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The American Herbal Products Association (AHPA) filed comments in support of a document drafted by the US Department of Agriculture’s (USDA) National Organic Program (NOP) that suggests certifying and labeling soaps "organic" or "made with" under the Organic Foods Production Act (OFPA).
In the drafted document, the NOP states, "A formulated product produced using 75% organic ingredients and 25% allowed synthetics is eligible for certification as a “made with” product. In addition, the “made with” products should carry a certified organic content of 75% when used in subsequent down-stream processing, under the condition that full disclosure of its organic content and other ingredients is provided by the manufacture. If a soap is produced using 80% certified organic oil and 20% sodium hydroxide, the soap would be eligible for certification as a soap “made with organic oils.” Further, the soap “made with organic oils” may be processed downstream into other products using 80% as the organic content for 56 those calculations."
Michael McGuffin, president of the AHPA responded, “Our strong support for extending the NOP to include soap made from agricultural ingredients is consistent with our established position that the OFPA is best applied broadly to all organic products based on content and irrespective of end use."
The AHPA also notes that the US Food and Drug Administration (FDA) has taken the position that in designating cosmetic soap ingredients, a labeler may declare its ingredients either as the starting materials that went into making the soap or the resulting reaction products. For soaps to comply with the NOP, they would need to list the starting materials.
Although the AHPA supports the NOPs certification of soaps under the OFPA, it finds error with the NOPs mention of saponified oil. The draft document by the NOP states that soaps containing organic saponified oils as part of a separate process, may list the ingredient as a parenthetical statement, such as "saponified organic oil (organic coconut oil, potassium hydroxide), water, glycerin, beet juice color.” AHPA states that neither “saponified organic oil” nor “soap” currently appear to be allowed under FDA regulations. The association encourages NOP to initiate communication with FDA to clarify the issue.