The ‘European Cosmetics Standards Working Group’ initiative has published for discussion a list of criteria for another international label for natural cosmetics. Implementation of the label has not yet been finalised in many areas. There is no organisation to manage the label, and no proposals have been made as to the graphic design. In the opinion of NaTrue, the lack of clarity both with regard to the information communicated and the rules comprising the standard cannot provide the transparency nor the independency the future label should have from the point of view of the consumer.
In addition, the list of criteria published for discussion as the "COSMOS Standard" quickly reveals further inaccuracies and contradictions in terms of the natural and organic credentials of the ingredients:
1. Petrochemical raw materials and raw material components (known as moieties) may be used – up to 5 % in the end product.
2. 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. (6.4.3) states that water cannot be included in the calculation of the organic portion, however under (6.4.1) the opposite is stated concerning the processing of drugs.
3. There is a lack of clarity and transparency – for example there is no complete list of permitted raw materials.
4. According to COSMOS, chemical processes like alkylation and ‘processes to extract amphoteric materials’ are permitted. 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.
5. It is not clear how the provisions regarding Green Chemistry can be implemented by companies as they are too vague.
6. The point concerning packaging has not been addressed satisfactorily (7.4.3). It is not thinkable that chlorinated raw materials may be used in the manufacture of natural cosmetic products.