Whole Panic! Will they empty the shelves?

This week I have received numerous calls asking: “What can I do to get certified for (you pick the question)…the Whole Foods List…the Whole Foods Standards…the NOP…the NSF…? And then they want to do all of this by June 1^st for formulas that already exist and were never designed to meet any of those Standards.

Certified by next Wednesday.

Yeah, right.

I have received “Help!” calls from brands, from private label labs, from cosmetic distributors, and from NOP certifiers who look at ingredient statements of things like: “Cocoamidopropylbetaine, Sodium Cocoaphoacetate, Sodium Cocoyl Sarcosinate” . . . and their eyes cross. (Just in case you don’t know, none of these ingredients would pass NOP or NSF).

Folks - a few basics:

#1 - The NOP Standard is for food. The NOP certifiers are looking for an ingredient statement that includes recognizable food ingredients. (Yes, I know you make cosmetics but...facts are facts). You will need to make sure that your INCI names translate into things like “sunflower oil”, “Non-GMO Vitamin E”, etc. You will not meet the NOP unless you used all food ingredients and a few allowed non-organic food ingredients like citric acid and malic acid. Good luck with that.

#2 – The NSF Standard was designed without being tested by real cosmetic companies which means it will change repeatedly over the next few years. (Reminded me of that old line that a camel was a horse designed by a committee). They do NOT have a list of approved ingredients and it does not allow things like most vitamins (no C, no D, no A, etc.) and the only effective preservative it allows is potassium sorbate and sodium benzoate. Again, good luck.

#3 – Whole Foods sent this letter to their vendors…what, a year ago? Well, 11 months anyway. Now what?

Whole Foods decided that the NOP and/or the NSF were the only acceptable standards for their store. They have that right. One might argue that in the interest of promoting organic agriculture it would have served us all if they accepted the other organic standards, but . . . they didn’t and too many companies have waited until now to react.

Results? As of today - there are only 2 private labels labs in the US certified to do NSF certified products and it takes a few months to get through the process. There is only 1 certifier offering this standard and my sense is that it is a struggle to get the right documents from their applicants and they are learning as they go. It is a confusing process that is evolving and will get easier – but not before June 1^st. There are about 5 brands, (1 large, 4 small) who have gotten products certified.

SOOOO - should we start a pool? Who thinks that WF will pull all the non-certified products that are not certified off the shelves next Wednesday? I really don't know. I also don't know if they realize how few people have gotten certified. I am working with a few who are trying to get certified - but it won't be by next week.

Stay tuned - this will be interesting!

How Stupid is This?

It has been 11 years since I started working on the concept of certified "organic" cosmetics. In Europe they have multiple standards and literally thousands of certified product. Where are we here in the US?

Nowhere. The NOP is not designed to deal with chemicals (in spite of having certified multiple synthesized chemicals) and certainly can't sanction the use of synthesized preservatives. We don't really have a functional certification program. What constitutes a functional program?

TRANSPARENCY - the process should be clear and understandable to the participants and to the public.

RESPONSIVENESS - this is a young industry, any standard needs to be sufficiently responsive that when we learn something new or conditions change, the standard can be adapted in reasonable time and with reasonable effort.

RIGOR - the standard needs to 1) continuously improve and 2) be tough enough that it meets the consumer idea of an "organic cosmetic".

CREDIBILITY - the certifiers offering the standard need to have enough understanding of cosmetic chemistry, chemical manufacturing, and the laws governing the manufacturing and sale of these products that they are trustworthy.

The NSF Org. cosmetics program has been singled out by Whole Foods as its choice for standards and yet it does not seem to meet many of the criteria above. Consumers have no access to the standard (well - they can spend 100.00 and buy it). It is very cumbersome to change and so not responsive. It is not especially rigorous - there is no internal mechanism to review ingredients by experts before they are added to the allowed list and they don't actively communicate with consumers. Finally - QAI continues to ignore the fact that they need to hire a chemical engineer (like EcoCert did) - so credibility? Not so much. They are looking at chemicals with no one on staff who is trained in how chemicals are manufactured.

The continuing disconnect in this arena is that the cosmetics are made from chemicals. Whether people realize of not - even water is a chemical, H2O. And we all know that water can be contaminated by all sorts of nasty things.

Until the retailers and organic NGOS support multiple private standards to compete for the respect and trust of the consumers, the US will continue to lag behind Europe when it comes to a functional organic cosmetic certification program.

See? Like I said, how stupid is this?

What Is RBD Oil?

RBD or RBDW is “Refined, bleached and deodorized” and the “W” is “winterized”. Is that allowed for “organic” certified? Let’s look at the process of how we get oil from a seed.

Vegetable seeds, all seeds in fact, contain some oil. Nuts have as high an oil content as 74% (macadamias - no wonder they taste so good). Other sources of commercial oils are sunflower seeds, soy beans (beans are seeds . . .), or the seeds from coconuts and palms. We are also familiar with peanut oil, canola oil, and flax seed oil.

Conventionally, all of these oils are extracted from seeds via some combo of heat, pressure and solvents. “Organic” or natural oils are “expeller pressed” - the seeds are mechanically pressed to squeeze out the oil. In commercial, conventional manufacturing plants, the seeds are also treated with hexane, a petrochemical solvent, to get the last little bit of oil out of the seed. In organic operations the use of hexane or other petrochemical solvents is prohibited.

The product of any of these processes is called crude oil. In some cases it is simply filtered and then sold. “Virgin” oils, like “virgin coconut” are crude oils that have been filtered to remove the non-oil remnants from the extraction. Castor is filtered and then boiled to volatilize off any moisture. Unfiltered oils may also be sold - this should be somewhere in the product description. I sell an unfiltered avocado oil that is so dark green it is almost black and it smells just like avocados. RBD avo oil is pale yellow-green and has no distinguishable smell.

Refined oils may go through a number of treatments. In the organic world this may include filtration through diatomaceous earth or fining clay which reduces the color and smell of the oil and a treatment with less than 1/2 % of citric acid. The citric acid binds to metal molecules and allows the refiner to make sure that there are no heavy metals floating around your oil. Finally, winterizing, is a chilling process that brings any waxes to the top and allows them to be removed to ensure that the oil stays as clear as possible.

Personally I recommend refined oils for personal care: they have less of an aroma to conflict with essential oils or other aromatics, they have no heavy metal risk (remember - plants grow in dirt, dirt has all sorts of molecules so heavy metals naturally occur in plant derived products), and they tend to have a better shelf life.

There are different processing details that apply to each of the different types of oils but this is the basic thing that happens to make an RBD or RBDW oil. These letters should appear on the Specification or Certificate of Analysis that should accompany any oil you buy.

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