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Why the ISO 16128 guidelines for natural and organic cosmetics do not take consumers interest at heart

POSTED: 19.10.2017 IN:

ISO is an independent, non-governmental international organization that creates documents setting specifications, requirements or guidance on a topic. The process brings together expertise from a sector to address solutions to global challenges.  Generally-speaking through standardisation complexity can be reduced, and with-it barriers to trade. As such, this approach is something that the natural and organic cosmetic sector could have benefited from.

“Without prejudice, NATRUE welcomes internationally agreed initiatives aimed at reducing complexity and barriers to trade with an emphasis on combating ‘greenwashing’, which is the reason why the NATRUE Label exists. We believe strongly that consumers must not be misled by products claiming ‘natural’ and organic’ but this requires strict criteria to benchmark them” states Dr Mark Smith, Director at NATRUE.

Unfortunately, the outcome of this international process, the ISO 16128 guidelines, has fallen short of current private standard’s requirements, and there is no guarantee that products using it will be consistent with consumer expectations, especially within established markets such as the EU. The broad permissions and flexibility of approach as a guideline fails to combat greenwashing that, at heart, still misleads consumers, fragments the market place, and impacts those innovative producers of authentic products. As such, even if both are voluntary schemes, use of the ISO guidelines cannot provide the same immediacy and transparency to reassure consumers and match their expectations as current private standards.  

The 3 critical points overall regarding the ISO 16128 guidelines they stand that do not improve the current status quo regarding greenwashing and differ from private standards are:

  • ·        General lack of transparency for consumers
The guidelines can only be accessed by paying, and even if purchasing the guidelines alone will not clarify how they have been used in practice.
  • ·        Permitted ingredient origin:  Petrochemical and GM Plants

Petrochemical: Users of the guideline are not obliged to restrict the use of petrochemicals whatsoever. Consumers would not expect mineral oil to be in authentic products but ISO 16128 would allow it. This is an example of how the guideline is fundamentally inconsistent with the principles of the sector, and do not help the evolution and growth of the sector or solve the core issue surrounding greenwash.

GM Plants: Consumer do not expect cosmetic ingredients coming from sources like genetically modified plants (GMOs) to be permitted in natural and organic cosmetics. Consumers are currently reassured on this point as each of the most established private standards for natural and organic cosmetics guaranteed a ban on such ingredients.  

  •       Verification, control and identification of finished products
Part 2 of the guidelines provides calculations to determine natural or organic ingredient content; these can be voluntarily authenticated by certification. However, certification here should not be confused with whether or not the product can officially qualify to claim natural or organic, or certification as it is understood according to private standard that sets specific criteria for finished products. Certification to ISO 16128 only authenticates that the calculation was carried out correctly, as the guideline has no benchmark to establish at what percentage content a product can claim or be considered natural or organic. These are out of scope of ISO 16128 and remain the responsibility of the regulator.

     Consumers have grown to expect some kind of verification logo or seal on a product to assure them of its authenticity. In a study commissioned by NATRUE to GfK it emerged that over 60% of consumers are reassured by the presence of a label on natural and organic cosmetics.

Now we’re here, what do we want from our future?
It should be remembered that the ISO guideline is purely voluntary; its availability does not represent an automatic change in the regulatory framework for natural and organic cosmetics. Countries might choose to adopt the ISO guidelines but there is no obligation.

For the time being ISO 16128 does not change the status quo and leaves space for products that continue, at best, or increase at worst, greenwashing. If a regulatory body were to adopt the guidelines directly in their current state the market risks to be swamped with legitimate but “nature-inspired”, as opposed to truly authentic products thereby generating confusion amongst consumers and negatively impacting authentic producers. More broadly, it is not only possible to conceive fragmented use of the guideline by companies within a territory or nation but also fragmented use globally, if different regulatory bodies decided to add or modify criteria from the ISO 16128 template if incorporating it into law or national guidelines. In either scenario there may be variation between one product’s petrochemical content and another, or whether ingredients in that product are from GMO origin or not.   

To provide consumers with the products they expect, NATRUE advocates that any future regulatory procedure for natural and organic cosmetics, including an official definition or specific guidance for product claims ‘natural’ or ‘organic’, must be strict.

One crucial factor is to maintain trust for future sector growth. This means proactive commitment to stop greenwashing and promotion of an environment of transparency and authenticity. To meet consumer expectations, and to truly combat greenwashing, products claiming to be natural or organic must severely restrict petrochemical use to only specific functions, like preservatives, with a clear emphasis on eliminating their dependence altogether, as well as excluding ingredients from GMOs. All of which will also mean increasing encouragement for further scientific innovation of authentic natural and organic ingredients. Taken together, however, we can see a future where products deliver claims that align themselves with consistent and established consumer expectations for natural and organic rather than greenwash.

 NATRUE is the only association uniquely placed to represent the natural and organic cosmetic sector through its seat at the European Commission Working Group on Cosmetics. This privileged position allow us to directly participate and contribute to evolving legislation, like claims, and  actively campaign to support initiatives that help the whole sector to progress and prosper without undermining consumers trust” concluded Dr Smith.  


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