Creative Developments (Cosmetics) Limited

Organic Standards for Cosmetics: SPC 2002

John Woodruff

There was an interesting contrast for cosmetic manufacturers and formulators at two separate events in London during the same week in April 2002. Over a three-day period at the Excel centre more than 300 exhibitors competed to discuss the latest ingredients for cosmetic products. The focus was on scientific development and innovation, product efficacy and consumer safety. The majority of new materials were synthetic, or if derived from nature, they were chemically processed to yield the required end result. At Olympia an equivalent number of exhibitors were extolling the virtues of natural foods and health and beauty products at Natural Products Europe. It was at this event that the Soil Association chose to launch its Standards for Health and Beauty Products, which severely restricts the ingredients that can be used in such products if they are to gain the coveted Soil Association organic certification.

To understand the standards it is necessary to understand the aims of the Soil Association (SA). It is a registered charity founded in 1946 to research, develop and promote sustainable relationships between the soil, plants, animals, people and the biosphere in order to produce healthy food and other products with the minimum of harm to the environment. To date the Soil Association’s certification arm, SA Certification Ltd. has certified 2,700 farms and growers in the United Kingdom, 1,400 organic processors and 30,000 organic food products. The SA guarantees organic authenticity of foodstuffs by a process of complete traceability back to the farm, with each intervening stage being duly certified.

Concern that the increasing use of the term “organic” by cosmetic companies could result in a loss of consumer confidence in SA certification of foodstuffs led the association to set up a committee in Spring 1999 to produce standards for health and beauty products. Draft proposals were produced in November 2001 and the standards were launched in April 2002 at Olympia. The aim is to maintain consumer trust in the term organic as applied to foodstuffs by the SA, to extend this into other product areas to give the consumer the power to choose products that are better for the environment and to encourage organic production.

Compliance with the standards is not going to be easy. At the launch Pauline Hilli, scientific advisor to the committee, said that they were setting high standards that would be fair to large and small companies alike. That they would encourage “legal” organic products and would put pressure on formulators which in turn would create pressures on ingredient suppliers to provide certified organic materials. The standards would require commitment from those wishing to apply for certification; proper training of staff; complete traceability of all ingredients; environmentally sensitive manufacturing methods; constant auditing and new packaging designs.

There has to be a balance between the availability of raw materials and consumer demands and the SA accepts that for many product categories it is currently impossible to provide effective products based purely on organic ingredients. To overcome this there are two separate levels of certification. For the benefit of the calculation the water content is excluded. What remains must be at least 95% organic for the product to qualify for full organic certification. Alternatively if the balance is at least 70% organic the product may be labelled “made with xx% organic ingredients”.

Chemists have problems with the term organic; in the context of the Soil Association standards it means plants and animals that have been produced without the use of artificial fertilisers and insecticides, without artificial feed and growth hormones and which have not been genetically modified. It is the SA definition of the term that is used throughout this text. Ingredients for organic cosmetic products then fall into four categories; permitted; restricted; prohibited and uncertain. Permitted are materials from certified organic crops that have been obtained using appropriate extraction methods.

Permitted extraction methods include solvent extraction, provided the solvent is certified organic, CO₂ extraction and supercritical fluid extraction, most physical methods and hot and cold infusions. Materials of animal origin are permitted where the animals are from a certified organic farm and have been processed to SA standards to yield, for example, glycerine. Restricted extraction methods include the use of non-organically certified solvents and of ultrasound techniques. Prohibited is the use of petrochemical solvents, of propylene glycol and butylene glycol. Post extraction the material may be filtered and concentrated by evaporation, vacuum distillation or spray drying but pasteurisation is restricted and irradiation is prohibited. Permitted materials of non-organic origin include the use of mined clays such as kaolin, chalk, montmorillonite, sand and pumice where these are essential to the nature of the product but “fillers and binders” are restricted and talc is prohibited.

Ascorbic acid, tocopherol and other plant-derived antioxidants can be used and the permitted preservatives are sorbic and benzoic acids and their salts and benzyl alcohol. The use of phenoxyethanol, lactoperoxidase and phenylethyl alcohol is restricted to special circumstances. All other antimicrobial agents not listed above that are permitted by the Cosmetics Directive are prohibited by the SA. Citric acid and lactic acid may be used for pH adjustment and plant gums may be used as viscosity modifiers. Titanium dioxide and zinc oxide are permitted as UV filters and silicon dioxide and caprylic diglycerides are permitted as dispersing aids but alumina is not and chemically synthesised UV filters are prohibited.

It is permitted to saponify organic oils and fats with sodium or potassium hydroxide and to chemically process organic raw materials using petrochemical and synthetic reagents to produce functional ingredients but it is prohibited to use fatty chains of petrochemical origin. Examples of permitted surfactants include alkyl polyglycosides, alkyl glucosides, alkyl betaines and fatty acids and alcohols provided they are of vegetable or organic animal origin. Soaps and glyceryl esters are also permitted. Sulfonation, ethoxylation and propoxylation processes are prohibited and so are alkyl sulfates and cocamide DEA and MEA. This provides very little choice for preparing satisfactory shampoos, shower gels and bath foams and there is uncertainty over which other surfactants may or may not be used.

The criteria for the acceptability of surfactants are based on the Nordic Ecolabelling Scheme for personal care products with the addition of criteria based around the origins of the starting materials. Thus the source material is ideally organic but restricted use of non-organic material is possible where it can be shown that it is necessary. The recommended source material is organic plant derived, permitted is organic animal derived, restricted is non-organic plant derived and prohibited is non-organic animal derived.

This is a brief summary of a thought-provoking document. Those considering the formulation, manufacture or marketing of organic cosmetics are strongly advised to obtain a copy of the standards from the Soil Association.

Soil Association
40-56 Victoria Street, Bristol BS1 6BY

John Woodruff

16^th April 2002