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Organic and Natural: Caveat Emptor
By: David C. Steinberg, Steinberg & Associates
Posted: April 1, 2009, from the April 2009 issue of Cosmetics & Toiletries.
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.
What is Natural?
According to the author, when he first began to learn during the Dark Ages, the elements of earth, air, fire and water were understood to be natural; thus everything made from them was considered natural. Later, industry expert Ken Klein stated that anything made from the first 92 elements of the periodic table are natural, and that no man-made elements should be used in products claiming to be natural; however, this philosophy did not seem a sufficient answer for what marketers where claiming.
An Internet investigation retrieved several meanings for the term natural, among which were: being present in or produced by nature; i.e., a natural pearl; being inherent or not acquired; not being produced or changed artificially; and not being altered, treated or disguised.
The US Food and Drug Administration (FDA) does not define natural in the Food, Drug and Cosmetic Act or any other FDA regulation; the closest definition2 for natural personal care products was established in Canada as a regulated category called Natural Health Products. This regulation, which went into effect on Jan. 1, 2004, defines natural health products (NHPs) as: vitamins and minerals, herbal remedies, homeopathic medicines, traditional medicine such as traditional Chinese medicine, probiotics, and other products like amino acids and essential fatty acids.