Certified Organic Skincare & Labels Decoded

Let's Talk About Certified Organic Skin Care & Organic Labels 

We receive a lot of questions about organic labels and symbols — and it’s no surprise. The rules can feel confusing, especially when they’re applied to products that aren’t food.

Before we get into the different labels and classifications, it helps to understand what “organic” actually means.

How the USDA Defines “Organic”

In the United States, the term organic is defined and regulated by the U.S. Department of Agriculture (USDA) through its National Organic Program (NOP). The NOP is the federal system that sets and enforces the standards for how organic products are grown, handled, and labeled.

In short, the NOP is the rulebook — and the referee — for all organic claims in the U.S.

The National Organic Program (NOP), under the authority of the Organic Foods Production Act of 1990, created and maintains the National List of Allowed and Prohibited Substances (National List) as a tool for managing the materials used in organic production.

The NOP standards were created for agriculture and food — not cosmetics — but they are the only federally recognized organic standards we have.

That means:

• There are no separate organic standards for personal care products.
• If a skincare or soap company wants to make an organic claim, it must follow the same rules used for organic food.

As USDA Deputy Secretary Kathleen Merrigan explained:

“The USDA regulates organic personal care products only if they are made up of agricultural ingredients. We have no standards for personal care products and have no plans to develop standards at this time.”

In other words:
The USDA doesn’t regulate cosmetics — but it does regulate the word “organic” if a skincare company using agricultural ingredients is certified organic. (More about that later)

Organic Begins on the Farm

Organic certification starts long before an ingredient reaches a product—it begins with how it is grown.

To qualify for USDA Organic certification, farms must protect natural resources like soil and water and follow strict ecological practices. A few examples:

• Many organic farms plant cover crops to enrich soil, prevent erosion, suppress weeds, and maintain fertility.
• Land must be free of prohibited chemicals for three years before crops can be certified.
• GMOs and growth hormones are not allowed at every stage.
• Synthetic fertilizers or sewage‑sludge fertilizers are prohibited
• Irradiation of finished products is not permitted
• Farms must maintain clear boundaries and buffer zones to prevent contamination from neighboring non‑organic land.

Organic farming is designed not only to produce ingredients but to protect soil, conserve water, support biodiversity, and avoid contaminating land and groundwater.

From Harvest to Finished Product

Once harvested, organic ingredients must continue to be handled with the same level of care.

• Oils, herbs, and botanicals must be processed without synthetic solvents or shortcuts
• Equipment and facilities must be cleaned using only approved substances
• Every step — processing, storage, packaging, labeling — must protect the ingredient’s organic integrity.
• Full traceability is required. Every claim must be verifiable and auditable.

How Organic Certification Applies to Soap and Skincare

In 2002, the USDA clarified that the National Organic Program would extend beyond food to include products made with agricultural ingredients—including personal care products.

Because there are no cosmetic‑specific organic standards, companies fall into two categories:

• Those who choose to follow USDA organic rules and get certified
• Those who use the word “organic” loosely because no organic oversight for cosmetic‑specific rules exists

This is why understanding the USDA categories and labeling is so important.

Who Does the Certifying?

Any farm, processor, repackager, or manufacturer that wants to sell or label products as organic must be certified by a USDA‑accredited certifying agency. These agencies audit companies annually to ensure that every ingredient and every step meet NOP standards.

Chagrin Valley Soap is certified by OEFFA (Ohio Ecological Food and Farm Association) — a nonprofit, USDA‑approved agency that verifies our organic ingredients and manufacturing processes.

Understanding Organic Labeling

The USDA uses a structured labeling system based on the percentage of organic ingredients in a product (excluding water and salt-NaCl). 

There are four categories of organic claims, but only two are allowed to use the USDA Organic Seal.

1. 100% Organic

Products may be labeled “100% Organic” if every ingredient (excluding water and salt) is certified 100% organic.

• May display the USDA Organic Seal
• May use the phrase “100% Organic” on the front label
• All agricultural ingredients must be certified organic
• The certifying agent must be listed on the label — "certified by. . . "

This is much easier to achieve for single‑ingredient items (like coffee or adzuki beans).
For blended formulations, every ingredient must be 100% organic — even 99.99% is not enough.

2. Organic (95–99.9% Organic Ingredients)

Products may be labeled “Organic” if 95–99.9% of ingredients (excluding water and salt) are certified organic.

• Remaining 5% must be on the USDA National List of Allowed Non‑Agricultural Substances.
  
• If an ingredient is available organically, it must be used — cost is not an excuse.
• All agricultural ingredients must be certified organic
• May use the USDA Organic Seal
• The certifying agent must be listed on the label — "certified by. . . "

3. Made With Organic 70–94.9% Organic Ingredients

Products labeled “Made with Organic ___” contain 70–94.9% certified organic ingredients (excluding water and salt).

• Remaining ingredients must be on the National List of Allowed Substances
  
• Must be certified by a USDA‑accredited agency
• Cannot use the USDA Organic Seal
• Cannot use the word “organic” as a product claim (for example, “organic soap”)
• May list up to three of the "Made with organic" ingredients on the principal product display panel
• May display the certifier’s logo (ours is OEFFA)
• The certifying agent must be listed on the label — "certified by. . . "

This is the category most often misunderstood — especially in skincare.

4. Specific Organic Ingredients (Less Than 70% Organic)

In addition to products that fall under one of the three regulated organic label claims above, some products contain less than 70% organic ingredients but include the organic ingredients used in their ingredient lists. 

• May list certified organic ingredients in the ingredient list
• Cannot use the USDA Organic Seal
• Cannot display the certifier’s logo (ours is OEFFA)
• Cannot claim “organic” on the front label, website, or marketing materials
  
• The "specific organic ingredient" claim is only verified if the company is certified organic

If a company is USDA certified, any ingredient listed as “organic” is still verified by its certifier — but neither the label, the website, nor the marketing is allowed to make that verification claim.

Recognizing Legitimate Organic Labels and Claims

Now that you understand the organic labeling tiers, the next question is usually: why do some of our products use the USDA Organic Seal, while others display the seal of OEFFA, our USDA‑accredited certifying agency?

Both seals indicate that the product has been independently verified and certified under the USDA’s National Organic Program.

The difference is not about quality—it’s about which labeling category the product qualifies for.

When the USDA Organic Seal Is Allowed

The USDA Organic Seal may only appear on products in the 95–100% organic tiers.
These products are also allowed to use the word “Organic” on the front label.

Whenever possible, this is the standard we strive to meet—and one we are proud to achieve across much of our product line.

When the Certifier’s Seal (OEFFA) Is Used

Products like our "organic" soaps and shampoo bars are 85–93% organic and fall into the “Made With Organic Ingredients” category.

Because the soapmaking process requires lye — a non‑agricultural ingredient that makes up more than 5% of the formula — they cannot meet the 95% threshold, even though the rest of the ingredients are organic.

These products are fully certified organic, but they cannot use the USDA Organic Seal or the word “organic” as a standalone product claim (for example, “organic soap”)

Instead, they display the seal of our certifying agent and the words “Certified Organic by OEFFA.”

What Both Seals Mean

Both seals communicate the same thing:

The product has been independently verified to meet strict, federally regulated organic standards.

Why Aren’t All of Our Products Certified Organic?

Over the years, we’ve added more and more certified organic products to our line. But some of my favorite formulas use ingredients that simply do not exist as certified organic. 

Not because they’re unsafe, but because the USDA organic system was designed for agriculture, not skin care.

When Ingredients Don’t Fit the System

Ingredients like cocoa butter work beautifully within the system. Since they are used in both food and skincare, organic versions are widely available.

But others, such as some clays, mineral salts, and bamboo charcoal, are not commonly used in food.

So there is neither the demand nor the framework for them to exist as certified organic.

Agricultural vs. Non-Agricultural Ingredients

• Agricultural ingredients come from plants or animals and are carbon-based (like oils, herbs, and butters)
• Non-agricultural ingredients are mineral or naturally occurring substances (like clays, salts, baking soda, or pumice)

The USDA allows certain non-agricultural ingredients—but for agricultural ingredients, the rule is strict:

If an organic version exists, it must be used.

When an Agricultural Ingredient Isn’t Available as Organic

According to the NOP, the 100% Organic and “Organic” (95%) categories require all agricultural ingredients to be organic.

If a certified organic version of an agricultural ingredient is not available—such as wild-harvested botanicals like yucca or alkanet root—the product cannot qualify for the highest organic tiers.

Instead, it must be labeled “Made With Organic Ingredients” and may display only the certifying agent's seal (in our case, OEFFA).

Even then, we must still provide documentation showing that these ingredients were grown and processed without:

• toxic pesticides
• GMOs
• sewage sludge
• irradiation

A Perfect Example of How Organic Rules Don’t Always Fit Skincare

Some ingredients simply don’t fit neatly into the agricultural-based rules.

Magnesium hydroxide is my favorite example.

It’s a safe, effective ingredient used in natural deodorants—and it does appear on the USDA’s allowed list.

But only for one very specific purpose:
to give to cows when they have an upset stomach

Because cow indigestion is its only approved use under NOP rules, it cannot be used in any tier of certified organic skincare.

This means that products like our Sensitive Skin Deodorants cannot be certified organic, even though all of the other ingredients are certified organic.

It’s a small—but telling—example of how standards designed for agriculture don’t always translate cleanly to personal care.

Why Organic Still Matters

Organic certification isn't simple and was never designed for skincare—but it remains the clearest, most rigorous standard we have for defining what “organic” truly means.

It asks more. It requires more. And sometimes, it doesn’t fit perfectly.

For us, choosing to work within that system is about more than meeting requirements.

It’s about honoring the integrity of our ingredients, respecting the process behind them, and giving our customers something real—something they don’t have to question.

And while the labeling system can feel complicated at times, it was never meant to be a puzzle—it was meant to bring clarity.

Because in the end, it’s not just about what’s on the label.
It’s about whether the word “organic” still means something you can trust.

• Why Most "Organic" Soap Bars Aren't Labeled Organic
• Why We Chose USDA Organic Certification—and Why It Matters
• Why We Believe in Natural Skin Care

This article was originally published in 2017 and updated in 2021. It has since been reviewed and refined to improve clarity and expand on key details. The principles and standards discussed remain the same.