.  However, when it comes to agriculture and the plants used in cosmetics, the USDA (United States Department of Agriculture) limits the usage of the word organic to strictly naturally (in this case not synthetically) produced plants and compounds–no synthetic chemicals such as those found in pesticides, insecticides, or in food for livestock may be present. The term Organic really is derived from “Organically Grown” and was shortened to Organic.

For a plant to be considered organic by the USDA, several regulations must be followed. The land supporting the crops must not have had any synthetic or prohibited substances, no synthetic pesticides may be used, etc., in the past 3 years. (For more on the details please visit the USDA site here). The farmer/producer of the plant must be certified, any handler of the goods must be certified, and your manufacturer/filler must be certified by the USDA. Essential has this certification, but it’s because of these rules that you can only claim something is USDA Certified Organic and use the official seal if we create and then package and label your products in house. If you buy something from us that is certified organic but fill it off into smaller containers in your own non-certified facility, you may not claim it is certified organic.

The USDA does understand that ingredients such as water and salt cannot be organic (they have no carbon atoms and were never alive), and these are permitted in organic products. However, there are several ingredients that might catch you off guard and explain why you’ve never seen these few items labeled organic.

Examples of Inorganic Ingredients

We know that synthetic, lab-created ingredients are considered not organic (aka they are ‘conventional’) by the USDA, but let’s explore other ‘natural’ ingredients. As discussed water cannot be organic—it simply exists as two hydrogen and one oxygen molecules. There is no carbon and it has never been alive if it is simply pure water. The same goes for salt (composed of sodium and chloride atoms). But things like clay are also inorganic compounds. There is some evidence that microbes can affect the type of clay, but clay itself is primarily silicate rocks mixing with water. Life may well live within a clay, increasing the need for strong preservatives, and the USDA accepts some clays as organic, but often not. Kaolin, however, is typically permitted. All minerals are technically inorganic as well. For an extensive list of the exceptions, please visit this governmental website.

And let’s talk about shampoo and body wash.   We get a lot of requests for organic cleansers.  So we reached out to our compliance officer (who is also a certified cosmetic chemist) and here’s her response:

You can’t have an 100% organic soap since to make soap, you need to combine fats/oils with an alkali (lye) which would make it a synthetic detergent. Surfactants, used in shampoos and body washes primarily, are almost always synthetic and therefore disqualify the entire product for Organic Certification.   There are surfactant ingredients like quillaja and xylityl cocomate that can be organic but they don’t foam up like a surfactant cleanser.

If you’d like to delve into the world of surfactants, you can read about them on our Surfactants – More than Just Bubbles blog.

Lab-Made is OK!

We would like to take a second to note that although we value organic ingredients and products, we are also supporters of lab-created, nature-identical compounds and ingredients.  Everything, including water, is a chemical, so it’s about knowing what type of chemical something is rather than immediately understanding a lengthy or intimidating name.  As mentioned, water is a chemical and its chemical name is dihydrogen monoxide–it can certainly look daunting or scary but simply describes the molecular structure. And, too, it’s important to remember that lab-created is the only way to manage certain plant-based resources as populations continue to boom.

Scientists have long had the capacity to synthesize molecules that are identical to those found in plants, providing the same effects and benefits. We are happy using these on our own skin, and as the drive for sustainable beauty, not just natural beauty, takes hold there will likely be no choice but to embrace these nature-identical compounds.  Water shortages, climate change, overpopulation, over-harvesting — all are eating into the availability of plant-based resources. Ironically, this means that sometimes the most sustainable, safest ingredients are not those grown in dirt, but those made with the science of green chemistry.


In summary, we know that certain products are not organic in the scientific sense, and several others can never be considered organic by the USDA. It’s easier to see how a clay face mask, for example, shouldn’t be labeled organic. Knowledge like that may help you on your own quest to become certified and when formulating new products.

Whatever your goals for your own beauty line, we are here to help! It can be a bit of a wait to get your own labels and products USDA-certified, but we know how to do it and welcome guiding you through the process. Let us know how you value or incorporate organic products into your own line in the comments!

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Curtis Reser
2 years ago

Wow, very interesting . Enjoy reading your articles.

2 years ago

Thank you for this article! I learned a lot! I knew before that soaps could never be organic, but didn’t realize that applied to clay as well. What are the more safe ingredients to use to make products that bubble and foam? I’d like to add a bubble bath to my line, but would like to use the safest and non toxic ingredients possible.

2 years ago

Great public service posting this subject. Few comments from a bodycare formulator, water counts, when California suffered from low water supply the heavy metals found in the water supply infiltrated organic crops and lead to higher levels of thallium in some kale, etc. Salts are another issue as ford lake salts which is an alum (aluminum)
is used as a food coloring in most processed food and can act as a sodium in the body or in cosmetics can be absorbed thru skin.
Shampoo containing certified oils can be made with bubbles if the formulator takes the time to work the process. It took three years for me to achieve this without adding any misleading surfactants. It really comes down to taxing those companies who manufacture products containing harmful synthetic chemical for polluting the waters we drink from.