Organic and Natural: Caveat Emptor

Apr 1, 2009 | Contact Author | By: David C. Steinberg, Steinberg & Associates
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Title: Organic and Natural: Caveat Emptor
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Keywords: natural | organic | regulation

Abstract: Previous columns have discussed Canadian Natural Health Products regulations but have steered clear of the natural and organic debate, although this author previously published an article that debates animal versus vegetable ingredients, in which he explains that a chemical is a chemical regardless of its origin; a molecule of glycerin is just that, whether from natural sources like animal or vegetable fat, or from petroleum or biodiesel sources.

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Every once in a while, readers ask how topics are selected for this column. This time, the idea came from an e-mail inquiring what COSMOS standards are. Previous columns have discussed Canadian Natural Health Products regulations but have steered clear of the natural and organic debate, although this author previously published an article1 that debates animal versus vegetable ingredients, in which he explains that a chemical is a chemical regardless of its origin; a molecule of glycerin is just that, whether from natural sources like animal or vegetable fat, or from petroleum or biodiesel sources.

COSMOS is an independent effort in the European Union (EU) aimed to outline organic and natural standards, with draft guidelines published in November 2008. But how is it different than other standards? This calls for a review of the various natural and organic standards for the personal care industry and how they have evolved.

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Figure 1. USDA Organic Seal

USDA Organic Seal

USDA Organic Seal

Figure 2. Natural Products Association Seal

Natural Product Association Certified

Natrual Products Association Seal

Figure 3. OASIS Organic Seal

OASIS Organic

OASIS Organic Seal

COSMOS Chemical Reactions

Allowed physical processes:

  • Extractions must use natural materials with any form of water or with a third solvent of plant origin such as ethyl alcohol, glycerin, vegetable oils and CO2 absorption (on an inert support that conforms to these standards);
  • Bleaching or deodorization (on an inert support conforming to these standards);
  • Grinding, centrifuging (solid/liquid separation, spin-drying);
  • Settling, decanting, desiccation or drying (progressive or not by evaporation/natural under sun);
  • Deterpenation (if fractionated distillation with steam);
  • Distillation, expression or extraction (steam);
  • Filtration and purification (ultra filtration, dialysis, crystallization and ion exchange);
  • Lyophilization, blending, percolation, cold pressure and hot pressure (depending on the fluidity of the fatty acids to be extracted);
  • Sterilization with thermal treatments (according to a temperature respectful of the active substances); and
  • Sifting, maceration and ultrasound

Allowed chemical processes:

  • Alkylation, amidation, calcination of plant residues and carbonization (resins, fatty organic oils);
  • Condensation/addition, esterification, etherification and fermentation (natural/biotechnological);
  • Hydration, hydrogenation, hydrolysis and neutralization (to obtain Na, Ca, Mg and K salts);
  • Oxidation/reduction processes for the manufacture of amphoterics; and
  • Saponification, sulphation and roasting

Unallowed processes:
Any other processes that are not listed above are not allowed, including but not limited to:

  • Bleaching or deodorization (on a support of animal origin);
  • Use of enzymes derived from GMOs;
  • Deterpenation (other than with beam);
  • Ethoxylation, irradiation and sulphonation (as the main reaction);

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