Labeling Organic Soap
We received an email from a customer with a link to another company that claims to sell "organic soap.
"Their soap says the words "organic soap" right on the label and your soap only says "made with organic extra virgin olive oil and herbs." So I assume that your soap is not really organic."
This email highlights a major problem in the soap making and personal care industry -- false and misleading labeling.
The word “organic” is currently one of the most popular terms to include on all varieties of personal care products and can be seen displayed.
However, this word actually has a pretty narrow definition.
In the US the word "Organic" is controlled and governed by the USDA National Organic Program (NOP), the government organization that sets the standards for Certified Organic production in the United States.
Although the company referred to in the customer email was NOT a USDA certified organic company, their soap was labeled “organic” and the word organic was also used in their company name. Which is technically 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's National Organic Program (NOP) has specific rules for what makes a product organic as well as how to label organic products.
Within the NOP, there are three levels or tiers of organic certification. Classification within these levels is based on the percentage of a product’s organic ingredients vs. total ingredients, not counting water or salt and labeling rules based on these three levels of certification.
100% Organic is exactly what the name says. Products can be labeled “100 percent organic” only if they contain 100% organically grown and produced ingredients (excluding water and salt).
All soaps, even those made with certified organic ingredients, are made with sodium hydroxide (lye). Although no lye (sodium hydroxide) is left in the finished bar of a properly made soap, it is impossible to make real soap without sodium hydroxide as an ingredient. Unfortunately, organic lye does not exist.
So, there is no such thing as a “100% organic” soap.
Notice the word "Organic" on the label of this soap bar.
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.
According to the FDA real soap is defined as being made from a fat (vegetable or animal) and an alkali (sodium hydroxide).
The chemistry of natural soapmaking requires about 8 to 15% lye/sodium hydroxide (when excluding water from the recipe).
Even though no lye remains in the finished product, the lye is counted in the total weight when determining the percentage of organic ingredients.
Since no real soap can be 95% organic, as a USDA Certified Organic company we are not allowed to use the words "organic soap" on the label.
According to the labeling rules of the USDA use of the word "Organic" is not permitted on the label of any product that has not achieved USDA Organic certification.
A simple equation is used to calculate the percentage of certified organic ingredients in any product. The weight of organic ingredients divided by total weight of all of the ingredients (excluding water and salt) determines which label can be used. Either 100% Organic, Organic (95%+) or Made with Organic Ingredients (70% +).
In Europe, the lye is sometimes 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 90% organic, due to the sodium hydroxide, (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."
Buying a soap with the USDA organic certification "Made with organic (ingredients)" means that it meets requirements for organic growing, production, handling, storage, and processing practices and is guaranteed to be free of toxic pesticides, genetically modified organisms (GMOs), sewage sludge, and irradiation.
So, was our customer right in questioning the labeling discrepancy?
She was correct but for the wrong reason. I checked out the link the customer sent to the other company. The company was not a USDA certified organic company, the soap was NOT organic, and should not have been labeled organic.
Simply put, under USDA rules, there is no such thing as "organic soap." The most a consumer can hope to buy is a soap that is "made with . . . organic ingredients."
Notice the ingredient list on a bar of our Milk & Honey Baby Soap. All of the ingredients are organic except the lye and the goat milk. (We use milk from free-range goats that eat wild vegetation which can not be certified organic.)
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 by 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?
However, many companies label their soaps as organic or all natural, but still contain synthetic ingredients such as chemical fragrances or dyes. The only way to ensure a soap is truly made with organic ingredients is to look for USDA organic certification.
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!
Learn More Blog: "A Few Words About Organic Soaps and Shampoos"
Our Unofficial Seal
Although not an official label, we sometimes use "natural ingredient" seals on some of our Soaps and Shampoos, like the Dead Sea Spa, 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.
Unlike in some other countries, in the United States Organic certification of personal care products is based on the standards for organic farming and agriculture. There is no branch of organic certification for personal care products.
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 Bamboo Charcoal, 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.
Please Note: According to USDA NOP there is an exception to their organic labeling rules. Companies whose gross income from organic sales is less than $5,000 (per year) do not need to be certified in order to sell, label, or represent their products as organic. These operations must still comply with all other USDA organic regulations. Exempt operations may use the word “organic,” but may NOT use the USDA or any organic seal on their products