By Darrin C. Duber-Smith, MS, MBA
One of the greatest points of confusion in the world of personal care products occurs when the word "organic" is used on the label to describe the nature of a particular product. As we know, the words "organic" and "natural" do not necessarily describe the same types of products, but it is important to remember that an organic product is always a natural product, and that natural products (generally described as a lack of synthetically derived and/or processed ingredients) are rarely organic. An organic product goes beyond natural, defining not only a method of suatainable agriculture, but also a lack of synthetic pesticides, herbicides, heavy metals and other undesirable compounds that could be found in otherwise "natural" products. In the food world, organic has been very strictly defined due to the years of work that many interested parties at all levels of business and government have invested, but in the personal care products industry, there is much room for improvisation among marketers. To clear the confusion and establish industry standards for topical products, as has already been done with food products, the Organic Trade Association (OTA) formed the Personal Care Organic Standards Task Force (PCOSTF) to tackle the issue of what should and should not be labeled as organic. The PCOSTF is a subset of the OTA's Quality Assurance Committee (QAC), a body that oversees the Association's position on various standards. A growing number of personal care companies have been making organic label and marketing communications claims for many years, so the OTA, in order to check the current and potential abuse of this important moniker and provide meaningful differentiation for suppliers and consumers, set out to affirm that, like foods, any organic personal care product label claim of organic must contain at least 70% of such ingredients. According to OTA's Associate Policy Director Tom Hutcheson, "The personal care people are going through the same process that the food people recently went through. The primary question at hand is to decide whether or not we want a small niche market based on product purity or a much lager market based on process verficiation." The organic food people decided on the latter "process" approach and the result has been the cultivation of a growing market consisting of an increasing consumer base that demands these products, as well as the commensurate increase in agricultural acreage devoted to organic products. This transformation as well as the "process" approach, in the mind of this author, has improved environmental conditions and biological health and provided smaller farmers with the requisite product differentiation in order to become competitive by offering a product the "big boys" cannot provide. Legislatively speaking, all of this completed work has resulted in a clear definition with regard to organic food labeling that is characterized by strict control of both the process and the materials used in the process. This ultimate certification applies to process and not what is in the end product. Why? Simply because it is impossible to avoid marginal "undesirables" contamination of organic ingredients due to the nature of agriculture. This marginal contamination will not affect the organic labeling as long as the process of organic farming, etc., has been unadulterated. Ultimately, this is seen as the only way to achieve a meaningful distinction if we are to have organic nomenclature at all. Thus, since it appears impossible that an organic product can be completely free of all undesirable residues, the process defintion makes perfect sense in fostering a larger industry that can achieve greater positive impact on the environment and those who depend on it. According to Hutcheson, the PCOSTF should be done within a couple of months, and its recommendations will be presented to the QAC, which includes representatives from all sectors of trade. After this review, the results will be posted for a 90-day period of public comment after which time the OTA Board will vote on its approval. The resulting industry self-regulation should clear any confusion related to what should be labeled as organic and what should not in the personal care industry. Be aware, however, that at the present time there is nothing precluding a marketer from making an organic label claim regardless of product content. In the temporary absence of industry standards, it is difficult to take the case of an alleged violator in front of government regulators under charges of violating policies on misleading labeling. Until the OTA finishes its important work, the rule of the day is truly "caveat emptor."
Darrin C. Duber-Smith, MS, MBA, is president of Green Marketing, Inc., a Colorado-based strategic planning firm offering marketing planning, marketing plan implementation, and other consulting services to natural products companies in all stages of growth. He has 15 years of specialized expertise in the natural products industry and is also Visiting Assistant Professor of Marketing at the Metropolitan State College School of Business in Denver, CO, as well as executive director of the International Association of Natural Product Producers. He can be reached at [email protected]