The 'European Cosmetics Standards Working Group' recently published its proposed standard following six years of deliberations.

The 'COSMOS Standard' still remains to be adopted by the private organisations that constitute this initiative but the criteria differ little from the first draft that was published in November 2008. The standard is still only a draft and should come into force on 1st September 2009. However, certified products have until 1st September 2012 to comply.

There will also be no shared logo. The logo of the corresponding labelling organization will continue to appear on products together with a COSMOS certification mention. This cannot mitigate confusion among consumers who do not know what the various logos of organisations in different countries stand for.

The standard continues to reveal inaccuracies and contradictions

1. The criteria for natural products lack consistency. There is no minimum requirement for the use of natural ingredients and no maximum threshold for the use of chemically processed agro-ingredients in products labelled 'Cosmos-natural'. 
2. Petrochemical raw materials and raw material components (known as moieties) may be used – up to 2 % in the end product. This means that petrochemical substances are even allowed in 'Cosmos-organic' labelled products. 
3. The calculation of the organic percentage is misleading from the consumer's point of view: chemically altered raw material components and natural raw materials receive equal treatment. Paragraph (6.2.1) states that water cannot be included in the calculation of the organic portion, however under (6.2.3) the opposite is stated concerning the reconstitution of concentrates. 
4. There is a lack of clarity and transparency – for example there is no complete list of permitted raw materials (especially the so called chemically processed agro-ingredients). Furthermore, the lists of permitted ingredients do not indicate INCI-nomenclature. 
5. According to COSMOS, chemical processes like alkylation are permitted to obtain chemically processed agro-ingredients. This means that raw materials are allowed that in the opinion of NaTrue should definitely not be used as ingredients in Natural Cosmetics – from the point of view of science and the consumer. 
6. It is not clear how the provisions regarding Green Chemistry can be implemented by companies as they are too vague. 
7. Packaging has not been addressed satisfactorily. Chlorinated raw materials should not be involved in the manufacture and distribution of Natural Cosmetic products.
8. There is no percentage threshold for products of the same brand. For certification under the NaTrue-Label, at least 75% of all individual products (in terms of formulations) of the same brand must be certified as Natural or Organic Cosmetics. Cosmos has no such limitation.

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