There currently are no separate standards for personal care under the USDA National Organic Program—only standards for food certifications. In order to be certified, personal care products must meet the food standards. Among those in the industry and consumers, there is confusion, as well as misrepresentation about what is “organic” and widespread misleading marketing claims and labeling. We help our customers understand the intricacies and challenges of developing certified products. We define “organic” consistent with USDA requirements in meeting the USDA standards at either 70% (made with some organic ingredients category), 95-100% (organic), or 100% organic. The latter categories can display the USDA certified organic seal. Please go to Labeling and Composition Guide link. The USDA standards are the “Gold Standard” internationally for personal care.
However, we see product development as a continuum and understand some customers may want “natural” formulas, or products with some organic ingredients only. We will help you reach your definition of where you want your products to be on the continuum. Marketing goals and cost generally drive where your products need to be on the continuum.
Development costs approved for customizing bases of formulations
Formula Approval by customer
Private labeling agreement
Labeling (draft of final label) review and approval by certifier as well as submission of paperwork to certifier (our responsibility). Each product must be certified under brand name.
Submission fees (will be determined per product submitted)
Upon approval, a certificate will be issued by certifier stating each product is certified and at what level.
Any change in formulation, must be re-approved with appropriate label copy changes
Traceability needs to be assured so customer must use lot number on all invoices to their customers.
Sensibility Soaps, Inc. copies of organic certificates (link to be posted)
Introduction to Certified Organic:
When we use the term “organic”, we mean USDA certified organic. If you want “natural” or to use some organic ingredients, this section will not apply. This is “required reading” for anyone considering or planning to market a USDA certified product or product line—especially those at 95-100% organic.
Thinking about USDA-certified organic products versus conventional ones requires a significant shift in thinking and expectations for most potential customers either working in the industry or for those who typically use conventional products. We say, “They get it” when someone understands there are limitations and inherent differences in certified organic products because there is much misleading information, which leads to confusion. We have now implemented a waiver requiring customers to sign to acknowledge understanding and agreement about what you will read below so there should be no surprises or expectations we cannot meet. If this—organic product development and manufacturing--- were easy, everyone would be doing it. We know it is a changing marketplace and consumers require education, however, if the company who is marketing certified organic products does not “get it”, the consumer will not either. If you are not committed to understanding, appreciating, and being able to communicate about the differences in certified organic products, including supporting the increased cost, marketing certified organic products is not likely going to work for your company.
What are the differences between conventional personal care products and certified organic products?
There are many differences and they are significant. Conventional products contain many chemicals designed to perform in personal care products: emulsifiers, preservatives, surfactants, etc. These are not permitted in organic products. Organic products contain food ingredients. Food ingredients allowed are only those grown organically. There are no chemicals permitted; the only ingredients allowable other than food are those on the National Approved List under the USDA National Organic Program (NOP). There are simply some products, which perform even better than conventional products and some, which will not perform as well. That is a subjective evaluation, however. The performance of silicones and quats are virtually impossible to achieve organically. There are compromises at times. Reaction is typically “Wonderful, surprising, unbelievable!” to “Can this product foam more?” These are foods made to perform as personal care products versus chemicals designed to perform in personal care.
Cost: This is an important consideration. Certified organic raw materials’ costs reflect supply and demand. And, these raws are sourced and purchased internationally. Generally, the pricing of finished organic products is at least 30-75% higher than conventional or “natural” products. That is a critical understanding. We cannot make certified organic products for what we can conventional ones—it is generally impossible. Water does not count as organic in calculating percentages so cleansers do not contain water in order to achieve a 95-100% organic claim. Organic juices are used. Typically conventional cleansers contain over 85% water. The pricing of ingredients fluctuates—again it is supply and demand. So, we must factor some margin into pricing to account for that or we cannot offer you somewhat stable pricing. However, it is routine that our raw material pricing goes up so we must pass that on. These raw materials are commodities. Some are more stable in pricing, however, most are not. Meeting strict organic standards necessary to maintain certification must be reflected in pricing. And, these are made in smaller batch sizes so we do not have economies of scale in manufacturing.
Performance: Products are formulated and processed to optimally perform, however, please remember that these are foods. Most products perform as well as many conventional products, however, expectations about some products cannot be met---there are limitations inherent to using these standards. For example, foaming cannot be comparable to the use of a surfactant such as Sodium Lauryl Sulfate in cleansing products.
Aroma: There is a base odor in all products due to the use of food ingredients, however, in most products, it is minimal. There are no artificial or “natural” fragrances allowed, only organic essential oils or flavors. Aromas can fade, as can flavors used for aromatic purposes. Aromas can change over time in products. We will not assure aroma standards since there will be variation. We have fragrance manufacturer partners who work with our bases and your fragrance specifications for certified organic aromas. Cost is variable and we will guide you on essential oils and blends, which meet your target pricing. Organic essential oils and blends are typically very expensive and require a much higher percentage of fragrance loads in products versus conventional products. Think anywhere between $45.00 per pound to hundreds of dollars per pound.
Preservation: Products are formulated for self-preservation by ingredients and processing. A shelf life of 2 years can be expected. Over time, aromas may fade or change slightly, there may be some color shift or change, and products should be kept at ambient temperatures of 50-95 degrees F for optimal performance and life. Extreme heat will degrade and change most products—even conventional ones. Products are challenge tested for preservative efficacy. Costs for testing are the responsibility of the customer.
Aesthetics: Products made with foods are generally more “earthy” in colors naturally. Creams and lotions depending upon ingredients are typically “cream-colored”. Pastels or pure whites are not typically achieved. Also, important to understand is that colors change from batch to batch due to the natural variations in colors, which occur with the raw materials. For example, olive oil may be greener, more yellow, or more brown depending upon the crop. We will not assure color standards since there will be variation. We recommend that customers do not use clear bottles or containers but a solid color or heavy frost due to the colors and variations from batch to batch. And PET bottles and containers are best due to the propensity of organic ingredients and the possibility of bottles paneling, however, compatibility testing is recommended.
Consistency/viscosity: There are variations in consistency at times due to the variability of raw materials, however, we can achieve a range. Processing methods help achieve this, however, there will be some slight variation from batch to batch depending upon lots of raw materials used.
Stability: Products are stability testing. Since no conventional emulsifiers are able to be used, there can be slight free-floating oil at times in lotions, however, generally this is not the case, however it can happen especially of course when products are exposed to extreme temperatures. When a formula requires it, we recommend “shake before use” instructions, however, this is usually not required.
Development: We continue to advance our knowledge and expertise in creating products, which continue to perform better. So, formulas evolve into generations from beginning ones. There are development costs to consider in your budget. “Tweaking” a formula base does require time to formulate and will require testing. Flexibility is key for customers to understand that and keep aware that although a performance expectation may be compromised, we continue to work diligently to resolve over time. Or, adjust product line development accordingly.
Lead-Times: Since sourcing, based upon supply and demand, can be challenging with organics, lead-time is a factor. The sooner, the better, for Purchase Orders to be initiated. Generally, order lead-time is 4-6 weeks, however, some raw materials may require additional time for delivery. Plan to give us 6-8 weeks, and projections are always helpful for procurement. We are sensitive to your time-frames, however, as a partner, expect to work with you to determine reasonable and achievable time-frames so no one is disappointed by the possibility of not meeting time-frames for product launches and re-orders.
Labels: Labels must meet both USDA and FDA standards. All label drafts must be approved by Oregon Tilth and us prior to manufacturing them. If you choose to have them manufactured before approval, we cannot be held responsible if changes need to be made. This is the case with secondary cartons as well.
Certification: We must submit paperwork for certification for each product and each company. Although a product base was certified before, each label must be certified. We will provide you the submission costs for certification.
Quantities: We have quantity requirements for production batches. There are many reasons for these requirements from adequate processing and batch sizes to cost-effective manufacturing goals of the company, which is in customers’ best interests as well for pricing. We may not be able to meet your needs, however, we try to determine this early on to not waste your time or ours. Generally, however, we try to be flexible, when possible. We can produce products for test marketing and do pilots, however, we also have the capacity for larger production runs.
Private Label Agreement: Our certifier requires a private labeling agreement between our customer and our company in order to assure National Organic Program standards will be met by our customer.