The US Department of Agriculture (USDA) has proposed changes to the 'made with organic' standard that is used for personal care products. Specifically, the draft guidance addresses the use of non-organic ingredients in 'made with organic (specified ingredients or food groups)'' products, and the use of statements about the
percentage of organic ingredients within the 'made with organic' labeling category.
The USDA National Organic Programme’s (NOP’s) 'made with organic' standard has been adopted by the personal care and cosmetics industries, even though these standards were not originally designed for use in non food items, NOP’s 'made with organic' standard has been designed for products containing a minimum of 70 percent organic ingredients and the proposed clarifications relate in particular to the claims authorised for the labelling of such products.
According to the NOP, statements such as “made with organic ingredients” or “made with 75 percent organic ingredients” are not acceptable versions of the ‘made with organic…’ claim. Instead, the ‘made with organic…’ claim must be followed by a mention of a specified ingredient such as ‘made with organic shea butter’. This can be used with or without a percentage claim, the NOP has said. The NOP clarified that a percentage claim should not be used on its own without being accompanied with a ‘made with’ claim that mentions specific ingredients.
In addition, it said a claim of 100 percent organic should not be used in conjunction with a ‘made with organic…’ claim as it could be misleading. For example a product with multiple ingredients might say ‘made with 100 percent organic lavender oil’ which might lead consumers into thinking that the product is 100 percent organic.
The NOP is publishing the clarifications, and seeking comments, as it says it has received a number of questions on the subject.
Details of the proposed changes and how to leave comments can be found on the Federal Register Notice .