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The Process of Going Organic

By: Darrin Duber-Smith
Posted: October 26, 2012, from the November 2012 issue of GCI Magazine.

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Additionally, much has been made of the fact that the USDA Organic certification is difficult to get, as the regulations were originally intended for food. Some ingredients that aren’t allowed in ingestible products but are commonly found in topical products continually frustrate beauty product developers and manufacturers seeking the USDA Organic certification.

The NSF program seeks to address these issues, although the “made with organic ingredients” claim isn’t as strong as an “organic” claim. However, as a vast majority of consumers don’t know the differences in the parameters for each certification, it’s possible the NSF program might eventually eclipse the USDA program in the next few years, depending on the increasing level of consumer knowledge and the importance consumers will or won’t continue to place on the purity and organic nature of a beauty product.

It also is necessary to clarify that under USDA guidelines, a product that contains 95% or more organic ingredients (excluding water and salt) can use the highly recognizable green-and-white USDA Organic seal on its label. The company can claim “100% organic” and “organic” respectively, depending upon the amount in question. A product made with more than 70% organic ingredients can claim to be “made with organic ingredients” and a product with less than 70% can simply asterisk each particular ingredient as “certified organic,” but that product can make no other claims about its organic nature.

And while this might sound nice and easy, there are still difficulties in translating food regulations to beauty products in order to meet the requirements for the USDA Organic certification. This has made the new NSF seal an attractive option for marketers, but overall, the major continuing problem is a lack of consumer awareness.

The Process

The actual steps to go about becoming certified can be translated fairly simply, as enumerated here.

  1. Hire a raw materials-sourcing consultant to review your formulas and source certified organic substitutes.
  2. Based on long-term availability and cost considerations, decide what percentage of your product will be organic.
  3. Look at replacing all synthetic ingredients in your formula with either organic or natural ingredients. The organic consumer doesn’t want synthetic ingredients in any form, and there are substitutes for all of them at this point.
  4. Look at all the available certifications, but for the U.S. market, you’ll likely decide between USDA and NSF. The USDA certification is a sought-after choice due to its awareness with regard to food products, but it may not be good for higher-volume beauty brands. The NSF certification is an option that may be a better move for larger companies that move more product volume.
  5. Ensure your labels and marketing claims are legal by consulting with an U.S. Food and Drug Administration (FDA)/USDA/Federal Trade Commission (FTC) attorney.
  6. Monitor the supply chain for ingredient availability. As larger companies switch to organic more and more, the supply chain will get squeezed. Make sure all of your certified organic ingredients have substitutes that are neither synthetically derived or synthetically processed (that is, “natural”) so these ingredients can be interchanged if necessary.
  7. Pay attention to how the certified organic nature of your product may change over time. Numerous companies have had to drop the USDA seal as the certified organic ingredient count dropped below 95%. This problem likely won’t occur with NSF as your formula would have to drop under 70% organic ingredients to necessitate removing the NSF seal.
  8. Commit to natural and organic. There is no room for synthetic ingredients when your brand is positioned as natural or organic.

Organic Opportunity