The final version of the long awaited Cosmos standard was published on 8 June this year after almost seven years of talks and a struggle to define the minimum requirements for organic and natural cosmetics. Now these have been agreed, the harmonisation of the market seems feasible – but will it work?
The European Cosmetics Standard Working Group that drafted the Cosmos standard included representatives from the main European organic certifying bodies including BDIH in Germany, Cosmebio & Ecocert in France, the Soil Association in the UK, ICEA in Italy and Bioforum in Belgium. The definitive draft should be released soon and any changes are likely to be just a formality and only minor adjustments. The Cosmos standard was to have been in place by September this year but the date was recently postponed to January 2010 to coincide with when the actual Cosmos-certified products are expected to hit the shelves.
The representatives behind the Cosmos standard have worked together to develop common rules to promote sustainable production and consumption of organic and natural cosmetics and to encourage the development of a single market. Indeed the ultimate goal of creating a harmonised and recognised standard is to incorporate it into EU law in order to protect the organic cosmetics sector. At the moment the word organic, when used to describe cosmetics, is not regulated in any way and as a result consumers can be easily misled.
Putting plans into practice
Betty Santonnat, director of development for Cosmebio comments: “It is important to keep in mind that cosmetics don’t fall within the scope of the current regulation (EC) N834/2007, which relates to food and farming organic production. This is why private standards, such as Ecocert, have appeared in the cosmetics market. However, having too many national standards in Europe is confusing for consumers. It’s even common to see different seals from different organisations on a product. The aim of harmonisation through the Cosmos standard is to provide minimum requirements that will be the same for everyone across Europe.”
The Cosmos standard was also devised to ensure only safe cosmetics are placed on the market while promoting the use of organic ingredients and natural resources responsibly.
Reaching an agreement was not an easy task. “During the preparation of the document there were many areas of controversy and that is one reason why the process has taken so long,” says Francis Blake, standard and technical director of the Soil Association. “Among the biggest issues were how to calculate the percentage of organic ingredients in the product and what the minimum percentage should be. Ecocert and the Soil Association have traditionally used very different methods of calculation and bridging the gap between these was very difficult. Another area of controversy was the application of green chemistry principles, particularly deciding on which ones we could implement with concrete requirements as this is a very new and emerging science.”
The deliberation of the required Soil Association mandate to use organic ingredients where available (which is required by the Soil Association but not by Ecocert) and the list of permitted non-organic ingredients caused the final draft of the Cosmos standard to be a somewhat painstaking process.
The European Cosmetics Standard Working Group decided that products can be defined as organic if they feature at least 95% of ingredients that are certified organic. Probably one of the most controversial measures adopted by the Cosmos standard is allowing chemically-processed agro ingredients to comprise up to 2% of the product. However, these ingredients are only allowed for a grace period of 36 months.
The rules of composition for gaining organic certification include having a minimum total organic content of 20% (except for rinse-off, lotion and powder products where the minimum requirement is 10%), at least 95% of physically processed agro-ingredients must be organic and at least 30% of chemically processed agro-ingredients must be organic – with formulaters getting the same 36 month grace period to adhere to these rules and to allow formulators to seek alternative sources.
Blake continues: “There will only be one common standard so they will not have to worry about whether they comply with different rules for different countries. However, they may have to change their formulations in order to comply with this new overall standard. For consumers, it will mean much less confusion on the shelves.”
The packaging however will continue to feature the national certification body’s logo, so Cosmebio, for example, together with the name of the new standard which will be either Cosmos natural or Cosmos organic. There will however be no actual Cosmos logo.
Hard to harmonise
According to a survey carried out for the UK’s CTPA by YouGov in March last year, consumers are very confused about organic products. “Around 91% of people think that shampoos contain certain chemicals but only 55% of people think organic shampoos contain chemicals,” says Paul Crawford, head of regulatory and environmental services at the CTPA. “In fact lots of chemicals are used to make organic cosmetics but consumers don’t seem to understand this nor the principles and the differences between the various standards. This complexity is why it has taken seven years for Cosmos to develop a harmonised standard. And in the meantime, a new standard was developed and released by NaTrue.”
NaTrue is a non-profit organisation and industry lobbying group that was founded by natural cosmetics brands including Dr. Hauschka (Wala) and Weleda to represent the interests of manufacturers of natural and organic cosmetics at an international level. NaTrue was in fact in disagreement with some of the Working Team’s plans, specifically the use of up to 2% petrochemicals which will be allowed for 36 months. Another point of contention was the fact that the Cosmos information will appear alongside the logo of the individual certifying body for that country – and according to NaTrue this will just cause further confusion among consumers.
At the Natural Cosmetics Masterclass held in London last month, Vincent Letertre from Dr. Hauschka and the Scientific Board of NaTrue explained what brands have to do to carry the NaTrue standard. It will be applied only if at least 75% of all products within a line or brand can be certified as organic or natural. This is to avoid the situation where a company certifies just one or two products but gives the appearance that a range is entirely organic. Unlike Cosmos, NaTrue has its own independent and accredited certifying bodies and membership is not a condition of certification. NaTrue has come up with a series of strategic marketing techniques and a star classification which allows manufacturers to find out right away how their product will be classified.
One star means natural, two stars means natural cosmetics with organic ingredients and three stars indicates a fully organic product. While the standards were only launched in September last year, NaTrue certified products are already available on the market. Some in the industry feel that the NaTrue standard has simplified many of the issues that Cosmos battles against.
According to Crawford: “Where so many certifying bodies are competing commercially with different standards, it is difficult to see how consumers will really benefit. Cosmetics legislation ensures that all cosmetic products are safe whilst organic and natural standards focus on the origin of ingredients. While standards do benefit manufacturers, consumers should also share in those benefits. This is why the European cosmetics industry supports harmonisation in this area, particularly the underlying criteria used by natural and organic standards. Until the Cosmos label becomes widely recognised by consumers it will have little marketing value. However, this is true of any new standard. If companies continue to use the logos of national certifying organisations it won’t help the marketing of Cosmos, but that is a commercial decision which each company must make.
“At this stage, I am not sure whether the Cosmos standard will have any wider significance. Indeed, some of the criteria appear to create further barriers to the wider harmonisation process. Apart from European differences, there are also barriers with the US. The technical criteria used there are different, in particular with regards to the way water is accounted for and the use of ingredients derived from animals. Standards in Europe exclude ingredients from dead animals whereas there are no such limitations on the US market. One possible solution is to allow ingredients from animals killed for food purposes. However, with the implementation of the overall animal testing ban, this would not be possible for the EU standards.”
The organic market
What the NaTrue and Cosmos standards do have in common is their effort towards regulating a market that is still in its relative infancy and lacks consistency.
Speaking at the Natural Cosmetics Masterclass, Amarjit Sahota, director of Organic Monitor which was hosting the event, gave an overview of this market sector.
Said Sahota: “Data from 2007 shows that the European organic C&T market is still a niche category, representing on average 3% of the entire industry worth €1.5bn. The German market is the largest in Europe, with a total market size standing at €8.2m and Germany is also the place where most organic private labels are developing. On the opposite side of the pond, the UK only has a very small organic market. Data from 2008 showed a market size of €180m, just 2% of the entire market. Here the spend per capita stands at just €3, which is 50% less than the rest of Europe. Skin products are the best performing organic products covering 57% of the market, followed by hair care at 28%.
“Despite its small size, in 2008 the British organic C&T market grew by 16% and consumer trends show that the appetite for organic goods is not going to end soon. This is true for the whole of Europe where organic cosmetics are experiencing an increasing penetration in mainstream retailers. Meanwhile private label and concept stores are also rising in number while celebrity endorsement is helping the segment along too. Development in the organic C&T market has also become competitive with many mergers and acquisitions taking place. L’Occitane en Provence recently bought Melvita to add an organic arm to the business rather than reformulating its own lines. Conventional cosmetics companies have also claimed their slice of the organic market launching many new lines, and savvy consumers have driven this trend by beginning to understand the potential dangers of chemicals found in beauty products. The initial demand for organic food has definitely transferred onto the cosmetics market while the rise in ethical consumerism is enriching this sector too.”
Sahota made it clear how difficult it is to define natural and organic cosmetics since, apart from private initiatives from the Soil Association, until now there has been no national or European standard for all.
While organic cosmetics contain certified organic ingredients, natural cosmetics are made from plant extracts and natural ingredients and can still contain a low amount of synthetic chemicals. Most companies that claim to be natural avoid or at least aspire to avoid parabens, petrochemicals and in general synthetic ingredients in their formulations. But, says Sahota, their marketing must be made clearer otherwise consumers will get disheartened and lose interest in a jungle of definitions that make no sense to them. Marketing organic, fair trade, ethical, environmentally friendly and free-from variants is a sign that the industry is making an effort to be innovative. But it’s crucial to remember that consumers are looking for visible, credible results.
What also must be taken into account are the rising numbers of private standards coming out and the fact that retailers could start developing their own standards, something that UK retailer Alliance Boots has already done for its own Botanics line. The economic slowdown has also had an impact on the organic market with less capital available for investment.
However, the organic market appears set for a successful future, at least with regard to private labels which, despite the economic crisis, can count on relatively low prices in comparison with leading organic brands. This could prove to be a winning weapon in a market where consumers are very price sensitive and have reason to look for points of differentiation.
While Cosmos certainly represents a positive step forward on many levels in the harmonisation process, there are still a number of uncertainties about it and NaTrue may represent a viable alternative for companies looking for clearer certification.
Cosmos vs NaTrue
' NaTrue was designed by the industry for the industry and therefore for a formulator itâ€™s clear and easy to work with, with a positive list of permitted ingredients and criteria available online.
â€œThe Cosmos standard has been designed by several certification bodies and it is not yet clear exactly which chemically modified materials are permitted. Also, NaTrue is a triple standard (organic, natural and organic and natural) whereas the Cosmos standard is a double one (organic and natural).
â€œNaTrue has a foothold in the US with the QAI agreement (Quality Assurance Inspection for the ISO standards), working on the claim that it is made with organic ingredients. This is important as the NOP system (National Organic Program by the USDA) in the US is not aligned with Europe. Cosmos-certified products would not be recognised by the NOP so for reasons of export to the US, NaTrue products have a point of advantage.
â€œNaTrue has a simple scheme that charges fees per product while Cosmos organisations charge a membership fee and a percentage of the profits. On the other hand, the certification bodies behind Cosmos are well known by the public already whereas NaTrue is still relatively unknown. '
No organic requirement
Synthetic preservatives allowed
95% of the physically processed ingredients must be certified organic
Minimum 20% organic content
At least 30% of the chemically processed agro ingredients must be organic within three years of introduction of the standard
Green chemical processes must be used
Source: Organic Monitor
The NaTrue standard (star classification)
Natural Cosmetics* No organic content required. Minimum levels of natural content and max level of nearly natural materials are specified by product type
Natural Cosmetics with organic ingredients** Must also contain a minimum 15% of chemically unmodified natural substances and a maximum of 15% of nearly natural substances
A minimum of 70% of the natural substances of plant and animal origin must come from controlled organic farming and/or from controlled wild collection
Organic Cosmetics*** Must also contain a minimum 20% of chemically unmodified natural substances and a maximum 15% of nearly natural substances. A minimum of 95% of the natural substances of plant & animal origin must come from controlled organic farming and/or from controlled wild collection
Source: Organic Monitor
Why organics does matter
' My mother Margaret, who formulates our products, has gardened and eaten organically since the 1970s, a long time before it became trendy. She has similarly been formulating organic skin care for the past 20 years. To us the organic philosophy makes so much sense both for the environment and for people themselves. We have to create sustainable products that arenâ€™t reliant on petrochemicals or intensive agriculture, plus natural substances are much more compatible with the human body than synthetic ones and therefore achieve better results. Our hero product is our Gentle Herb Shampoo, the first ever shampoo to be certified to organic standards in the UK back in 2004 and which has now become a best seller. Our new 2-in-1 Purifying Mint Mask was recently the first ever product to be certified to both UK organic and Fairtrade standards.
â€œI would advise consumers to purchase organic cosmetics for three main reasons â€“ they are healthier, more effective and they are better for the environment. Several studies confirm they are more effective as they use organic plant oils, rather than petrochemicals, have higher vitamin content and therefore are far better moisturisers.
â€œWith regard to the Cosmos standard, I do think that it will have the credibility to be entertained by EU decision makers. All major certifiers in five European countries agreed it so itâ€™s very representative of the brands and products on the market today. Cosmos will also successfully cut down confusion for consumers. It will make it easier to recognise when a product has certification, tell the difference between natural and organic and compare organic content between products. National certification logos, like that of the Soil Association in the UK, will be retained somewhere on the packaging which might still look a little odd to the consumer, but Iâ€™m hoping that the word Cosmos on the front of the pack will be a sufficiently unifying feature.'