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Regulatory: Updates to Independent EU Cosmetic Directive

By: David C. Steinberg, Steinberg & Associates
Posted: July 7, 2009

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With the growth of nationwide food stores based on certified organic foods, interest in the organic market has spread to cosmetics and other personal care products. From this interest, several groups have emerged with varying standards for organic certification; most use a seal that appears on product labels to indicate organic certification. Following are some of the major bodies, as well as their requirements. This is not a comprehensive list but it will provide an overview.

National Organic Program (NOP, United States): Within this program are four levels of organic claims for foods. The NOP defines the claims that can be used for agricultural products by their content, excluding water and salt. 100% Organic: For this claim, 100% of the ingredients in the product must be certified organic products and in this case, the USDA Organic seal may be used.

  • Organic: To make this claim, 95% of the materials in the product must be certified organic products; the same USDA Organic seal may be used in this instance.
  • Made with organic ingredients: For this label claim, 70% to 94.99% of the product’s ingredients must be certified organic; in this case, use of the USDA Organic seal is not permitted.
  • Contains organic: This label claim requires less than 70% of certified organic ingredients in a product and also cannot bear the USDA Organic seal.

Natural Products Association (NPA, United States): This organization was founded in 1936 and was principally concerned with dietary supplements. The group represents more than 10,000 retailers, manufacturers, wholesalers and distributors of natural products, including foods, dietary supplements, and health and beauty aids. On May 1, 2008, the group issued its certification program for personal care products. In order to display the NPA seal, a product must meet the following requirements:

  • Contain at least 95% truly natural ingredients or ingredients that are derived from natural sources;
  • Contain no ingredients linked with potentially suspected human health risks;
  • Not be processed in ways that significantly or adversely alter the purity of its natural ingredients; Include ingredients derived from a purposeful, renewable/plentiful source found in nature (flora, fauna, mineral);
  • Be minimally processed and avoid the use of synthetic or harsh chemicals so as not to dilute the material’s purity; and
  • Should contain non-natural ingredients only where viable natural alternative ingredients are unavailable, and only when they pose absolutely no potentially suspected human health risks.

The Natural Products Association also has published8 a list including 839 ingredients that it considers meets these requirements.

Cosmetics Organic and Natural Standard (COSMOS, EU): As noted above, COSMOS is an independent effort in the EU, with its draft published in November 2008. This standard was developed from collaborations between working groups including: the Instituto per la Certificazione Etica e Ambientale (ICEA in Italy); the Federation of German Industries and Trading Firms for Pharmaceuticals, Health Care Goods, Dietary Supplements and Personal Hygiene products (BDIH in Germany); Bioforum in Belgium; the French Professional Association of the Ecological and Organic Cosmetics, and a French certification organization (Cosmebio/Ecocert in France); and an environmental charity promoting sustainable, organic farming and championing human health (The Soil Association in the UK). The COSMOS draft is available at