This page covers the following sections:
- Help and Guidance from ISO (International Organisation of Standardisation)
- Third-Party Verified Certification
The Cambridge English Dictionary definition of Natural is “as found in nature and not involving anything made or done by people”(1).
However, there is no legal definition for “Natural” as far as cosmetic products or cosmetic ingredients are concerned. Many cosmetic and personal care products are based on “natural” or “naturally derived” ingredients. The lack of an agreed definition for these terms means that there is the potential for consumer confusion regarding what is meant when the word natural is used in conjunction with cosmetic products.
Basic definitions are used in part of the EU REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation. Many naturally occurring substances were exempt from the need for registration under REACh, provided that the also did not have specific hazard classifications.
In the guidance document, on exemptions from registration, published by the European Chemicals Agency (ECHA) reference is made to REACH Article 3 paragraphs 39 and 40.
- substances which occur in nature: means a naturally occurring substance as such, unprocessed or processed only by manual, mechanical or gravitational means, by dissolution in water, by flotation, by extraction with water, by steam distillation or by heating solely to remove water, or which is extracted from air by any means;
- not chemically modified substance: means a substance whose chemical structure remains unchanged, even if it has undergone a chemical process or treatment, or a physical mineralogical transformation, for instance to remove impurities;(2)
The ECHA guidance document goes on to say that chemical modification includes, but is not limited to hydrogenation, neutralisation, oxidation, esterification and amidation(3).
Entry 9 of Annex V of REACh also exempts from registration under the REACh Regulation, several other substances, which would also be classified as natural, these being vegetable fats, vegetable oils, vegetable waxes; animal fats, animal oils, animal waxes; fatty acids from C6 to C24 and their potassium, sodium, calcium and magnesium salts; glycerol(2).
The guidance document reminds us that the exemption from registration of glycerol only applies to glycerol obtained from natural sources as previously described(3).
It is interesting that the basic definition used in REACh is quite similar to that used in the “Natural Cosmetics Act” in the US. In the US there was an attempt to put into law a number of definitions in the context of cosmetic products. The “Natural Cosmetics Act” was introduced in November 2019 but failed to receive a vote prior to the change in administration.
The Bill defined the term natural as:-
“Any chemical substance that is naturally occurring and which is (i) unprocessed; (ii) processed only be manual, mechanical, naturally derived solvent or gravitational means, by dissolution in water or steam, by flotation, or by heating solely to remove water; or (iii) extracted from air by any means(4).
The bill specifically said that the term natural does not include petroleum and petroleum-derived ingredients, and went on to define “naturally derived ingredients” as:
- (A) any substance where the starting material is of mineral, plant, microbe, or animal origin but has been chemically processed;
- (B) any substance where the starting material is of mineral, plant, microbe, or animal origin but has been chemically processed and combined with other ingredients, excluding petroleum and fossil fuel-derived ingredients; or
- (C) an ingredient that is derived from a plant feedstock and bio-manufactured using processes like fermentation, saponification, condensation, or esterification in order to improve performance or make the ingredient biodegradable or sustainable(4).
The proposed legislation went on to say that any cosmetic product that included the term “natural” on its packaging or labelling would be misbranded unless the cosmetic contained:
- at least 70% natural substances (excluding water and salt);
- no fragrance ingredients other than natural substances or naturally derived ingredients;
and, aside from natural substances and water
- contained only naturally derived ingredients, except to the extent that a naturally derived ingredient “is not available for a specific function” or “is otherwise not feasible.”
The proposed Bill also included labelling requirements if the term “natural” was to be used in connection with one or more ingredients and prohibited certain manufacturing processes(4).
Help and Guidance from ISO (International Organisation for Standardisation)
ISO 16128 is a two-part ISO standard published in 2016 and 2017. It provides guidelines on definitions and criteria for natural and organic cosmetic ingredients and products. The guidelines are specific to the cosmetics sector and take into account that most existing approaches, written for the agricultural and food sector, are not directly transferrable to cosmetics. The guidelines apply scientific judgment and offer principles towards a consistent logical framework for natural and organic cosmetic ingredients and products, incorporating common approaches employed in existing references. The purpose of the guidelines is to encourage a wider choice of natural and organic ingredients in the formulation of a diverse variety of cosmetic products to encourage innovation(5).
The first part, ISO 16128-1:2016, provides guidelines on definitions for natural and organic cosmetic ingredients. In addition to natural and organic ingredients, other ingredient categories which may be necessary for natural organic product development, are defined with associated restrictions(5).
The standard describes natural ingredients as generally being obtained from plants, animals, micro-organisms or minerals, and goes on to list a series of processes by which the ingredients might be obtained. This list includes physical processes, fermentation and extraction using solvents but without chemical modification. It also specifically says that ingredients obtained from fossil fuels are excluded from the definition(5).
ISO 16128-1:2016 also suggests a definition for “Derived Natural Ingredients”. It says that these are cosmetic ingredients of greater than 50% natural origin. The level of natural origin can be calculated in a number of ways, which are set out in the document. Additionally, ISO 16128-1:2016 provides definitions for “Organic Ingredients” and “Derived Organic Ingredients”(5).
ISO 16128-2:2017 describes approaches to calculate natural, natural origin and organic origin indexes that apply to the ingredient categories defined in ISO 16128-1:2016. It also offers a framework to determine the natural, natural origin, organic and organic origin content of products based on the ingredient characterisation(5).
ISO 16128 does not address product communication (claims and labelling), human safety, environmental safety and socio-economic considerations (e.g. Fair trade).
Also available from ISO is ISO 9235:2013. This comes from the work that has been conducted within the essential oils sector. It is aimed at defining the natural raw materials and products stemming from this sector but is not intended to integrate all the provisions of other sectors of activity which use the products defined within the standard(5).
It is important for the industry to remember that whilst the terms 'natural' and 'organic' are not specifically defined under the EU and UK Cosmetics Regulations, and certification in relation to these claims is not a legal requirement, any claim made by a cosmetic product is covered by legislation and the claim must be capable of substantiation and must not mislead or misinform the consumer. All claims must comply with the Common Criteria. Such claims should not imply that this type of product is safer than other cosmetics just because they are making 'natural' or 'organic' claims. There are no safety advantages to natural and/ or organic ingredients and to claim that there are may be misleading.
The ASA states on the CAP website:
“Claims that organic cosmetic products are inherently safer than non-organic products are likely to be problematic, as all cosmetic products are subject to the same safety regulations”More information about the common criteria is available in the CTPA guide Confidence in Cosmetic Claims.
The European Commission has also published a Technical Document on Cosmetic Claims as guidance to enforcement authorities in the Member States for the case-by-case application of the Common Criteria.
Third-Party Verified Certification
Consumers like to have confidence in the claims made by the manufacturers of the products that they use and therefore often look for these products to be third party verified. Several systems now exist to provide third party certification for natural or organic cosmetic products.
If companies are seeking organic certification of their finished product(s) by a commercial organisation, CTPA urges them to remember that such certification is optional, while compliance with the EU and UK Cosmetics Regulations is mandatory.
The COSMOS-standard (Cosmetic Organic and Natural Standard), which was first published in 2010, is managed by a not-for-profit international and independent association (COSMOS-standard AISBL) founded by BDIH in Germany, Cosmebio and Ecocert, both of whom are in France, and the UK’s Soil Association. Together these organisations manage the COSMOS-standard(6).
The COSMOS-standard defines the criteria that companies must meet to ensure consumers that their products, which carry one of the COSMOS-standard logos, are genuine organic and natural cosmetics produced using sustainable practices(6).
The COSMOS-standard defines several key terms , such as, “Natural Origin”, “Non-Natural Ingredient”, “Organic” and “Organic content”. The standard also confirms that several types of chemicals are prohibited, including primary raw materials or ingredients that are Genetically Modified Organisms (GMOs) or derivatives of GMOs. Processes such as gamma and X-ray irradiation are also forbidden(6).
Sustainability of the ingredients used in COSMOS-standard certified products is a key factor and as such the standard requires that any palm oil and palm kernel oil (and their derivatives) used in cosmetic products must be from certified organic origin or certified sustainable sources(6). For more information on palm oil and palm kernel oil please see our section on Palm Oil.
Integrating and developing the concept of Green Chemistry is also one of the main rules which govern the standard.
Full information on the COSMOS-standard is available.
Another certifiable standard is offered by The International Natural and Organic Cosmetics Association (NATRUE). NATRUE AISBL is also a non-profit association, again based in Brussels, it was founded in 2007 by a group of companies committed to natural and organic cosmetic products and looking to promote natural and organic cosmetics made to an agreed and published standard(7).
The NATRUE standard defines things slightly differently from the COSMOS-standard but there are some common criteria, mostly in the type of ingredients which are not permitted, in particular no GMO ingredients or ingredients derived from GMO sources, no ingredients subjected to ionising radiation and no petrochemical derived ingredients. There is a preference that natural ingredients used be certified organic (in accordance with EU definitions or organic)(7).
Unlike other standards the NATRUE standard also covers natural fragrances and references ISO Standard 9235:2013.
There are also additional requirements within the NATRUE standard for finished cosmetic products which they certify. Find full details of the NATRUE standard and requirements.
The Fairtrade Foundation also permitted some beauty products to carry the FAIRTRADE Mark. The Global Fairtrade Certified Cosmetics and Personal Care Products Formulation Policy was created to enable more sales for Fairtrade producers for products that contain only small amounts of natural or naturally derived ingredients, but which are Fairtrade certified (such as cocoa butter for example). The policy outlined the specific formulation guidelines under which such products could be labelled with a special version of the FAIRTRADE Mark(8).
Details of the Global Fairtrade Certified Cosmetics and Personal Care Products Formulation Policy can be found here.
The Fairtrade Sourced Ingredient (FSI) model and FSI Mark were introduced In March 2019. This means that now most cosmetics and personal care products containing Fairtrade ingredients are being labelled with the FSI Mark, as this offers more flexibility for the cosmetic product category. This change of policy means that the use of the special version of FAIRTRADE Mark will be phased out(8).
Rather than focusing on all the ingredients for one final product the FSI model means companies can make big commitments to sourcing one or more specific commodities for use across their ranges, or even their whole business, without necessarily labelling the end product. Farmers still receive all the benefits of Fairtrade, as with the core FAIRTRADE Mark. This includes the protection of the Fairtrade Minimum Price (where relevant) and the Premium to choose how to invest in their community(9).
Organisations that certify products are grown in accordance with various organic standards are now in place in many countries around the world. Not many have their own specific standards for cosmetic products, many recommend COSMO-standard or NATRUE. If using ingredients that claim to be organically grown therefore it is important for the user to verify that the company offering the organic ingredient is a certified member of the organisation and that the standards of that organisation are comparable to those in the UK and EU.
There is increased interest in the use of wild harvested ingredients, but great care needs to be taken when using ingredients gathered from the wild. A considerable proportion of the world’s wild plants are under threat, with an estimated one in five species estimated to be at risk of extinction in the wild. The FairWild Standard was developed to ensure the continued use and long-term survival of wild species and populations in their habitats, whilst respecting the traditions and cultures, and supporting the livelihoods of all stakeholders, in particular collectors and workers(10).
The second version of the standard applies to wild plant collection operations wishing to demonstrate their commitment to sustainable collection, social responsibility and fair-trade principles. It unifies the International Standard for Sustainable Wild Collection of Medicinal and Aromatic Plants version 1 and the FairWild Standard version 1 into a comprehensive FairWild Standard for sustainable wild collection(10).
The scope of the FairWild Standard: Version 2 includes ingredients of herbal drugs and other botanical product originating from wild collection:-
- Plants, plant parts and plant products collected from natural habitats.
- Fungi and lichens collected from natural habitats.
Animal and animal product, such as wax and honey, are excluded from the standard.
If companies are looking to use wild harvested plant ingredients it is recommended that they therefore look at the supply chain to ensure it is sustainable and ethical practices are employed throughout even if it is not certified to the standard.
Fair for Life is a certification programme for fair trade in agriculture, manufacturing and trade. It was created in 2006 by the Swiss Bio-Foundation in cooperation with the IMO Group, it was taken over by the Ecocert Group in 2014 to meet a specific demand from organic farming stakeholders.
Fair for Life depends on the notion of "responsible supply chains" and has a long-term vision, making a sincere commitment and acting responsibly throughout the supply chain(11).
The label encourages a supply chain business model that aims at the resilience throughout. By following the framework defined by Fair for Life certification, producers, processors and brand owners can secure their sales and supplies, thanks to tools such as long-term contracts that include fixed prices and volumes, and by establishing a real partnership between them.
The Environmental Working Group (EWG) is a US based non-profit corporation which is dedicated to protecting human health and the environment. The EWG VERIFIED™ scheme was started for cosmetic products. To be awarded this mark the products must not contain any of chemicals on EWG’s ingredients of concern list, the product must also provide full transparency on all the ingredients used in it and be made to GMP(12). This system is only applicable in the USA.