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ISO Guidelines for Natural and Organic Cosmetics
Why the ISO 16128 guidelines for natural and organic cosmetics do not have consumer interest at heart
In September 2017, the International Organisation for Standardisation (ISO) officially issued Part 2 (ISO 16128-2:2017) of the guidelines covering the technical definitions and criteria for natural and organic cosmetic ingredients and products. Part 1 (ISO 16128-1:2016) was issued in February 2016, and now with this second part complete a producer or manufacturer can now freely use these guidelines.
ISO is an independent, non-governmental international organisation that creates documents setting specifications, requirements or guidance on a topic. The process brings together expertise from a sector to address solutions to global challenges. Generally speaking through standardisation complexity can be reduced, and with it barriers to trade. As such, this approach is something that could have been of considerable benefit to the natural and organic cosmetic sector.
“Without prejudice, NATRUE welcomes internationally agreed initiatives aimed at reducing complexity and barriers to trade, with an emphasis on combating ‘greenwashing’, which is the reason why the NATRUE Label exists. We believe strongly that consumers should not be misled by products claiming ‘natural’ and organic’ but this requires strict criteria to benchmark them”, comments Dr Mark Smith, Director General at NATRUE.
Unfortunately, the outcome of this international process, the ISO 16128 guidelines, has fallen short of current private standards’ requirements, and there is no guarantee that products made to ISO guidelines will be consistent with consumer expectations, especially within established markets such as the EU. The broad permissions and flexibility of approach of the ISO guidelines fail to combat greenwashing that, at heart, still misleads consumers, fragments the market place, and impacts those innovative producers of authentic products. As such, even if both are voluntary schemes, use of the ISO guidelines cannot provide the same immediacy and transparency to reassure consumers and match their expectations as current private standards.
The 3 critical points overall regarding the ISO 16128 guidelines, which do not improve the current status quo regarding greenwashing, and significantly differ from private standards, are:
General lack of transparency for consumers
The guidelines can only be accessed by paying, and, even if purchased, the guidelines alone will not clarify how they have been used in practice.
Permitted ingredient origin
Users of the guidelines are not obliged to restrict the use of petrochemicals whatsoever. Consumers would not expect mineral oil to be in authentically natural products but ISO 16128 allows it. This is an example of how the guidelines are fundamentally inconsistent with the principles of the sector, and do not help the evolution and growth of the sector or solve the core issue surrounding greenwashing.
Consumers do not expect cosmetic ingredients coming from sources like genetically modified plants (GMOs) to be permitted in natural and organic cosmetics. Consumers are currently reassured on this point as each of the most established private standards for natural and organic cosmetics guarantees a ban on such ingredients.
Verification, control and identification of finished products
Part 2 of the guidelines provides calculations to determine the natural or organic ingredient content; these can be voluntarily authenticated by certification. However, ISO certification using ‘flexible’ guidelines is not on a par with certification to a recognised set level of naturalness or organic content by a private certification standard that certifies to specific criteria.
Certification to ISO 16128 only authenticates that the calculation was carried out correctly, as the guidelines have no benchmark to establish at what percentage content a product can claim or be considered natural or organic. These are out of scope of ISO 16128 and remain the responsibility of the regulator.
Consumers have grown to expect some kind of verification logo or seal on a product to assure them of its authenticity. In a study commissioned by NATRUE from research organisation GfK it emerged that over 60% of consumers are reassured by the presence of a label on natural and organic cosmetics. There is no proposed stamp or seal for the ISO guidelines.
Now we’re here, what do we want from our future?
It should be remembered that the ISO guidelines are purely voluntary; their availability does not represent an automatic change in the regulatory framework for natural and organic cosmetics. Countries might choose to adopt the ISO guidelines but there is no obligation.
For the time being ISO 16128 does not change the status quo and leaves space for products that continue, at best, or increase at worst, greenwashing. If a regulatory body were to adopt the guidelines directly in their current state, the market risks being swamped with legitimate but “nature-inspired” products, as opposed to truly authentic natural products, thereby generating confusion amongst consumers and negatively impacting authentic producers.
To provide consumers with the products they expect, NATRUE advocates that any future regulatory procedure for natural and organic cosmetics, including an official definition or specific guidance for product claims ‘natural’ or ‘organic’, must be strict.
One crucial factor is to maintain trust for future sector growth. This means proactive commitment to stop greenwashing, and nurturing an environment of transparency and authenticity where products deliver claims that meet established consumer expectations for natural and organic cosmetics.
“NATRUE is the only association uniquely placed to represent the natural and organic cosmetic sector through its seat at the European Commission Working Group on Cosmetics. This privileged position allow us to directly participate and contribute to evolving legislation, like claims, and actively campaign to support initiatives that help the whole sector to progress and prosper without undermining consumer trust”, concluded Dr Smith.
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NATRUE, an international not-for-profit organisation, has promoted and protected authentic natural and organic cosmetics since 2007. There are more than 5,500 NATRUE-certified products from over 230 brands, from almost 30 countries worldwide. There are over 60 members of the Association including green beauty pioneers and authentic producers. All certified products are listed on a public database accessible at www.natrue.org which can be used as a checklist to confirm whether a product is natural or organic.