Challenges and opportunities in the NOC sector: NATRUE and its role

NATRUE has worked for better regulation for natural and organic cosmetic products and has actively advocated for an official definition of natural and organic cosmetics, which is very much needed to combat greenwashing and misleading claims in the NOC sector.

B/Open team interviewed Dr. Mark Smith, the general Director of natrue

What is NATRUE’s role to face challenges and opportunities in the NOC sector?

However, greenwashing is still a challenge for the authentic NOC sector. As an international non-profit association, NATRUE remains an active participant and contributor towards the protection of natural and organic ingredients from inappropriate regulation that may reduce the NOC sector’s ability to manufacture products in line with consumer’s expectations. Since its foundation in 2007, NATRUE has advocated for better regulation and enforcement for natural and organic claims to ensure that consumers are not misled by greenwash, and to promote a level-playing field for the NOC producers. NATRUE is involved in regulatory decision-making both at international level and within the EU, through its privileged seat at the European Commission’s Working Group on Cosmetic Products.

As of today, there is still no official definition or regulation for natural and organic cosmetics but brands/companies respect private standards. What are the NATRUE requirements to certify a cosmetic product as natural or organic? Is this information available at first glance on packaging?

As a reflection of our founders’ ethics and values, the NATRUE Label is a voluntary scheme established to set strict criteria to represent natural and organic cosmetic product authenticity without diluting or compromising these product claims through arbitrary exceptions. NATRUE’s approach offers a comprehensive package of high benchmarks to guarantee trust both at product and brand level, which is achieved by setting clear requirements for a product’s contents and by focusing on authenticity, transparency and clarity. Label users that choose the NATRUE Label are truly committed to combating the threat of greenwash and to ensuring that consumers are offered authentic natural and organic cosmetic products that meet their expectations.

Consumers demand products that reflect certain qualities. In acknowledging these factors, the requirements of the NATRUE Label establish that NATRUE certified products cannot contain ingredients produced from mineral oils or GMOs, silicones, synthetic fragrances, and defined substances such as parabens. To protect the environment, our Label criteria does not permit microbeads and sets biodegradability requirements for surfactants; for ethical considerations, the NATRUE Label imposes a global ban on the use of its seal on cosmetic products where animal testing is required.

The NATRUE standard defines criteria for product formulations in order to be certified into one of three levels: natural, natural with organic portion or organic, and sets mandatory organic content for products containing organic ingredients.

The strictness and transparency of the NATRUE Label has ensured its place as a market leader for certified natural and organic cosmetics. For this reason, the NATRUE Label is the choice for some of the largest producers of authentic natural and organic cosmetics worldwide.

The NATRUE Label differentiates itself in that our standard:

– avoids overinflated natural content claims by treating added water as neutral;

– guarantees that every certified organic cosmetic ensures high organic content;

– requires each brand to commit to certifying at least 8/10 products of its brand/sub-brand to assure consumers that the NATRUE seal cannot be used selectively only for certain “hero” products and

– establishes a robust category scheme to ensure that innovative formulas continue to align with transparent natural and organic claims.

NATRUE has established guidelines for on-pack labelling of the seal for all label users to promote a correct and transparent use of the NATRUE Label. As part of our commitment to support product transparency, the certification level, the list of ingredients and other details about NATRUE certified products are available in real time on NATRUE’s website database to help consumers before, during and after purchase. NATRUE provides consumers supporting information about the products and help them identify brands with NATRUE certified products available on the market worldwide.

What are the steps in terms of certification process for finished products and raw materials?

The NATRUE scheme is built on a two-step certification process. First, a documentation check is carried out to verify if ingredients/raw materials formulations are compliant with the NATRUE criteria on the basis of documentation provided by the applicant. If the documentation confirms that the formula complies with the NATRUE criteria, the second step is an on-site audit, which aims to verify that the certified products/raw materials comply with the formula, as well as to ensure that the production is performed following NATRUE’s criteria requirements. Production must be traceable, i.e. the audit must reveal that the ingredients declared are purchased and used in the declared qualities and quantities. If these two steps are evaluated successfully, the finished product/raw materials are officially certified according to the NATRUE standard with a certificate valid for 2 years, and they are included in an online database (updated in real time) on NATRUE’s website.

NATRUE’s certification process is carried out by a network of NATRUE Approved Certifiers (NACs), which are recognised certification bodies accredited to the NATRUE scheme. This third-party certification system ensures the impartiality and transparency of the NATRUE scheme.

What is the benefit to buy natural and organic cosmetics products?

Baseline regulation does not define the characteristics of a natural and organic cosmetic or when a claim ‘natural’ / ‘organic’ is being misleading. Private standards can establish label criteria to ‘fill the gaps’ and to support the ethics and values of those that established the standard and the sector it represents.

Apart from their high quality and efficacy, natural and organic cosmetics align themselves with the purchasing decisions of more and more consumers looking for sustainable and ethical products. Nevertheless, consumers should remain vigilant to fully assess the qualities of a product claiming to be ‘natural’ or ‘organic’. NATRUE’s criteria reflects the commitment of all NATRUE members and label users to offer consumers natural or organic cosmetic products which are not only in line with their expectations in terms of formulation, but which also reflect values that are integral to the sector, including environmental protection, biodiversity preservation, sustainability and ethical trade. As such, for consumers investing in an authentic natural or organic cosmetic, choosing a NATRUE certified product represents more than just buying another cosmetic product, as this purchasing decision can help supporting animal welfare, ethical and sustainable raw material sourcing and the protection of the environment, all greatly promoted by NATRUE members and label users.

The values of the NATRUE Label criteria establish a system for rigorous and independently third-party control guaranteeing maximum natural and organic content levels in every product, hand-in-hand with a qualified commitment from brands to effectively combat greenwashing and misleading claims, together with environmental protection requirements.

Allergens are identified on cosmetics packaging but often, small sized packaging do not allow to precisely indicate them. What are NATRUE’s recommendation to avoid this issue?

Independently of the formulation as a natural, organic or conventional cosmetic product, all products must comply first and foremost with the basic requirements of Cosmetics Regulation (EC) No 1223/2009, particularly with regard to their composition, safety, efficacy and labelling requirements.  According to EU law, established contact allergens within the fragrance blend, as identified by the INCI ‘parfum’, must also be labelled on-pack on the INCI list by law when their concentration exceeds defined limits. These ingredients are found at the end of the INCI list. The purpose of this additional labelling, which is mandatory for every product on the EU market, is to notify consumers already sensitised to the presence of an established contact allergen. Currently there are 26 established fragrances allergens; some are natural, some are synthetic.

Following a 2012 Opinion by the EU Commission’s independent risk assessment body, the Scientific Committee on Consumer Safety (SCCS), the EU Commission has recently opened a public consultation to evaluate the future possible regulatory options in light of an expected increase in the number of allergens to be listed on cosmetic products. The options include both on-pack and off-pack (or electronic) labelling proposals.

In light of existing and evolving legislation, to assist producers and provide a point of access to information on fragrance allergens for sensitised consumers, NATRUE’s online database facilitates e-labelling of the full INCI listing, which can be found in the product description. Consumers can hence easily retrieve electronically the list of ingredients of NATRUE certified products, including the declarable fragrance allergens, often indicated by the mention ‘from natural essential oils’. For producers, this database provides a platform to support any additional e-labelling for consumer notification or characteristics of the product for promotion purposes.

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