Archive for ‘Soap Regulations and Requirements’

July 5th, 2011

Small Businesses are NOT Exempt from the New HR2359 The Safe Cosmetics Act 2011

It just figures that our government would wait to release the full text of the newly proposed HR 2359 Safe Cosmetics Act 2011 until a National Holiday like the 4th of July. I think they believe we were all too wrapped up in grilling our hot dogs and burgers, and watching fireworks to care about something as insignificant as a teeny, tiny bill that could ultimately wipe out our entrepreneurial businesses.

For anyone who hasn’t been following this issue, allow me to summarize.

The FDA regulates food and cosmetics. They are charged with enforcing the Food and Drug Act, a set of regulations that prohibit the use of toxic chemicals, specify labeling standards and ingredient disclosure, and provide a reporting and notification procedure should unsafe products be suspected. Adequate funding and a few revisions would allow the current law to be effective.

However, someone wants more money and less competition, and would rather create new legislation. Simply throw in a few carrots for small business, such as exemption from fees and certain registration requirements, hide the entire smothering, suffocating, job-killing monster full of regulation and fees under the friendly sounding title “The Safe Cosmetics Act,” and you’d think they’ve got this thing in the bag.

In the current Go Green atmosphere of the 21st century, public support for anything natural sounding is easy to come by. Who wouldn’t want to support a bill called “The Safe Cosmetics Act,” especially when so many people believe  that cancer causing toxic chemicals are allowed in our cosmetics?  This anti-toxic-filth movement has been perpetuated by powerful lobbying groups. They’ve worked hard to help build and sustain an atmosphere of distrust of the cosmetic industry, creating cute animated YouTube videos that sound convincing, make unsubstantiated claims, and quote bad science to induce a panic among all of us. They suggest that toxic chemicals aren’t regulated, that lead is “put” into lipstick by uncaring manufacturers, and that the products we all use daily are responsible for surging cancer rates.  Consumers, who often know little about real chemistry or science, believe this, and jump on the bandwagon supporting bad legislation that profits no one but the lobbying groups, and ultimately hurts consumers.

How do these groups (we all know who they are) profit from this legislation? First, the proposed legislation gives them carte blanche to file claims against businesses should they have “ANY reason whatsoever” to believe a product is misbranded. This gives them a ridiculous amount of power, as far as wiping small businesses out of the arena. Second, they could profit tremendously by ensuring that their database, and their bad science become the go-to source in deciding which chemicals will and will not be permitted in products should this bill pass.

Let’s learn a bit about these groups, shall we? One of the groups, created and manages an online database of chemicals and cosmetics, which allows users to identify the supposed health hazards of the ingredients found in their cosmetics. It assigns hazard ratings to each, and looks quite scientific and well-founded, but has been publicly attacked for being anything but.  The other group is actually an off-shoot of the first, and produces cutesy YouTube videos about hot button issues, garnering support for their causes, using scare tactics, broad generalizations and bad science to encourage the public to believe things that just aren’t true. Did I mention that both are huge political lobbying groups? Do you think now, that perhaps there’s something in it for them if a Safe Cosmetics Act can be passed into law?

Last year, HR 5786 The Safe Cosmetics Act 2010, was introduced, but was ultimately defeated due to its lack of exemptions for small cosmetic businesses. EWG and CSFC spent millions trying to rally support for it, but thankfully, indie businesses prevailed. Through an aggressive anti-Safe Cosmetics Act campaign, small cosmetic businesses were able to squelch the bill.

Unfortunately, a newly updated version of the bill was introduced in Congress on June 24, 2011, and we find ourselves defending why we are against The Safe Cosmetics Act, once again. This time, it’s HR2359, named, not surprisingly at all, The Safe Cosmetics Act 2011. Not very original, but effective, since of course, no one in their right mind would want to be anti-Safe Cosmetics, right? Before the bill’s text was even available to read, people had chosen sides. I withheld my decision until I could see what changes had been made.

The last time around, Indie’s were upset that there weren’t exemptions for small businesses. Well, in all fairness, this time around we got what we wanted, at least as far as that one issue is concerned. There IS an exemption for small business, BUT it only exempts us from registration and fee requirements. There are still disclosure requirements that will essentially require our products to be tested in order to discover minute amounts of “contaminants” in the formulations.

There are reporting standards that only allow for a 24 hour window of action. Better keep those business lines open on weekends! This will practically create the need for us to keep lawyers on hand 24 hours a day, in order to defend against unwarranted claims and supposed failure to act.

We will be required not only to keep toxic chemicals out of our products, a requirement already mandated by the FDA, but we will also be required to not use products which might be determined to be unsafe down the road. This would require us to have an omnipotent knowledge of these things.

Another important point, is that should a product be determined or even thought to be unsafe, anyone who has used the product will be notified. This will require a record of each and every person you have sold your product to. For those of us who participate in craft fairs, this will be a nightmarish record keeping task. “Please provide complete contact information, mam, so that I can notify you if the ingredients in my product are ever suspected of being a health hazard.” Can you imagine keeping track of thousands and thousands of customers? For what length of time? Indefinitely? Even tax records are only required for a 7-year span…

Then there are huge perception problems that will be created with passage of this bill. Small companies, who, lucky for us will be exempt from all the registration mandates (yay for us!!!), could be perceived as being “unregulated,” and therefore unsafe (hey- that’s not fair!). After all, no one is watching what we’re putting in our natural-ingredient-laden, untested products, right? Large corporations could use that as an easy advertising campaign against the small businesses that have actually been making the most natural, unadultered and safe products all along.

How about those of us who private label? Because of mandated transparency provisions in the bill, you would have to disclose your complete supply chain. Everyone will now have potential access to the same product you once thought was your “Signature Blend.”

Finally, do you really think being exempted from fees is going to save you money? Nope. Larger corporations, who supply your suppliers, think Cargill, will certainly fall under the umbrella of regulation, and wind up paying huge fees. How does this effect you? The cost of your supplies will go up, as these corporations attempt to minimize the impact of the new fees on their bottom line.

As I have learned from reading, re-reading, and dissecting the new bill, small businesses aren’t really exempt at all. We’re put in the unfortunate position of having giant red and white striped targets strapped to our backs, paying more for supplies, and having to keep file cabinets full of, most likely, useless information. And why? Because someone wants to make some money.

Please help us defeat HR2359. We want to keep making the safe, natural products you’ve come to trust and that your skin craves. With simple updates to current listings of unapproved chemicals, and appropriate funding to allow enforcement, the current FDA act adequately protects the public from adulterated, unsafe products.

You Can Help by Signing the Petition to Stop HR2359.

 

 

 

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June 28th, 2011

HR2359 The Safe Cosmetics Act 2011

Oh my. It seems we’re in this again. Another bill has been presented in Congress attempting to help clean up the ingredients found in our cosmetics. Will this bill provide the reforms we need and support Indie Cosmetic Businesses that are dedicated to making safe products? Or, will this bill merely increase regulation without noticeable benefit to consumers?

While many of us are absolutely FOR safe cosmetics, and absolutely AGAINST toxic chemicals in the products we use on our bodies, we at The Natural Bar Soap Company feel it is very important to not take a stance on supporting or not supporting proposed legislation, until we read the full text of a bill. The parts of a proposed bill that will affect us the most, are often found in seemingly minute details.

In the case of HR2359, The Safe Cosmetics Act of 2011, the full text is still not available. There are many many blog sites that purport to tell us what the bill is about, and the specifics of this proposed law. However, even though the bill was presented to the Congress on June 24th, the text has not been released by The Government Printing Office, as of June 28, 2011 for us to read.

Until we see the text, we will not take a position. We obviously need to change something, as current FDA laws that prohibit filth in our cosmetics are not being enforced, and many known-to-be-harmful chemicals are showing up in the body products we use daily. However, change for the sake of change, is not necessarily a good thing. It must be GOOD change.

This link to the Library of Congress, will allow you to read The Safe Cosmetics Act when it becomes available. At that time, we can all read the bill, and decide whether or not this bill is the good change we need.

http://thomas.loc.gov/cgi-bin/query/z?c112:H.R.2359:

 

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June 25th, 2011

HR2359 The Safe Cosmetics Act of 2011, Safe Cosmetics ActTo Amend Title VI of the Federal Food, Drug, and Cosmetic Act to Ensure the Safe Use of Cosmetics and For Other Purposes.

Almost a full year ago, I blogged about HR5786, The Safe Cosmetics Act that was presented in the 111th Congress in July 2010. Small cosmetic businesses around the country rose to the occasion and voiced our disapproval of this bill that would impose overreaching regulations on our entrepreneurial endeavors.

Groups such as Donna Maria’s Indie Business Network began circulating petitions gathering support for the bill’s opposition. The Handcrafted Soapmaker’s Guild established a Legislative Advocacy Committee, and solicited donations for a Legislative Advocacy Fund to fight the proposed legislation. We were all appalled that the government would impose product testing requirements on those of us using ingredients that are GRAS (generally regarded as safe), that nightmarish paperwork and data submission requirements would be imposed on us, and that trace elements in our ingredients would need to be discovered and disclosed on our labels, potentially even minute particles found in water (which vary depending on the water’s source).

We were particularly upset that small businesses would fall under the same umbrella of restrictions and regulations that large corporations would be subject to. What was being presented as an effort to ensure safe cosmetics did little to help that cause or protect the public, and instead buried small business under stacks of unnecessary, burdensome regulation.

On June 24th, a newly written bill, HR2359 The Safe Cosmetics Act to Amend Title VI of the Federal Food, Drug and Cosmetic Act to Ensure Safe Cosmetics and For Other Purposes was presented to the 112th Congress, sponsored by Rep. Janice Schakowsky (D-Il), Rep. Tammy Baldwin (D, WI) and Rep. Edward Markey (D-MA).  The new legislation is co-sponsored by:

Rep. Barney Frank (D-MA)

Rep. Earl Blumenauer (D-OR)

Rep. Judy Chu, (D-CA)

Rep. Luis Gutierrez (D-IL)

Rep. Barbara Lee (D-CA)

Rep. James Moran (D-VA)

Rep. Debbie Wasserman Shultz (D-FL)

Rep. Lynn Woolsey (D-CA)

HR2359 has been referred to the House Education and the Workforce committee, and the House Energy and Commerce committee, to discuss the provisions of the bill that fall under each respective committees’ jurisdiction.

It will be interesting to see how the concerns of the small business cosmetic industry are addressed in the new bill. As of 12:30am June 26, the text of HR2359 had not been released by the Government Printing Office. Apparently, after a bill is presented to the Congress, it can take a few days for the text to be made public, and sometimes longer, if the GPO is experiencing a back log of print requests.

Ideally, we would like to see exemptions for small businesses. We would like exemptions for products labeled as “Soap,” which do not currently fall under the Food and Drug Act’s jurisdiction. We would also like to be able to use ingredients without restriction, so long as they are already GRAS. As an industry, we welcome legislation that prohibits the use of toxic chemicals in cosmetic products, but demand that such legislation recognizes that many chemicals that are toxic at high levels, are perfectly safe at lower levels. We want legislation that is based on true science, rather than over-generalizing, fear inducing databases such as EWG’s Skin Deep database.  Legislation should above all, be applied fairly and reasonably, and not cause unnecessary fear or burden.

President and CEO Lezlee Westine, of The Personal Care Products Council made the following comment regarding presentation of the new HR2359 Safe Cosmetics Act two days ago.

“We are still reviewing the provisions of Rep. Schakowsky’s new bill, but we   are very concerned that, as written, it contains provisions that will place unnecessary burdens on (the) FDA and businesses of all sizes and may compromise jobs without providing meaningful benefits to consumers. Strong federal safety requirements already govern cosmetics and personal care products sold in the U.S. The safety of cosmetic and personal care products in the U.S. is overseen by the U.S. Food and Drug Administration under the Federal Food, Drug, and Cosmetic Act (FD&C Act), which requires that all cosmetics be substantiated for safety before they are marketed, contain no prohibited ingredients, and that all labeling and packaging be in compliance with U.S. regulations. Under the FD&C Act it is a crime to market an unsafe cosmetic product.”

We the people should demand safe cosmetics, but we should also demand laws that serve the public interest, not special interest and lobbying groups. I am looking forward to the text of the new HR2359 to be released to discover whether or not our elected policy makers were listening when we objected so loudly to HR5786.

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May 19th, 2011

The Role of GreenPalm in the RSPO

Palm Oil continues to be a source of great debate, although much progress is being made to ensure it is produced in sustainable ways. GreenPalm is  a global organization that is working hard to combat the social and environmental issues that result from the production of palm oil.

When manufacturers and retailers make and sell palm oil items covered by the GreenPalm program, they provide incentives and rewards to palm oil producers for their efforts to produce palm in socially and environmentally responsible ways. The program provides a way for participants to inform their customers about their efforts, and to earn more for their palm crops through the selling of Green Palm palm oil certificates.

The following is a letter I received this morning from Bob Norman of GreenPalm. I hope you’ll take a minute to read it, and also to share the information with others. It is imperative that while satisfying global demand for palm oil, we, in turn, demand that it is done so in a responsible way.

“The global perspective

GreenPalm enables RSPO certified palm oil producers to earn more for their efforts, wherever the palm oil is produced, whether or not they export to Europe. Since only a small proportion of palm oil producers actually export to Europe, this is of great significance. GreenPalm is engaged therefore in a much wider campaign, with global reach, rather than limiting itself to producers who already deliver to Europe.

Similarly, GreenPalm also offers a means for end-users of palm oil, wherever they are in the world, and whether or not other RSPO certified options are available to them, to support sustainable production and make a real difference. It also allows users of palm or palm kernel derivatives (which are not yet available from certified sustainable sources in sufficient quantities) to contribute to sustainable production and make supporting claims. The really good news is that they’re doing so in ever increasing numbers.

So far GreenPalm certificate sales have supported the production to 1.8 million tonnes of certified sustainable material, which is more than twice the volume of other supply chains put together. As a result, RSPO certified producers have earned $14 million in additional income for their efforts and $1.8 million has been raised to support the work of the RSPO into the process.

RSPO audited, transparent and credible

This has been achieved as every aspect of the GreenPalm programme is RSPO approved, credible and transparent, with strong and clear rules. Every certificate sold is directly supporting RSPO certified production from audited producers. Buyers and redeemers of GreenPalm certificates are recorded, and open to public scrutiny, on the GreenPalm website.

They include many of the world’s most respected brands: Unilever, United Biscuits, Cadbury’s, Cargill, Carrefour, Kellogg’s, Kraft, Marks and Spencer, Nestle, Oriflame, Premier Foods, Ginsters, Shell and Waitrose to name but a few. Each takes its CSR policy and reputation seriously, and their ongoing support is a testimony to the credibility and viability of GreenPalm.

In our view each RSPO supply chain option has a valid role to play. GreenPalm has played the biggest role so far and in an innovative, credible and transparent way has incentivised sustainable production around the world and helped to take the RSPO forward in making a better world. We thank you for your continuing support.”

The Natural Bar Soap Company only uses palm oil from sustainable sources to hand make our natural soap. We hope you’ll do your part, as well, and encourage companies you do business with to use and support sustainable palm oil as well.Your small steps toward environmental and social responsibility become large strides when combined with the efforts of other. No one is too insignificant to make a difference.

For more information about GreenPalm, please visit their website, by clicking here.

For information on the Roundtable on Sustainable Palm Oil, click here.

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October 11th, 2010

Natural Soap – Can it Be Made With Fragrance Oil?

Lately, I’ve been researching the word “natural.” At first glance, it seems like such a simple term, but dive in a little bit and you’ll begin to understand the confusion that arises from its use, and even from the lack of its use.

Let’s start with one very often misunderstood and often unknown fact:

The FDA does not regulate the term Natural, (with one tiny exception).

Unlike “organic,” which carries with it legal requirements of certification and such, the FDA, as recently as 2008, has stated that there are far more pressing issues to take up than that of looking into the potential regulation of “natural.” Therefore, all of those sites that attempt to tell you the FDA only allows plant or animal-derived ingredients to be called “natural,” are just plain wrong. Worse, they write about and spread their misinformation on their blogs and websites, causing even more confusion, and leading  thousands to believe that people using the term “natural” are being dishonest. Oh- what’s a soapcrafter to do?

With the absence of regulation, it remains up to the individual soap crafter to decide what to call their product. Arguably, since soap does not exist in nature, it is not truly “all natural.” However, when made with natural ingredients, I believe most people understand the term “Natural Soap” quite clearly. Regulation really shouldn’t be needed to explain that when natural ingredients (i.e., those that occur in nature, as opposed to being formulated from synthetic ingredients in laboratories) are used to create a product, it is “natural.”

Another hot topic in the “natural” realm is the issue of scent and which ingredients should be used to impart it to natural soap. Those who believe only essential oils can be used in natural soap occupy one side of the arena, while those who don’t object to fragrance oils in their soaps occupy the other. True, essential oils are about as natural as scent gets. Extracted by solvents, pressed or steam distilled, essential oils are truly the natural oil of a given plant. And, fragrance oils- well, they’re synthetic compounds, made out of chemicals with long, difficult-to-pronounce names,  that often irritate skin and aggravate asthma.

Right?

Not so fast. While it is true that “fragrance oil” is generally understood to refer to a synthetic fragrance with little to no natural component in its formula, there is actually a THIRD category of scents available to the soapcrafter which goes by the same name. These are the natural fragrance oils, and they are made with naturally occurring aromatics, called “isolates.” These include resins (for example, balsam and myrhh), absolutes (jasmine, narcissus), and often, even blends of essential oils. Many natural fragrance oils are available on the internet, and certification of their ingredients can be obtained.

The difficulty comes in the labeling of such ingredients. Unfortunately, FDA  regulations have really done a disservice to handcrafted soap makers in this important regard. The word “natural” is not allowed on an ingredient list, unless used as an adjective for the word “flavoring.” This means that soapers are limited to either listing specific essential oils, or the generic term “fragrance.” Therefore, natural fragrance oils, which are not simply essential oils, must be listed as “fragrance” without benefit of the modifier, “natural.” This leads customers reading ingredient lists to assume that these naturally fragranced soaps are scented with synthetic fragrance oil.

It is not likely that many customers will ask the soapcrafter about the source of the “fragrance oil.” At best, a soapmaker can put an explanation on their soaps’ labels, or hope to get to engage in conversation with their potential customers. It’s really a shame, though, that because of regulation, scent ingredients that are as natural as any others in a bar of natural soap must masquerade as “fragrance,” subject to the same miserable disdain so often inflicted upon their identically labeled synthetic counterparts.

If the FDA would simply allow “natural” as an adjective for flavorings, as well as for scents, this would clear up the confusion. Natural soapcrafters wouldn’t have to defend their choice of natural scents, and soap buyers could trust that what they’re buying, is as natural as the maker asserts it to be.

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October 6th, 2010

Top 10 Soap Ingredients to Avoid…

…if you want real, made-from-scratch, natural soap.

Natural Soap

Natural Soap

One of the easiest ways to know if the soap you’re buying is handmade from scratch, or simply hand formed or “melted and poured,” is to take a look at the ingredient list.

Unfortunately, many handcrafted soaps sold on the internet do not have such a list posted for potential users to read. Granted, if the soap is intended ONLY for cleansing, and makes no other claim but to clean, it does not require an ingredient list under current federal law.

However, many many websites are offering soaps they claim will  MOISTURIZE and/or CONDITION the skin, and even help ACNE! Under FDA regulations, these soaps MUST include ingredient lists due to the claims they make.

Perhaps the makers of these unlabeled soaps just don’t want you to know that they’re “handcrafting” their soaps using premade soap bases. Here are some of the common ingredients found in premade bases, that would not ordinarily be found on the ingredient list of a “from scratch” natural bar of handmade soap.

10. Sorbitan Oleate

9. Propylene Glycol

8. Sodium Laureth Sulfate

7. Sodium Stearate

6. Sodium Myristate

5. Sodium Cocoyl Isethionate

4. Triethanolamine

3. Sorbitol

2. Glycerin

1. FD&C dyes and lakes

10. Sorbitan Oleate- an emulsifier and hardener used to stabilize oils. Not necessary in a made-from-scratch bar of natural soap! Properly made-from-scratch natural soaps are stable mixtures of oil and water. It isn’t necessary to add additional emulsifying agents to handmade natural soap.

9. Propylene Glycol- a humectant, emulsifier and moisturizer. With the plethora of moisturizing oils available to the made-from-scratch soap crafter, a lab-isolated ingredient like this isn’t necessary. Shea butter, which is rich in vitamins, is wonderfully moisturizing. And olive oil, perhaps one of the most widely used oils in soap making is often chosen for its conditioning properties. As far as emulsifiers, read number 8! As for humectants, keep on reading!

8. Sodium Laureth Sulfate- i.e. Sodium Dodecyl Sulfate, is a DETERGENT and foaming agent that is absolutely unnecessary in a bar of made-from-scratch natural soap. Detergents are “ANTI-SOAPS.”  Many are harsh and stripping, and very cheap to produce. Instead of resorting to SLES as a foaming agent, why not try some good-ol’ natural castor oil, or even sugar? These two ingredients will cause some crazy bubbles in a bar of natural soap, with no risk of stripping or harshness.

7. Sodium Stearate- used particularly to harden soaps made with vegetable oil. Sodium stearate is the sodium salt of stearic acid (it’s created when the lye solution reacts with stearic acid). However, palm oil, lard, cocoa butter, and many other natural ingredients naturally contain stearic acid. They can create varying degrees of hardness in a bar of made-from-scratch natural soap. If a natural soapcrafter wants to create harder bars, they can change their formula to include oils that will create that quality, or alter the %’s used in their formula. It is quite simple to increase hardness without using an isolated chemical.

6. Sodium Myristate- an emulsifier, hardener and surfactant; the sodium salt of myristic acid, created when lye reacts with myristic acid. Coconut oil and palm oil are two great sources of myristic acid. True artisans use these “complete” vegetable oils rather than isolated compounds derived from them, to create their natural soaps. When seen on an ingredient label, Sodium Myristate is a good indication that a pre-made base was used. Natural, handcrafted, made-from-scratch soap does not need lab-isolated ingredients to create basic qualities such as hardness, that are generally expected in a bar of soap.

5. Sodium Cocoyl Isethionate- a surfactant, makes water “wetter” so dirt can wash away. Hmmm. I bet handcrafted, made-from-scratch natural soap does that, too. Soap’s main role in this universe is to act as a surfactant, and it does this quite effectively. Each end of a soap molecule has a specific function; the “head” bonds with water, the “tail” bonds with dirt. The two ends work together to lift and carry dirt away. Artisan soap crafters who start from scratch don’t use sodium coco-anything as an isolated ingredient in their bar soap batters.

4. Triethanolamine- an emulsifier, and a surfactant. A strong base with a pH of 10. Often used to balance the pH of cosmetic products.  As explained in #3, soap itself is a surfactant- it lifts grime, attaches to it, and allows it to be rinsed away with water. Natural, handcrafted, made-from-scratch soap does not need lab-isolated “emu’s” (emulsifiers) and “serfs” (surfactants) unless they are real, furry-but-dirty Emu’s, and sweaty, overworked Serfs!! Sorry– couldn’t resist.

3. Sorbitol- a sugar alcohol. Used as a humectant and thickener in premade soap bases. From-Scratch Natural soap contains loads of glycerin, which forms naturally during the soapmaking process. It is one of nature’s most wonderful humectants. Glycerin is capable of attracting water to itself, and hydrating skin. Rich, naturally creamy and thick bar soap made with natural ingredients, does not need additional thickeners or humectants.

2. Glycerin- a substance naturally produced in the soapmaking process. While there may be instances when a soapcrafter would want to add additional glycerin into their bar of soap, it would be quite uncommon. More often than not, the word “Glycerin” on an ingredient list indicates the soap was created from a pre-made base. Natural, handcrafted, made-from-scratch soap does not need additional glycerin throw in.

1.FD&C dyes and lakes- artificial agents used to impart color to soap, but totally unnecessary in a beautiful, naturally colored bar of soap. Nature’s pantry provides a rich assortment of herbs, flowers, roots, bark and minerals that can produce a beautiful spectrum of all natural color. I know- I know- by now, you’re got this sentence down: “Natural, handcrafted, made-from-scratch soap does not need” artificial colorants.

natural soap

natural soap

For really great, all natural, MADE FROM SCRATCH soap, visit my site! Soap makes great gifts- and is the best gift to give to ensure your friends are clean and pleasant to be with! As unfair as it may be, you are judged by the company you keep!

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August 31st, 2010

FDA Labeling for Soap

So, I finally have my answer. The FDA Compliance Office says I can label my cosmetic soaps in one of two ways: either “AT FORMULATION” or “AT USE.”

“At Formulation” requires the listing of lye, either sodium hydroxide or potassium hydroxide.

“At Use” requires the use of the terms for the salts of the fatty acids that the oils become, for example, sodium cocoate, sodium palmitate.

Either customers have to be educated on the fact that lye reacts completely and is not present in the finished product, or that “chemical sounding names” are really just natural oils converted into soap.

I’m going with “At formulation.”

Any thoughts? Please send me your comments.

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June 2nd, 2010

Organic Soap

There sure are a lot of soap companies out there claiming that their products are “organic” or “made with organic” ingredients. There are many that also say they are “certified organic.” Certified by whom?

Hmmm… The Natural Bar Soap Company adds several oils to our formulations that are purchased and labeled “organic,” and I would love to use that term on my labeling. However, just as the FDA has stringent guidelines for when a soap becomes a cosmetic or drug, I am sure guidelines exist  concerning use of the words  “organic,” “made with organic,” and “certified organic.” Before labeling my products with these words,  I thought it best to look into what sorts of regulation apply to their use.

Google searching “organic regulation” results in a plethora of information on the subject. I discovered that the FDA does not regulate organic products, except to the extent that they are soaps, cosmetics, drugs, or foods. However, I did learn that the United States Department of Agriculture does. In fact, there is a federal regulation, Title 7, section 205, titled “The Organic Foods Production Act of 1990″ that regulates the use of the terms “organic,” “made with organic,” and “certified organic.” Interestingly enough, although it is a food act, it is also applied to personal hygiene products (there is a debate currently going on about whether it should apply to non-consumable products, but until the matter is settled, soap makers need to follow the regulation as well).

The OFPA guidelines require adherence by producers of agricultural products, as well as handlers of those products (that would be soap makers, like myself). The only people exempt from the act, are retailers of the finished products, and handlers who will not sell more than $5000.00 per year of their “made with organic” and “organic” products. However, handlers wishing to claim that exemption must keep records proving that their ingredients are in fact Certified organic. Additionally, even though their ingredients may be certified, they are NOT allowed to label their finished product “certified” or imply in any way that their product is  “certified.” Products claiming to be organic must have a minimum 95% organic ingredients. Another designation,  “made with organic,” only requires the organic component be 70-95% of the finished product.

So, what’s a soapmaker to do? In order to prove your product is 95% organic, you need to have your formula tested. How many on-line soapcrafters have done that? I would guess not many. Another interesting note here, is that according to the USDA website, they consider glycerin, a byproduct of the soap making process, to be a synthetic. This is because the glycerin does not exist naturally on its own, but must be synthesized during saponification. So, the higher glycerin content of your soap, the less “organic” it is in the eyes of the USDA. While doing research for a previous blog article, I tried to find a calculation to determine the precise glycerin content of a given recipe for soap, and was unable to find one. I found several articles suggesting a range of values, but nothing precise. Therefore, how could the average soapcrafter determine this necessary piece of information? I personally don’t agree that glycerin is a synthetic. Many products in our grocery stores that are labeled “organic” including cookies and other baked goods, underwent chemical changes as a result of the baking process, yet are still worthy of being labeled “organic.” But, I digress…

As I mentioned earlier, I would LOVE to label my “made with organic” soaps as such, but because of our success on the internet, I cannot qualify for the certification exemption. To use the organic terms on my labeling, I’ll need to speak with an Accredited Certifying Agent, who in my state, happens to be the Maryland Department of Agriculture. Unfortunately, they are unavailable to talk to me at the moment. I’ve left a message… and I’m hoping they’ll call me back. I did, however, speak to a lady at the National Organic Program, who gave me a little bit of a head’s up into the certification process. I’ll need to furnish letters from each of my suppliers, addressed to me, stating that the products I have been purchasing are “Certified Organic” by the USDA. I will also need to pay for each of my soap recipes to be “formulated” to determine that the proper ratio of organic to synthetics is in line with the organic standard (read: LOTS OF $$$). I’ll also need a site inspection of my facility, ensuring that there is no cross-contamination of organic with non-organic ingredients. I can’t even wager a guess as to how much becoming certified would cost,  or how long it would take me, but I’m relatively sure that it’s a lengthy, costly process.

What I have gained, from looking into all of this, is a strong hunch that most of the soap companies out there claiming to sell “ORGANIC” soaps are using the word without having done their homework. Doing so puts them at great risk. The NOP has an arm that exists purely to enforce the OFPA Federal Regulation, and states they will “investigat(e) allegations of severe and willful violations for possible civil or criminal penalties.” If you have not gone through the certification process, and cannot substantiate your claims, it’s best to avoid the words “organic,” “made with organic” and “certified.”

While we are unable to use those words on our products at this time, we will continue to stand by our commitment to make ALL NATURAL soaps, naturally.

Our Promises to You:

We will use vegetable oils instead of animal ones.

We will use natural Essential Oils instead of synthetic fragrance oils.

We will use natural colorants and botanicals instead of artificial dyes, lakes and the like.

We will only test our products on our children and ourselves. :)

Additional regulation information can be found at the USDA NOP website: http://www.ams.usda.gov/AMSv1.0/nop

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