ASCP Skin Deep

MARCH | APRIL 2018

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www.ascpskincare.com 61 According to a recent report,¹ the global organic personal care market size in 2015 was estimated at $10.16 billion. Another study estimates the organic personal care market to exceed $13 billion in 2018.² But while this market has seen steady growth in recent years, experts point out that there are key detriments to using organic ingredients, including limited shelf life, fluctuating raw material supply, and a regulatory system that makes labeling and marketing organic products complicated, at best. "Certified organic" is a claim that is regulated by the US Department of Agriculture. To qualify, a product's ingredients must contain absolutely no toxic pesticides, toxic synthetic herbicides, or chemical NPK (nitrogen, phosphorous, and potassium) fertilizers, and—in the case of animal products—no antibiotics or growth hormones. Regulatory agencies have not defined the term natural in the context of cosmetics, but some guidance has been provided on use of the term with respect to food. According to the Food and Drug Administration (FDA), although they are not engaged in rulemaking to establish a formal definition for the term natural, they do have a policy concerning the use of the word in food labeling. The FDA says it considers natural to mean that nothing artificial or synthetic (including all color additives, regardless of source) has been included in, or added to, a food. Yet, they continue to hold off on fully defining "natural" ingredients in regard to food, nor have they defined the term in the context of cosmetics. This does not mean natural or all natural can be used without risk. For more information on cosmetics labeling, visit www.fda.gov/ Cosmetics/Labeling/Claims/ucm203078.htm. The appeal of organic or natural ingredients is a long-term trend. Here are some key pieces of information you should know before negotiating the slippery slope of marketing organic skin care products. The FDA does not define or regulate the term organic as it applies to cosmetics, body care, or personal care products. The USDA regulates the term organic for cosmetics products, as it applies to agricultural products through its National Organic Program (NOP) regulations. Any cosmetic product may be eligible to be certified under the NOP regulations if it contains, or is made up of, agricultural ingredients, and can meet the USDA/ NOP organic production, handling, processing, and labeling standards. The operations that produce the organic ingredients used in cosmetic products, the handlers of these ingredients, and the manufacturer of the final cosmetic product must all be certified by a USDA-accredited organic certifying agent. Once certified, cosmetics, personal care products, and body care products are eligible for the same four organic labeling categories as all other agricultural products. These include "100 percent organic"; "organic," where the product must contain at least 95 percent organically produced ingredients; "made with organic ingredients," which indicates a product contains at least 70 percent organic ingredients; and "less than 70 percent organic ingredients." For more information on organic labeling for cosmetics, the FDA recommends the NOP publication "Cosmetics, Body Care Products, and Personal Care Products." But, while the FDA does not have an official definition of organic, a cosmetic that is labeled "organic," according to the USDA, is still subject to the laws and regulations enforced by the FDA. Cosmetic products labeled with organic claims must comply with both USDA regulations for the organic claim and FDA regulations for labeling and safety requirements for cosmetics. The FDA also reiterates that an ingredient labeled as "organic" is not automatically safe. Companies and individuals who market cosmetics have a legal responsibility to ensure their products and ingredients are safe for the intended use. Notes 1. Grand View Research, "Organic Personal Care Market Size and Forecast by Product (Skin Care, Hair Care, Oral Care, and Cosmetics), by Region (North America, Europe, Asia Pacific, Latin America, and Middle East & Africa) and Trend Analysis from 2014 to 2025," accessed February 2018, www.grandviewresearch. com/industry-analysis/organic-personal-care-market. 2. Transparency Market Research, "Organic Personal Care Products Market for Skin Care, Hair Care, Oral Care and Cosmetics—Global Industry Analysis, Size, Share, Growth, Trends and Forecast, 2014–2020," accessed February 2018, www. globenewswire.com/news-release/2015/01/ 30/701573/10117865/en/Organic-Personal-Care- Products-Market-to-Reach-US-13-2-Billion-by- 2018-Transparency-Market-Research.html. Natural vs. Organic Ingredients

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