We received an email from a customer with a link to another company that claims to sell "organic soap."
The customer wrote,
"Their soap says the words "organic soap"
right on their label and your soap
only says "made with organic oils and herbs."
So I have to assume that your organic soap
is not really organic."
This email highlights a major problem in the soapmaking and personal care industry -- false and misleading labeling.
Although the company referred to in the customer email was not a certified organic company, their soap was labeled “organic” and the word organic was used in their company name. Which is not allowed!
The National Organic Program (NOP) of the United States Department of Agriculture (USDA) has specific labeling rules, as I will discuss below, but there is no effective enforcement of these rules for soap or personal care products. As a result, the word "organic" on personal care products often means very little.
However, when you see the USDA symbol or the words “Certified Organic by . . .” with the name of a USDA approved certifying agency, it provides a guarantee that the ingredients, as well as the manufacturing process, are truly organic as defined by the USDA.
Although many companies claim to sell organic products, most are not USDA Certified Organic companies. Since they are not held accountable by any certifying agency, they simply do not follow labeling regulations.
Chagrin Valley Soap & Salve has chosen to be a USDA Certified Organic company.
In doing so we are REQUIRED to follow the rules
for labeling set forth by the National Organic Program of the USDA.
The USDA has specific rules for organic labeling based on three levels or tiers of certification...
Products can be labeled “100 percent organic” only if they contain 100% organically grown and produced ingredients (excluding water and salt).
Although no lye (sodium hydroxide) is left in the finished product, it is impossible to make real soap without lye as an ingredient (click here to learn more) and organic lye does not exist. So, there is no such thing as a “100% organic” soap.
Products can be labeled as "organic" if 95% to 99% of the ingredients are organic (excluding water and salt). The remaining 5% must consist of nonagricultural substances on the USDA approved ingredient List.
The chemistry of soapmaking requires about 8 to 15% (when excluding water from the recipe). Even though no lye remains in the finished product, the lye is counted in the organic percentage. Since no real soap can be 95% organic, we are not allowed to use the words "organic soap" on the label.
In Europe, the lye is NOT counted as an ingredient in the organic percentage. As a result, soaps can be labeled as Organic. For example, you will see soaps certified by Ecocert labeled as organic.
Made With Organic Ingredients
Products can be labeled "made with organic ingredients" if at least 70% organic ingredients are used(excluding water and salt). The remaining 30% must consist of nonagricultural substances on the USDA approved ingredient List.
Since our "organic" soap is about 87% to 90% organic (remember water is not included), this is the proper labeling requirement.
The products may display the certifying agent's logo but not the USDA organic logo. Our certifying agency is OEFFA (The Ohio Ecological Food and Farm Association). Their logo is displayed on our "organic" soaps and shampoos. We are also required to list from one to three organic ingredients on the label. For example, "Made With Organic Shea Butter, Coconut Oil, and Calendula."
So, was our customer right in questioning the labeling discrepancy? Yes! Simply put, under USDA rules, there is no such thing as "100% organic soap" or "organic soap" when using water in the recipe. The most a consumer can hope to buy is a soap that is "made with . . . organic ingredients."
But the labeling dilemma does not stop there. According to USDA rules, the word "organic" should not be used on a label in any context (except in the ingredient list), or even on a website to describe any product, if the manufacturer is not certified by the USDA.
By now you are probably asking why and how do companies get away with misleading labels? While some companies simply do not understand the labeling regulations, others are taking advantage of the increasing demand for "organic" to sell their products and intentionally mislabel to lure the customer. These infractions, whether intentional or not, go unchecked because there is no "organic police" for the personal care industry. The use of the word "organic" on the labels of personal care products is not held up to the same rigorous standards as organic labels on food.
Be An Informed Consumer
Consumers are demanding more organic products. While sales for conventional personal care products have risen about 10% per year, sales of organic products have increased over 20% per year.
In an attempt to capitalize on the organic boom, many companies now sell "organic" products. However, when you purchase soap, skin or hair care products from a company using the word "organic" on the label or website without USDA Organic Certification, where is your guarantee? Are these companies truly selling organic products? Or are they simply selling the "word" organic?
Where is the accountability? Organic certification is the only way you can be sure a company's product truly complies with organic standards. If there is no certification, there is no proof, no accountability and technically these products are not organic as defined by the USDA!
Click here to read, "A Few Words About Organic Soaps and Shampoos"
Our Unofficial Seal
Although not an official label, we use these homemade seals on some of our Soaps and Shampoos, like the Dead Sea Spa, Rhassoul Clay & Yogurt, Loofah Pumice Foot Soap, Mud & Clay and our Bamboo Charcoal soaps and shampoo because they do not qualify for the "Made With Organic Ingredients" label described above.
Although these soaps and shampoos are made with certified organic ingredients and meet the same rigorous standards as those required for our "Made With Organic Ingredients" products, they contain ingredients like Dead Sea Mud that are not listed on the NOP National List of Allowed and Prohibited Substances (National List) for non-agricultural ingredients.
Organic certification of personal care products is based on the organic farming and agriculture standards. Likewise, the list of allowable non-agricultural ingredients (like clay, pumice, mud etc) is also based on those raw materials used in agriculture.
Since clays like kaolin and bentonite have some agricultural use, they appear on the list. Unfortunately natural Rhassoul Clay, Pumice, Dead Sea Mud, etc. are not used in farming and thus do not appear on the list.
For these products, we may only list organic ingredients on the information panel of the packaging or the ingredients list on the website. These products cannot display the USDA Organic seal or our OEFFA seal.
Since we are a USDA Certified Organic company we MUST follow all of the rules. We are not even allowed to use the words "Made With Organic Ingredients" on these products!