Some formulators say pure, undiluted hydrosols are a critical ingredient in the development of organic personal care products. But what constitutes a hydrosol and how its presence in a lotion, shampoo or conditioner is reflected on the label is being fiercely debated as the Organic Trade Association attempts to shape rules for using the word organic on personal care products.
The Personal Care Organic Standards Task Force, which has swelled over three years to 25 members representing manufacturers, ingredient suppliers, consultants and scientists, will make its first report at the OTA's All Things Organic Conference and Trade Show, May 14-17 in Austin, Texas.
OTA Executive Director Katherine DiMatteo says the task force's work has been complicated by the fact that the state of California, as well as various certifiers and organizations here and abroad, has already developed standards for organic personal care products—some based on the National Organic Program rule for food. The work is complicated still more by the fact that manufacturers have responded with new formulations and labels that comply with those rules.
"There is a lot of emotion and there are a lot of differences," DiMatteo says. "Our goal of having the organic label on personal care products gets confused with business competitiveness. And some people have a different set of values about what it means to use the word organic. It's not unusual, but it's very emotional."
Some decisions have been easy: Petrochemicals? Out.
But hydrosols, which can be used to replace the water in cream and liquid cleansers, are a different matter. On one side of the table are manufacturers that say hydrosol is a legitimate agricultural ingredient that, if certified organic, should count toward the total organic content of a shampoo or lotion. On the other side are folks who claim floral waters are far more water than floral and should be excluded from the calculations.
Lotions, shampoos and conditioners typically are a lot of water combined with fats or oils, explains Tom Havran, a product formulator and aromatherapy consultant who works on Frontier Natural Products Co-op's Aura Cacia line. "So here's where hydrosols come in: If your hydrosol is good, it can make that product really, really good. It can be a very valuable tool in creating an outstanding product."
Aside from essential oils and bath salts, Aura Cacia has no certified organic personal care products.
"They are extremely effective and have powerful therapeutic powers, if they're truly hydrosols," says Catty, who recently joined the OTA task force.
Havran says pure hydrosols are a "make or break" factor in creating organic personal care products. "The problem is we don't really know what a hydrosol is. There is no standard... And there is no standard for what you mean by hydrosol in a personal care product. Here's where it gets hairy: Water is exempt, so, theoretically, you could dilute hydrosol with water. Other than a manufacturer's word, there is nothing to fall back on for a standard."
The California Organic Products Act of 2003 does allow for enforcement of claims for products sold in California, says Gay Timmons, owner of Oh, Oh Organic in Los Gatos, Calif., and chairwoman of the California Organic Products Advisory Committee. "If they say it contains organic hydrosol, the state of California says we have the right to audit," she says. "And even if we didn't, there are various and sundry other mechanisms for oversight under the Food and Drug Administration and the Federal Trade Commission."
Still, production techniques are a key issue in assuring on a national level that hydrosols pack the punch they're supposed to. Jeanne Rose, executive director of the San Francisco-based Aromatic Plant Project and author of 375 Essential Oils & Hydrosols (Frog Ltd., 1999), says unscrupulous producers continue to collect the water that flows from a distiller long after the runoff is past its prime. "Hydrosol typically is the first 20 percent to 30 percent of the water, fluid or solution that comes over for essential oils," she says. "A hydrosol may be clear or have color; it also should have a powerful odor and must have taste. It should also have a pH of no greater than 5.5. Beyond that, it's just distilled water."
Donna Bayliss, a Northern California farmer who produces a patented organic lavender hydrofolate for personal care manufacturers, including Jason's Shaman Earthly Organics line, and a founding member of the task force, laments, "People just don't understand hydrosols." Buried deep in The Cosmetics, Toiletry and Fragrance Association's dictionary are definitions of floral waters, she says.
Though there are indeed definitions—lavender flower water is "an aqueous solution of the odoriferous principles distilled from the flowers of Lavandula angustifolia," for example—they don't specify what concentrations of the botanical elements must be present. And that worries personal care product makers like Larry Plesent, president of Vermont Soap Works and editor of the Green Products Alliance newsletter.
Without clear parameters, allowing floral waters might open the door for abuse by manufacturers who toss a handful of herbs into 20 gallons of water and call it good. "The question is where you draw the line," Plesent says.
Natural Foods Merchandiser volume XXIV/number 5/p. 16, 22
Natural Foods Merchandiser volume XXIV/number 5/p. 16