Choosing an Organic Standard: Part 1
Choosing the right organic standard for your market and brand can be the difference between products that work and products that will never be manufactured. BPI Labs has years of experience working with our authorized certification agent, Oregon Tilth, in the development and certification of organic personal care products.
If you don’t know who Oregon Tilth is or how products become certified organic, then read our article here.
You’ll read the following in this article:
- The difference between USDA NOP and NSF/ANSI-305 certifications
- The difficulty in using USDA NOP as a standard for personal care
- The creation of NSF/ANSI-305 as an organic standard for personal care
- The market’s readiness to adopt NSF/ANSI-305 for personal care
The USDA NOP Standard
The USDA Organic standard, formed by the USDA’s National Organic Program (NOP), is regulated with agricultural products in mind. According to the USDA NOP, personal care products are only eligible to be certified USDA Organic and to use the USDA label on product packaging if the product is made of at least 95% food-based ingredients (National Organic Program). So, achieving USDA Organic certification is a challenging task as the majority of personal care products cannot be made up of 95% food-based ingredients and still be an efficacious and user friendly product.
One of the great difficulties in producing efficacious personal care products is in the creation of preservatives that can keep your product within the Food and Drug Administration’s (FDA) guidelines for product contamination. Organic matter is a natural breeding ground for all manner of microbiological cultures including some pathogens. The FDA’s guidance on Title 21 of the CFR suggests that zero pathogens can be present and under 500 colony forming units (CFU) for products applied to the face and 1000 CFU’s for products applied to the body. If microbiology is found in excess of those guidelines then the FDA considers your product adulterated and will take action to prosecute your company under federal law.
If microbiology is found in excess of those guidelines then the FDA considers your product adulterated and will take action to prosecute your company under federal law.
The USDA’s focus is on the preservation and consumption of agricultural products, and their guidelines leave out many possible candidates for organic personal care ingredients and preservatives of personal care product. However, BPI Labs has found some suitable ingredients and preservatives that can be considered USDA NOP qualified, but they are not guaranteed to work in many personal care products. Consequently, formulation work for an organic product that satisfies the USDA’s NOP standards is difficult and usually prolonged.
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