Dear National Organic Standards Board:

The USDA [National Organic Program] NOP specifically invited personal care manufacturers to certify to USDA NOP standards upon the launch of the program in 2002. Our company, Dr. Bronner’s Magic Soaps, followed other major companies, specifically including Lynn Betz’s company Sensibility Soaps, in obtaining USDA NOP certification in 2003.  Dr. Bronner’s NOP certified products alone support over a thousand organic farmers and 8000 organic acres, with over $29 million in wholesale sales in 2008. Conversations with major brands in the industry indicate that late 2009 and 2010 will see significant new USDA NOP lines introduced, including AVEDA founder Horst Rechelbacher’s new USDA NOP brand, Intelligent Nutrients. More and more cosmetic products are being developed within the rigorous constraints of the NOP to perform as well as modern synthetic variants.

This sustainable innovation should be supported and defended in the face of mainstream cosmetic industry’s knee-jerk “Better Living through Chemistry” inertia and resistance that seeks to co-opt and destroy the organic label in personal care.  Lynn Betz has been at the forefront of organic integrity, proving the mainstream industry wrong time and again with quality NOP personal care formulations that work as well as their synthetic counterparts, in product category after product category.  And she does so with “proof in the pudding” products and well-reasoned articulate arguments that the NOSB and NOP will appreciate.  She handles herself with grace and aplomb even when dealing with provocative behavior and words from those opposed to her position.

Dr. Bronner’s is in entire agreement with the recent Recommendation set forth in the Discussion Document “Solving the Problem of Mislabeled Organic Cosmetics & Personal Care Products”, dated March 13, 2009, prepared by the National Organic Standards Board’s Certification, Accreditation and Compliance Committee (http://www.ahpa.org/portals/0/pdfs/09_0323_CACC_Discussion_Draft_Organic_Personal_Care.pdf). 

That Recommendation, which will be presented to the NOSB for its Public Meeting in Fall 2009 for formal adoption, is to make the NOP standards mandatory for cosmetic/personal care products that make organic claims, not simply voluntary.  Given the relevance of personal care to NOSB considerations in the near future, Lynn is an ideal timely candidate to help NOSB board members appreciate the history and reality of certified organic personal care.

Organic personal care is about simple time-honored recipes handed down to us by generations of wisdom, based on ingredients produced from organic agriculture with a bare minimum of synthetics and processing. Beginning in the 1940’s, the world was flooded with cheaply-made synthetic products and ingredients, ranging from pesticides and food additives to detergents and plastics, all created in the laboratory largely from non-renewable petroleum. It was hailed as “Better Living Through Chemistry,” but unintended consequences included pollution of the air and water, deterioration of soil tilth and health, unhealthy overly-processed foods, and synthetic ingredients in personal care products – more than a few with significant toxicity issues. In response, the organic movement of the last few decades rejected the intensive synthetic inputs and processes in conventional agriculture and food processing, recognizing that traditional methods and materials result in better soil, human and environmental health. Thus, organic integrity in body care necessarily means that a product claimed to be “Organic” is composed of certified organic ingredients produced with minimal processing without unnecessary synthetics, produced in compliance with USDA NOP regulations.  Real organic personal care is “organic food for the skin” and does not utilize synthetic preservatives that can irritate skin. Natural unrefined oils and waxes are used as emollients and moisturizers, instead of hydrogenated oils and synthetic silicones. Traditional natural simple soaps are used in hand and body washes, instead of modern synthetic surfactants usually made in part with petrochemicals.

Lynn is not unfamiliar with conventional chemical driven personal care, and has experience formulating and private labeling in that arena as well.  But she knows what’s organic and what’s not, and control of the meaning and use of “Organic” is what is at stake:  the organic multi-stakeholder movement represented by NOP/NOSB, versus the cosmetic industry’s hype-of-the-moment marketing that seeks an organic greenwash for its chemical-driven formulations.  Private cosmetic industry standards want to take the term “Organic” and apply it outright to O95 products whose primary cleansing agents have never and can never be made in a kitchen, and which are not commercially available from organic material in the first place. The NOSB CCAC Recommendation correctly notes that currently “[c]onsumers are not assured that organic claims are consistently reviewed and applied to this product class” and “[t]ransactions lack the regulatory clarity that applies under the NOP to food products that contain organic ingredients.” Manufacturers “are hindered by a thicket of competing private standards and confusion regarding the applicability of NOP .”

Lynn is an important advocate and example of the truth all too many seek to quash but which the NOSB and NOP need to understand and hear loud and clear. High-quality high-performance personal care is being produced and certified right and left right now under the NOP by organic companies of integrity, who support organic agriculture and farming with the integrity the federal NOP ensures.  Only by making the NOP rules mandatory for cosmetic/personal care products can consumers be adequately protected from the misleading and deceptive labeling practices currently prevalent in the marketplace.

Sincerely,

David Bronner
President
Dr. Bronner’s Magic Soaps