USDA Certified Organic Choices
Some of the most frequent questions we hear at Essential are about getting products certified “organic.” Consumers and purveyors both love the USDA and the Oregon Tilth (OTCO) seals, and of course, want to have them on the outside of every bottle! Organic Certification increases your product’s cache in today’s skincare-glutted marketplace, and also reassures you and your customers that the ingredients in your bottle or jar meet a higher standard of responsible growing and sourcing than conventionally grown ingredients. For purposes of this blog, we’re only talking about botanical ingredients, not animal by-products.
Before we go too far, let’s talk briefly about the four types of organic certification available here in the United States. The first three apply to food products but are also used in cosmetic and personal care products. The fourth is for personal care and cosmetics, only. We’ll get into more detail a little further into the blog.
- 100% Organic – 100% of all ingredients are Certified Organic
- Organic – 95% of all ingredients (not including water) are Certified Organic; the other 5% are on the “acceptable” list of ingredients
- Made with Organic Ingredients – a minimum of 70% of the content is Certified Organic; the other 30% are on the ‘acceptable” list of ingredients.
- NSF/ANSI 305 Contains Organic Ingredients – A designation specifically for Personal care products containing a minimum of 70% organic ingredients.
Well Virginia, MAYBE you Can Get Organic Certification
My favorite analogy for securing USDA Certified Organic is this: you can go to law school, but unless you take and pass the bar exam, you cannot call yourself a lawyer! This is the same with the term organic. Until the ingredient or product has been USDA certified, it’s not organic in the United States. The same holds true for other countries and regions around the world.
Let’s say you want an organic ingredient, for instance, USDA Certified Organic Tea Tree Essential Oil, added to a finished product, such as our USDA Certified Organic Barrier Balm, (we love to do that in our lab!). Essential doesn’t carry USDA Certified Organic Tea Tree Essential Oil, but it is available from other suppliers. There are several steps to follow.
- Ensure that the ingredient you supply is already USDA Certified Organic, or has an equivalent certification, such as Australian Certified Organic.
- Ship directly from the supplier to our facility, (aka drop shipped) so that it does not get handled by a non-certified facility, such as your non-certified kitchen at home or a non-certified warehouse.
- Send all provider documentation showing existing certification to our compliance team.
Once we have your ingredient and documentation in hand, we will submit to OTCO on your behalf. If they certify it, then it becomes an organic ingredient when used by Essential, and is added to our Certification Document for use here in our facility. If you take this ingredient to another USDA Certified Organic facility, this process will be repeated.
Once approved, the ingredient can carry the word “Organic” on the ingredient deck. If you want a finished product containing this ingredient to be Certified Organic, the final product, documentation for all ingredients, and your label must be submitted to OTCO for consideration as a Certifed Organic product under one of the first three organic certification types we mentioned at the top of the article.
Getting Hiccups Along The Way
If your supplier can’t provide you the documentation proving USDA certification or an equivalent certification, such as EU Organic, it is not an organic ingredient, even though your provider says it is. That’s the annoying part about “organic” being a legally defined term.
If an ingredient is handled or opened in a non-certified facility (such as a non-certified holding facility), and then sent to us for use, the chain of custody is broken, and the ingredient can no longer be considered certified organic. Therefore, your entire product is then out of compliance for certification.
When you talk to us about getting your ingredients certified, we will pull out our big megaphone and yell” Beware!” So don’t be surprised or offended. Just because someone says it is certified organic, doesn’t mean it is! There are lots of phony certificates around (we’ve seen our fair share), and we can guide with concrete steps to take to protect yourself. We had a customer last year who purchased a very expensive oil and sent it to us for his product. His supplier swore this oil was Certified Organic by a local certification body in his country. The supplier ultimately refused to send the right paperwork, and the ingredient was denied USDA Certified Organic status. Big bummer. We hate to make those phone calls.
So do yourself a favor and ask for their Certificate of Organic Ingredients before you buy. That way you can see for yourself that what you’re buying is what you want. Our compliance team can help, too.
We Love Organic Growers
If you think there are numerous hoops for certification in organic cosmetics, there are even more for growers. This makes finding ingredients that have been certified organic by the USDA, or other certified agency, challenging. It’s also one of the reasons we love our Essential purchaser, Michelle. She works so hard all day to find only the purest, best, highest quality ingredients. And like you, we prefer certified organic ingredients.
Essential Oils, though, are often wily beasts. They grow all over the world, and we source them from all over the world! Not every country has the agricultural oversight needed to make organic certification possible. And, too, some ingredients will just never be available as certified organic because of the way its grown and harvested. Take Brazilian Rosewood (Aniba rosaeodora) Essential Oil—steam distilled. A beautiful EO with a slightly spicy, floral and sweet smell. Depending on where it is grown, how it is harvested and processed, some of this EO may never qualify for organic certification.
Brass Tacks: 5 Ways Organic Gets on Your Label
There are five different organic choices when you talk about Certified Organic status and adding that to your labels and packaging. Four use the USDA Certification Program and one through the NSF, which is designed specifically for personal care products, including cosmetics.
Certification: “100% Organic”:
What this means: Every ingredient in your product is 100% USDA Certified Organic (excluding water and salt).
How you Get it:
- Submit your formula, your product, and your label (with seals in place) for our compliance review, a
- We submit all of that to OTCO
- OTCO certifies it
You can: Celebrate! And of course, use the term “organic” and the USDA and OTCO seals on the front panel of your product’s label.
Certification: “Organic”:
What this Means: At least 95% of your ingredients are 100% USDA certified organic (excluding water and salt). All other ingredients are on the “acceptable list” of ingredients, as outlined by the USDA.
You must also: Prove there are no USDA certified organically grown ingredients to use in place of the conventional ingredients making up the remaining 5%,
How you Get it:
- You submit your product and label (with seals in place) for our compliance review;
- We submit it to OTCO;
- OTCO certifies it!
You can: Shout Fantastic! And of course, you can use the term “organic” and the sale USDA Certified and OTCO seals on the front panel of your product’s label.
“Made with Organic Ingredients”:
Designed for products with 70% or more USDA Certified Organic ingredients. This is probably the most challenging level of labeling to understand. You might see products on our website with the percentage of organic content listed as 89% and say to yourself: well, the percentage is at least 70% organic content, and so I should be able to say it’s “made with organic ingredients” on my label! However, “Made with” has the same legal oversight as “100% Organic” or “Organic.” If your product includes even one tiny percentage of an ingredient not on the Acceptable List of USDA organic ingredients, then your product will not qualify for even “Made With” status.
What this Means: At least 70% of ingredients are USDA Certified Organic Ingredients. Your products/ingredients must undergo the same certification process as if you were going to use the USDA Certified and OTCO Certified seals on your labels. All other ingredients are on the ‘acceptable” list of ingredients.
How you Get it:
- You submit your product and label for our compliance review;
- We submit it to OTCO.
- OTCO Certifies it:
You can: use “Made with Organic” on your labels though you cannot use the seals.
To use one of Essential’s lovely products as an example, our Baby Crème so luscious and is chock full of organic content at 80%. However, because of the preservative we use to make it (even though it’s in the product at less than 1%), this gorgeous, rich, beautifully safe crème will never qualify for even “Made with Organic Ingredients” status.
Products with Organic Ingredients but that aren’t Certified
If your product has less than 70% USDA Certified Organic Ingredients or includes ingredients, not on the acceptable list, then you can use the word organic only on the back panel in your ingredient list. This is the only time where the regulated term is being used more specifically as a way to describe the ingredient, but it is still a legal term. The word organic cannot appear anywhere else on your label, and you cannot use the seals at all. You can say “80% organic content” on the back panel, though! Right now, most of Essential’s wholesale products fall into this category.
NSF/ANSI 305 “Contains Organic Ingredients
The NSF (founded in 1944 as the National Sanitation Foundation but now calling itself NSF International) created a program to work with the personal products and cosmetics industry in 2009. Since the USDA seal and OTCO are primarily for agricultural products, we can see how obtaining certification for skincare and cosmetics can be challenging! So through the NSF program, a product may contain ingredients that the USDA may not have certified as organic. For instance, lye. Lye is required for soap to lather (a process called saponification), and it might still qualify for the NSF/ANSI 305 designation even if it doesn’t qualify for “Made with Organic Ingredients” certification. To obtain this certification, Essential still must submit your formula to OTCO, who in turn can submit it to the NSF for review. If NSF says your formula meets their criteria, then you can use their mark on your labels and also use the terminology “contains organic ingredients!” Yay!
Organic Shouldn’t be Part of your Product or Company Name
We’ve mentioned that non-certified organic products can identify organic ingredients in the ingredient list on the back panel, and can indicate the total organic content as a percent of the product, also on the back panel of your labels. The National Organic Program (NOP) does not otherwise allow the word “organic” to be used in product labeling. They have not attempted to prevent companies from using the word “organic” in their company names, but they may. In that event, it will not matter what permutation of the word “organic” is being used. “Organic” or “organically” will make no difference. As a company with very strict FDA and USDA compliance, we can’t tell you not to use the term in your name or even your tagline, but using caution is always a good way to make the decision!
How We Can Help
When you work with Essential, you can select from more than 50 certified organic ingredients available directly on the website at wholesale prices. You may also choose from a line of seven beautiful USDA certified organic finished products that are ready for filling and labeling. All carry the USDA and OTCO seals. All Essential stock bases that can be certified “100% Organic,” “95% Organic” or “70% Made with Organic Ingredients” have been through the appropriate certification process, making it easier for you to do so.
We know that the world of OTCO and USDA can be complicated and maybe even intimidating, but our crack team of customer service, compliance, and purchasing agents will always look out for your best interest and help make it as clear and straightforward as possible. You can always ask more questions at our website or by giving us a call! We’re here to help!
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