Posting about Organic Standards and Organic Sunless Tanning Solutions

The following was our response in 2009 to a thread in www.tantalk.com entitled best Organic Solutions.  It should be helpful for those seeking truth about organic sunless solutions and also who wish to understand how “organic” applies to sunless tanning.  Please call us if you have any questions.

“Re: Best Organic Solutions

Tanningdudes comments really bring out the complexity and many important facts relating to the state of organic cosmetic products in the USA and organic sunless solutions in particular. Well done – this is important for consumers and us in the industry marketing products.

We would like to add our 2 cents worth on this topic and this relates to both tanning lotions and sunless solutions. We hope you find this helpful. 

Our qualification to comment on this is that Biddiscombe is a Certified Organic Manufacturer under the federal law called the National Organic Program (NOP) that is administered by the USDA. We take organic claims very seriously.

The facts are as follows:

1. The federal NOP or organic program was designed as a law controlling organic food products. 

2. There is no federal law applicable to controlling organic cosmetic products. 

3. The USDA reluctantly agreed to allow the USDA Organic seal to be used on cosmetic products if the products were fully in compliance with the organic food rules.

4. Two private entities, NSF and Oasis, are working on developing private certifications for organic cosmetics. These private standards are in their infancy.

5. Without violating law, companies may use the word organic for their products regardless of the percent of organic ingredients or whether there are other very un-natural ingredients. This is being done extensively across the country and there is much deception occurring.

To use the USDA food program Organic seal on a cosmetic product, two requirements must be met. The product must meet the ingredient requirements of the NOP and the product must be manufactured in a Certified Organic Facility.

Let me tell you this – making organic cosmetic products under the NOP that are good is an amazing challenge. As the organic food rules have tightened over the last 2 years, this has become even more difficult and we work on this stuff every day.

That is a broad brush overview on organic and the lack of laws that control organic cosmetic products. I will follow with another posting that deals with ingredients. Between these 2, you should have a good feel for where we are on organic.

Knowledge is power.

John from Biddiscombe

Re: Best Organic Solutions

Quote:

Per our other posting, a company is permitted to use the USDA NOP Organic certification process for cosmetics provided they meet the organic food rules. There is currently no applicable law controlling organic cosmetics.

Clearly from your question, you have heard percentages thrown around. These come from the food rules. The private standards that are being developed by a couple of groups have percentages as well. (The way that the private standards will work is if you comply with their rules and pay the fees, you can use their organic seal).

Under the food rules (the NOP), there are 2 pieces:

The organic portion – all must be certified organic under the US rules, the NOP.

The non-organic portion – the USDA has a list of permitted non-organic ingredients. This list is called the National List and it basically excludes all synthetic ingredients. Even if an ingredient is 100% natural, if it is not on the list you are prohibited from using it unless it is organic. 

The NOP has 3 different levels under the food rules that can be certified.

a) 100% Organic – clear enough

b) Organic – 95%+ organic with the remainder being from the National List.

c) Made with Organic Ingredients – 70%+ organic ingredients with the balance from the National List.

If a product both meets one of these and the product is made in a Certified Organic Facility, it can be certified. A private certification company provides the certification i.e Organic Certifiers, Oregon Tilthe, QAI.

Organic Sunless Solutions

Here is the deal. 

There is no dihydroxyacetone or DHA certified under the NOP. If someone is telling you otherwise, they are being untruthful. Ask em for a copy of the NOP certification.

Tanningdude correctly states that there is one DHA supplier that makes DHA that is EcoCert certified organic. EcoCert is the French organic standard. Currently there is not reciprocity between the US and Europe on organic standards so EcoCert certified organic products can not be considered organic for purposes of an NOP certification. 

As an example of what is possible, we have a sunless solution that is 95% + organic ingredients certified under either the NOP or EcoCert. The remaining 5% is all natural including the cosmetic colors.

I have looked at some so called organic solution ingredient lists and they do not come close to organic under the NOP rules and some ingredients raise my eyebrows!

What can you do if organic is important? Ask for ingredient lists. Ask if the DHA is certified in any way. Ask for the percentage of certified organic ingredients. Confirm that there are no synthetic ingredients. And don’t forget this applies not only to solutions but also to lotions.

My projection is that the 2 private standards will establish a following and they will eventually become a basis for some organic labeling laws. This could take years but there is currently a lawsuit that could accelerate things.

Hope this helps in your understanding.

Thanks to kggonline and tanningdude for getting this thread started. I think it is important.

John”

Last edited by Biddiscombe; 07-16-2009 at 01:33 AM.