Leslie's Spa Development Articles

5 Degrees to Organic

By Leslie Lyon and Marilyn Patterson

Non-edited version. See published articles in Skin Inc. Magazine, titled Deciphering Organic, Part I & II. Part I February 2010 is available here; Part II March 2010 is available here.

Plastic reusable water bottles were the best thing since sliced bread until Bisphenol A; a chemical used to manufacture plastics, was found to be contaminating the bottled water, and landfill sites started to overflow with non-degradable plastics. The word "chemical" has become a bad word, but the worry here really became about carcinogens. The exposure to contaminants that cause adverse affects to human health and the environment are what's driving the massive organic movement that is currently underway.

We want a healthy environment, rather than one we need to protect ourselves from, and it is believed that a product with the words "natural" or "organic" is the best choice. So, companies use these words as powerful, persuasive marketing tools to help sell their products. Until now, this has been made possible due to the lack of guidelines and enforcements; but things are changing.

In North America, the governments have defined the term "organic", as plant material that has been grown and harvested according to strict agricultural standards. The word organic on a cosmetic or skin care label implies a certain level of organic plant content is present in that product. The word "natural" however, has no strict definition, so is widely used and mis-used in many industries, including the cosmetic and skin care industries. Herein lays the problem: Naturals are the essential "support system" to organics; they include emulsifiers; thickeners and carriers that hold the organic ingredients together and allow the product to aid and protect the skin. But if the "support system" can contain contaminants due to the lack of guidelines, how can a product achieve true organic status? As we become more attuned to the facts, a tremendous pressure is placed on ingredient manufacturers and skin care formulators, as this status is very difficult, and expensive, to achieve.

So the big question is "Does the Spa Professional truly get what they want and expect when they purchase a skin care line which has been marketed as natural or organic?"

Leslie Lyon has interviewed Marilyn Patterson, a Cosmetic Chemist and Consultant for the development of natural and organic cosmetics, with the intent to help educate Spa Professionals on the authenticity, safety and effectiveness of natural and organic ingredients, in order to better understand this complicated hot topic.

Leslie: Many products make claims that they are "green"; "natural"; "organic", etc., but who looks out for the spa professional as they attempt to make safe choices?

Marilyn: In North America, the cosmetic industry is self-regulating, with guidelines provided by the governments. If a product has complaints against it, then the government will intervene; look into the complaints; and only then will an unsafe product be removed from the market. Cosmetics and skin care products are under the category of "buyer-beware". Like food, the consumer must learn what is good for them and make their own choices; in the price range they are willing or able to budget.

Organic is the only one of these three words that is government regulated. There are many cosmetic and skin care lines with "organic" in the product, or in the company name on the label, but this is misleading to the consumer. A lawsuit has been filed by Dr. Bronner's Magic Soaps against many companies that are currently using the word organic as a marketing strategy. But the lawsuit has been taken one step further to try and eliminate any competition, by also suing the two (2) Certifying bodies involved: OASIS and Ecocert. These two organizations do not agree with Dr. Bronner and the USDA's strict definition for Organic, when applied to cosmetics and skin care, rather than food.

SAN FRANCISCO, CA - After hearing oral arguments earlier this month, the San Francisco County Superior Court ruled on Thursday, October 8 that Dr. Bronner's Magic Soaps can proceed with its lawsuit seeking to compel "organic cheater" companies and certifiers to drop, or stop certifying, deceptive organic label and brand claims. Culprit brands include Avalon "Organics", Jason "Pure, Natural & Organic", Nature's Gate "Organics", Kiss My Face "Obsessively Organic", Giovanni "Organic Cosmetics", Head "Organics", Desert Essence "Organics" and Stella McCartney's CARE "100% Organic". The culprit certifiers are OASIS and Ecocert. Estee Lauder is also a defendant due to its expressed intent to enter the market under its Aveda brand with misleading OASIS-certified "organic" products. The 800,000-supporter-strong Organic Consumers Association (OCA) has played a leading role in exposing and educating consumers about deceptive organic branding, and the organization is a party in the litigation with Ecocert.

Leslie: How do you define green?

Marilyn: There is no global definition for green, although it is assumed that a green product will be biodegradable and made with environmentally- friendly methods. The Canadian government started a certification body in 1988 called Ecolabel (www.ecologo.org ) to define green, although "Green" has become a much broader concept in the minds of spa professionals and their clients.

Leslie: What is green washing?

Marilyn: Using green words such as organic, natural, vitamin or botanical, when they are present in concentrations too low to have any effect, is a form of green washing. Another form of green washing is when the green ingredients are used with unacceptable ingredients, which may have negative health or environmental side effects.

Leslie: What are Green Lists and Black Lists?

Marilyn: Each Organic/ Natural certifying organization has its own green or positive list of allowed ingredients. They are difficult to access, but you can find out more about Green List (positive) and Black List (negative) cosmetic ingredients at www.saffronrouge.com.

It is a tedious process to go through the ingredient listing on the cosmetic product label and compare to the ingredients on the green and black lists, but this is the only way to ensure that the products you are interested in, are truly natural, if they do not have a reputable certification logo. The other option would be to hire a consultant to help you through this process.

Leslie: Can an ingredient be referred to by more than one name and therefore "fool" us?

Marilyn: There is only one INCI (International Nomenclature of Cosmetic Ingredients) name assigned by the CTFA (Cosmetics, Toiletries and Fragrance Association) for a cosmetic ingredient which can be used on a product label, but not all companies follow the labelling regulations. In the USA, the regulation control is very lax compared to Europe, where mislabelled cosmetics are frequently fined. You will see a number of companies put the source of the ingredient in brackets after the INCI name. This is misleading and often inaccurate. An example would be 'sodium laureth sulfosuccinate (coconut)'. This is also improper INCI labelling.

Leslie: Are there laws when it comes to labels on a product?

Marilyn: The FDA in the USA and Health Canada in Canada do have strict labelling requirements concerning claims, ingredient labelling, letter size, etc., but the policing of these are minimal.

Leslie: What's all the fuss about parabens - what are they and why so taboo?

Marilyn: Parabens are a group of synthetic molecules which act as preservatives in cosmetic and skin care products. They have been grouped together by the media, but each one has different properties regarding solubility and shape/ binding properties. Some forms can exist in nature, for example: blueberries contain natural parabens. Parabens hit the news when a study was released which found parabens in breast tumour tissue. The extrapolation was made that the parabens must have migrated into breast tissue from the use of underarm deodorant/antiperspirants and that they had a causal effect on the tumour formation. The study was small and not definitive so there has been much controversy over this. Some parabens are very weakly binding to estrogen binding sites in tissue. The worry is that they will exert an effect on breast tumour cells or any other estrogen sensitive tissue, to increase tumour growth. It could be that in the future, there will be a scientific basis for this health scare. The data is not clear at the present time.

Much of the marketing of natural products is based on what they do not contain. "No Parabens" is one of the ways to differentiate a product from another. People have recognized that preservatives, fragrance and colour ingredients have the highest allergenicity, so marketing people target these types of ingredients.

Natural or organic products would not use parabens, because they are synthesized from non-renewable petroleum sources. Leslie: What is biodynamic farming, and what is the difference between that and organic farming?

Marilyn: Organic farming is concerned with the chemicals which are used to help grow crops, prepare fields and control pests. Only natural and environmentally safe chemicals can be used, and composted material plays a large factor in the preparation of the field. Biodynamic agriculture considers the farm to be a self-contained entity. There is a strong correlation between the crops, livestock, careful maintenance of the soil and recycling of nutrients in order to maintain an ongoing, pristine quality compost; astronomical sowing and planting calendar (phase of the moon); and the health and well being of all involved.

Leslie: How do you decide if an ingredient can be used in a natural or organic skin care product?

Marilyn: The guidelines for accreditation of ingredients for natural and/or organic cosmetic products or skin care lines are similar for all certifying bodies, with some variation on the percentage of organic content and allowed preservatives. To be used in a natural/organic cosmetic or skin care product, an ingredient must comply with the following:

1. Renewable. Most plant material is renewable. Plants grown organically are preferred for environmental and safety reasons. Minerals may also be acceptable if they do not contain harmful contaminants, such as heavy metals. Natural minerals do not break down and are not changed so are not really consumed, but go back to earth eventually. Petroleum, although natural, is usually changed in form when it is used in manufacturing, and it is not renewable. As well, animal products are allowed if no harm is done to the animal. There are some exceptions such as carmine (red colorant) which is crushed insects and chitin/chitosan from shrimp shells.

2. Safety. Safety testing is currently done on animals but there is a move to find more humane testing methods using cell cultures. A botanical oil or extract often has a long history of use, so is deemed safe. If there is a chance of harmful impurities being present in an ingredient, then the ingredient is not allowed;

3. NO Synthetics. Most synthetic ingredients use petroleum based starting molecules;

4. Biodegradability. Silicones do not biodegrade, so are not allowed. There are many surfactants and preservatives which are not allowed, as they do not biodegrade quickly and are harmful to aquatic species;

5. Processing. Many of the guidelines deal with harmful impurities that could be present. A botanical oil which has been extracted with a petroleum solvent such as hexane is not allowed because some hexane could remain in the oil, while the same botanical oil which is cold pressed is allowed. An example would be extra virgin olive oil which is always cold pressed, as opposed to a cheaper grade of olive oil which would probably have been solvent extracted. Many ingredients that start out with plant material are still not allowed because the process that they undergo creates toxic or carcinogenic side products, or the ingredient that it is reacted with is toxic or carcinogenic and will remain as a contaminant in the ingredient. The governments do regulate the amount of toxic or carcinogenic impurities that are allowed to remain in an ingredient, but we can never be sure if these levels are safe or if the manufacturer has stayed within these ranges.

5 Degrees to Organic

When deciding which Degree of Organic is suitable to you as a Spa Professional, you must first decide what your own organic "standards" look like. Do you buy organic food? As with food, you must determine which ingredients are important to be organic, and which you consider to be safe (enough) with, or without the organic certification. This is acquired knowledge, and the personal preference of each individual. We have created these 5 Degrees to Organic, which as they approach the 5th Degree, ingredients will begin to better meet established regulations; become more pure; and move from the designation of "natural/organic" to "certified organic". Understanding these degrees will help to better equip the Spa Professional as they make their natural/organic product choices:

Degree #1: Natural/organic ingredients used for marketing only

An ingredient that delivers efficacy is rarely inexpensive. Companies selling low to midrange priced cosmetics may prefer to spend their money on marketing, rather than expensive ingredients. Marketing claims must follow government guidelines, which differentiate between cosmetic and drug claims, but a lot of puffery is allowed. It is therefore difficult for the professional to know the truth in the advertising. A quick look at the ingredient list will give an educated professional an idea of where this product stands. If the natural or organic ingredient that is being marketed is near the bottom of the ingredient listing, then it may be that it is not being used at an efficacious level, and most of the ingredients will not follow the natural/organic ingredient guidelines as described above. No natural cosmetic product would have an ingredient that starts with PEG- or PPG-, or a word that ends in "eth" for example.

Marilyn: This first Degree should be avoided if you truly want a natural product.

Degree #2: Natural/organic ingredients used for efficacy in a non-natural base

There are many natural/organic ingredients that have proven efficacy and have been found to be safe by the FDA/Health Canada, but have been used in a product with other accompanying ingredients that do not fit the guidelines for natural/organic ingredients as given above. Often a botanical (plant based) active is chosen over a synthetic active, because the product can then be described as natural/organic in marketing claims. Because North America has no true definition for natural, a product with only a few natural or organic ingredients can be marketed as natural. The Spa Professional needs to evaluate the ingredients on the label before making a decision. The natural/organic ingredient will have a Latin botanical name and you would expect to see this name before the middle of the ingredient list. But at this degree, any other ingredient names will not fit the certifying bodies' definition for acceptable natural/organic ingredients. The marketing information that goes with these products will mention efficacy studies if they have them. If not, you cannot be sure of the effect of the botanical, or if it is even used in an efficacious concentration.

Marilyn: This second degree could be efficacious but has still not reached the true designation of "natural".

Degree #3: Natural/organic ingredients but the product is not certified

In North America, there is still some debate about what certification body is most credible. As a result, many companies are following the European guidelines for ingredient choices, but not going through the certification process. Ingredients must follow guidelines for safety and environmental protection that surpass the regular government guidelines. At Degree #3, all ingredients on the label should be on a green list and follow the guidelines for natural (supporting)/organic ingredients, as shown above.

Marilyn: The third degree is usually safe, but it can be difficult to assess which products fall into this category. Even if a botanical ingredient is used, it may have been extracted with a petroleum based (non renewable) solvent and the solvent will not be listed on the label. But it is in this third degree that you are most likely to find efficacious, natural products at a more reasonable price.

Degree #4: Certified Natural/Organic

This category is where the debate begins. Many certifying bodies are stating that the product is organic according to their regulations, but the percentage of organic botanicals required is below the 95% organic content which is the percentage demanded for organic food. I would suggest that they should be considered "natural" rather than "organic". If a product is certified natural/organic, it will have a logo which denotes this. Some of the world-wide logos are shown below (this list is not exhaustive). A certified natural/organic cosmetic or skin care line must use ingredients that follow the stricter rules for safety and environmental protection. The main difference between Degree #3 and Degree #4 is that a certified natural product must use certified organic botanicals when possible and non-organic botanicals must be 5% or less of the botanical content, to qualify at Degree #4. The problem with non-certified organic botanicals is that pesticides or other harmful impurities may be present because the plants may not have been grown organically. Many efficacious botanical actives are excluded because they are not certified organic and there are few organic actives available at this time. There is no way to tell if the botanical listed on the label has been grown without pesticides or herbicides unless the cosmetic has undergone a certification process.

In Europe, COSMOS www.cosmos-standard.org is the first European Harmonized Standard for Organic personal care products. Many countries in Europe have individually developed standards for natural/organic cosmetic products, and in an effort to standardize these regulations, 6 of the European Organic Personal Care regulatory bodies have formed COSMOS.

COSMOS requires 95% of agricultural ingredients to be organic; and 20% of total product by weight, including water, to be organic. It does allow a maximum of 5% synthetic content. But this organization is still under development and will not have products certified under it for another year or two. The 6 Founding Members still certify under their own logos and standards.

Marilyn: I have classified these certifying bodies as natural/organic rather than certified organic because the percentage of organic ingredients required is not as high as the food organic standard. Any ingredient that is allowed to be used by these certifying bodies, I define as natural unless the ingredient has been certified organic. It is possible to make an efficacious and elegant cosmetic product in this category but with the added expense of certification. This Degree is probably the best choice for a Spa Professional as the work of verifying natural ingredients has been done for you.

Degree #5: Certified Organic

In North America, this is the strictest certification of organic and until recently, only pertained to food. It is therefore under the Agriculture Department regulations in most countries. (The following list is not exhaustive):

1. In North America, the most recognizable logo will be the USDA Organic. It is the strictest of organic standards because it is really a food standard, requiring at least 95% organic content to use the logo. It disallows synthetic preservatives and most chemical processing of ingredients. www.ams.usda.gov There are 4 categories of organic under the USDA.

   1. "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;

   2. "Organic": Product must contain at least 95 percent organically produced ingredients (excluding water and salt). Remaining product ingredients must consist of non-agricultural substances that are approved on the National Organic Program List (NOP), or non-organically produced agricultural products, not commercially available in organic form, also on the NOP List. Products may display the USDA Organic Seal and must display the certifying agent's name and address;

   3. "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% organic ingredients (excluding water and salt) and only organic herbs may be labelled 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;

   4. 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.)

2. NSF is one of the first US organic standards to emerge after USDA for cosmetic manufacturers. NSF requires a minimum of 70% of all ingredients (excluding water) to be organic to use its "made with organic" claim. NSF allows a broader array of preservatives and chemical processes than USDA. www.nsf.org As this organization started certifying cosmetics in 2009, there will be few available products on the market under this certification, at this time.

3. OASIS, Organic and Sustainable Industry Standards, is an industry association formed to certify personal care products specifically, in order to separate cosmetic standards from food. Oasis requires 85% of all agricultural ingredients to be organic and allows a broader array of preservatives. www.oasisseal.org As this organization started in 2008; there are few cosmetic products currently on the market that have this certification. There are 2 levels: one is "Organic" with the OASIS Seal/Logo; and one is "Made with Organic", which requires 70% organic ingredient content and does not have the Logo on the bottle. OASIS will be increasing the required organic content as the industry develops more organic ingredients.

Marilyn: The fifth degree of Organic will be the safest product to use, but the ingredient limitations make it difficult to formulate elegant and effective creams, or mild, pH friendly cleansers. Oil serums, balms (all oils and butters) including lip balms and hydrosol sprays will be the most common kinds of products with these logos.

The Spa Professional has many choices to make when deciding on a product line. Because cosmetic product/ingredient certification and regulations are un-unified, it can become more confusing, the deeper you delve into it. But as a decision-maker, it will help if you consider these points carefully:

1. The ingredient listing on labels is very important. Familiarize yourself with all of the details and accompanying claims;

2. Seek out the designated "ingredient expert" at the cosmetic companies you are researching, in order to compare your findings, and learn even more;

3. Confirm there is a valid certification logo when the word organic is used to describe the product;

4. If a product has a logo, find out about the certifying body that uses that logo and make sure it agrees with your own philosophy, and that it is indeed from a reputable source. Many companies create their own logos which have no certification body behind it;

5. Look for valid proof of a product's promise of efficacy.

For the Spa professional to give their clients the natural/organic/green cosmetic products that are being demanded, they must ensure that the products have undergone a thorough evaluation in order to be certain that the products will truly meet the needs of the client. If there is a valid certification logo, the rest of the promotion and advertising budget can be devoted to a product's unique features.  In the very near future, you may need to explain to your client why one product line without certification, is better than one with certification, and your credibility will depend on this.