Judi Beerling, Technical Research Manager, Organic Monitor Ltd

Oat Cosmetics IngredientsCertification of Natural and Organic Cosmetics – Where is it going?

Consumers are increasingly showing interest in purchasing ‘green’, sustainable or ethically produced cosmetic products. For some this means looking for natural or organic personal care or for the absence of certain “chemicals” of concern to them. It is not the intention of this article to debate the merits of natural versus synthetic raw materials but to focus on the current state of play in the natural & organic cosmetics market. Product sales in this category were increasing at double-digit rates in the UK, as they were in the rest of Europe, before 2009. High growth rates are envisaged again as the economy starts to recover from the recession. predicts The market share of natural & organic products is predicted to reach 5% of the total personal care product sales in the coming years [1]. Increasing penetration of these products in different types of retail outlets is expected to drive market growth.

Consumers have an enormous choice of products in almost every walk of life and face considerable problems when selecting ‘authentic’ natural and organic cosmetic products. There are no laws regulating what can or cannot be marketed as a ‘natural’ or ‘organic’ cosmetic product. Indeed, many products are often marketed as such but contain relatively low levels of natural/organic ingredients [2]. Consumers look at product labels and ingredient lists for clarification, but are often confused by the complicated sounding ingredients listed in unfathomable INCI terms often peppered with a good smattering of Latin.

Suppliers, manufacturers and formulators alike realise the need to reduce reliance on petrochemicals, as well as satisfying the needs of the “green” consumer. Standards and certification play an important role in providing a guarantee to consumers that products meet certain minimum criteria for authentic natural/organic products. Although the level of certified products is generally increasing, especially in Europe and North America, there are differences between the major standards on what ingredients are permitted. Also, some brand owners are creating their own natural / organic seals and logos, adding to consumer confusion.

Many brands, especially those outside Europe, often use a number of synthetic ingredients that are not common to natural & organic cosmetics. They would be classified by the author as ‘semi-natural’ or ‘naturally inspired’ although consumers may perceive them as pure natural due to the marketing. Hence, “greenwashing” has hit the headlines. This is often in relation to the use of the word “Organic” or “Natural”, being used prominantly on the front of the packaging (or even in the brand name) where there is in fact very little organic or natural ingredient content. With so many brands making natural and organic claims – many of which are unsubstantiated – standards play an important role in providing a level playing field in terms of cosmetic formulations. Certification also helps build consumer confidence, since standards give reassurance that products do not contain potentially harmful or unsustainable ingredients.

A large number of natural & organic standards have been introduced in recent years, however the adoption rates have to date been mostly on a national basis. The major standards in Europe include Ecocert Greenlife (France), COSMEBIO (France), Soil Association (UK), BDIH (Germany), Ethical and Environmental Certification Institute – ICEA – (Italy) and a host of smaller national standards including the Organic Food Federation’s (OFF) Non Food Certification Company (NFCC) and Organic Farmers and Growers (OFG) in the UK. There is a less crowded picture in North America with the United States Department of Agriculture National Organic Program (USDA NOP) and NSF ANSI 305 being the major organic standards, with the Natural Products Association (NPA) being to only real natural cosmetic standard to date. Organic standards exist in Australia and IBD in Brazil has organic and ecosocial standards but much of the rest of the world looks to Europe or the USA. The most interesting developments in recent years have been the attempts to form regional or international groupings based on harmonisation of various national standards. NATRUE were the first to launch a standard based out of Belgium in late 2008 having become disillusioned with the slow progress of European harmonisation efforts. The COSMOS standard, from which NATRUE broke away, was finally launched in 2011 after nearly nine years of discussions. The COSMOS (which stands for COSMetics Organic Standard) AISBL (international non-profit organisation based in Brussels) grouping involves Ecocert Greenlife, COSMEBIO, BDIH, ICEA and Soil Association.

Figure 1 lists the types and key features of major European national certification of natural and organic cosmetics standards currently available, compared to the COSMOS harmonised version which is due to finally replace these shown by the end of 2016. The NATRUE standard is also included for comparison.

Fig.1: European Certification of Natural and Organic cosmetics Standards

Standard Type Key Features
Ecocert Greenlife Organic (Bio)
  • Min. 95% ingredients are natural or derived from natural sources.
  • Min. 95% of plant ingredients are produced by Organic Farming.
  • At least 10% of entire product contents (including water) must be produced by Organic Farming.


Natural (Eco)  


  • Min. 95% ingredients are natural or derived from natural sources.
  • Min. 50% of plant ingredients are produced by Organic Farming.
  • § At least 5% of entire product contents are produced by Organic Farming.
COSMEBIO Organic (Bio) As Ecocert Organic
Natural (Nat) As Ecocert Natural
BDIH Natural
  • § Natural source raw materials or those produced by permitted ecological processes.
  • § Some requirement for listed plant materials to be organic.
  • § Only certain synthetic preservatives are permitted.
Soil Association Organic
  • Min. 95% organic ingredients by weight (of the agricultural ingredients) and only permitted non-organic ingredients, processing aids and water.
  • Water is excluded from the organic calculation.
  • Products that contain 70-95% organic ingredients can be labelled with the phrase “product containing X% organic ingredients”.


ICEA Eco Bio (Organic)
  • Plant / animal materials used must be organic.
  • Prohibited list of ingredients / chemical reactions
COSMOS Organic
  • § Min. 20% organic content (except rinse off / powders 10%).
  • § 95% of physically processed agro ingredients must be certified organic.
  • § Only permitted Chemically Processed Agro Ingredients (CPAI).
  • § 100% natural / naturally derived ingredients (except approved synthetic preservatives & petrochemical moieties)
  • § No organic requirement.
NATRUE Organic
  • § 13 product categories.
  • § Specific levels of required natural and “derived natural” substances quoted by product type in tables provided in the standard.
    • Most products – min 20 % of natural and max. 15 % of derived natural substances.
    • § Min. 95% of the natural substances of plant & animal origin must be organic.
With OrganicPortion As above but

  • § Min 15 % of chemically unmodified natural substances and max. 15 % of derived natural substances.
  • § Min. 70 % of the natural substances of plant & animal origin must be organic.
  • § Min. level of natural content & max. level of derived natural materials specified by the product type.
  • § No organic content required.



The implications of the harmonised COSMOS standard to manufacturers of certified products were possibly not clearly understood at first and further refinements of the standard have taken place based on licensee and stakeholder feedback. The latest standard revision (version 2) was launched on October 21st 2013 and can be found online [3]. Some major changes to note in this second revision are as follows:


  • To achieve ‘COSMOS NATURAL’ certification the product must now indicate the percentage of natural origin ingredients by weight in the total product, as “x% natural origin of total”.


  • Petrochemical solvents will be allowed (provided there are no natural alternatives and they are recycled and eliminated at the end of the process) for chemical processing of agro-ingredients with certain exceptions. However, except by permission, petrochemical or halogenated solvents are not allowed for processing organic ingredients, even if they are subsequently removed.


  • Phosphorylation is now an allowed process for leave on products only, which brings the standard more in line with NATRUE. The prohibition for rinse off products is presumably on environmental grounds.


  • Cocamidopropyl betaine, alkylamphoacetate/ diacetate based amphoteric and alkylglucosidecarboxylate surfactants which were due to be phased out by the end of 2016 are now allowed but only where the ‘chemical moiety’ does not exceed 2% in the finished cosmetic product.


  • Other ingredients containing both natural and petrochemical moieties that are permitted by exception include Dicapryl Carbonate, Carboxymethyl Cellulose (Cellulose Gum) and Hexyl Laurate .


  • Most interestingly, Guar Hydroxypropyl Trimonium Chloride (which was at one time allowed as an exception by Ecocert) and Distearoylethyl Dimonium Chloride (DSEDC) are now permitted (with the same restriction of 2% petrochemical moiety in the end product) but for hair products only.


  • Annex VI of the standard provides a list of physically processed agro-ingredients that are considered to be available in organic form in sufficient quantity and quality. These must be organic in products under COSMOS ORGANIC certification. Examples include a number of fixed oils, such as Argan, Almond, Coconut, Palm and Olive oil, along with Shea and Cocoa butter and certain plant extracts.


By comparison, the North American situation on the surface appears to be more stable and less complex. It is not so easy to compare US organic products with their European certified equivalents because of the way water is treated in the calculation. The major organic standards in the USA exclude water from their calculation of organic content whereas most European standards, such as Ecocert or COSMOS count it as natural (since it cannot be organic) or neutral in the case of NATRUE. However, COSMOS for example allows the ‘without water’ organic content to also be displayed for comparison purposes. Figure 2 summarises the major North American standards for natural & organic cosmetics.


Fig. 2. North American Certification of Natural and Organic cosmetic standards

Standard Type Key Features
USDA NOP 95 – 100% Organic
  • § Organic – if they meet same criteria governing organic food certification.
  • § Can use the logo on the front of pack.


>70% ‘made with Organic’
  • § Not able to display the logo on pack.
  • § Water excluded from calculations.


NSF ANSI 305 Made with Organic
  • § Min. 70% organic content by non-water/non-salt weight.
  • § More chemical processes allowed for the remaining ingredients than USDA NOP.
NPA Natural
  • Must be made with min. 95% all-natural ingredients
  • Can only contain synthetic ingredients allowed under this standard ‘that do not have suspected human health risks’.
Whole Foods Premium Beauty Natural
  • § A retailer standard.
  • § Must be at least 95% “petroleum free”.
  • § Focuses on prohibited ingredients list.

NATRUE entered into a standards equivalency agreement with the American certification agency Quality Assurance International (QAI) in February 2009. QAI have been a major driver of the NSF ANSI 305 standard. The equivalency agreement means NATRUE “With Organic Portion” products should also be able to meet the NSF ANSI 305 ‘Made with Organic Ingredients’ cosmetic standard in the USA, and vice-versa.

In February 2011, NATRUE and NSF announced that they would be working together on a new American National Standards Institute (ANSI) standard for natural cosmetics. This would allow equivalence to be achieved in the USA for NATRUE Natural cosmetics. NATRUE and NSF were until this point in discussions to achieve a similar agreement with the Natural Products Association (NPA). However, talks broke down and so now there is the liklihood of two competing natural standards for the USA along with the Ecocert / COSMOS standard, since Ecocert Greenlife also has a market presence in the US. However, the new natural standard is still in the discussion and definition of terms stage, so it could be some time before it is finalised.

Huge strides have been made in recent years in the number and types of natural & organic raw materials available to formulators. This has become a key area for many suppliers, highlighted by the large number of natural/naturally derived ingredient launches at major trade exhibitions each year. Many of these suppliers will also go down the route of obtaining certification (if organic) or approval of one of the major natural standards bodies, such as Ecocert Greenlife or NATRUE, for their ingredient. This makes it much easier for a formulator to know which ingredients they can utilise in natural product development. COSMOS approves natural raw materials by trade-name but the number of ingredients on the database is still quite small (633 at time of writing) whereas Ecocert has almost five times as many. This is certainly not enough yet to be able to formulate all types of products easily. Thus some checking is required to ascertain the likelihood that an ingredient would or would not pass the COSMOS certification process as part of a finished product. This process has also been simplified in the new standard as many suppliers did not appreciate the level of detail about their manufacturing process that the original raw material questionnaire required. Fortunately, suppliers now tend to openly disclose which preservatives they use in their materials and whether ionising radiation was used for sterilisation (which is a prohibited process). There is also a need to prove absence of any genetically modified plant material. These are all areas that can trip the formulator up, sometimes quite far down the line. This can be a costly mistake as the certification process can often add several months to the development time. Other challenges of formulating to standards are the lack of choice / performance in certain categories of ingredients. For example, hair care is notoriously difficult to formulate naturally, let alone to an organic standard. Most consumers don’t want to pay high prices for inferior performing products. Shampoos and conditioners (along with styling products) have always been a massive challenge and it is interesting to note the COSMOS changes (see earlier) to allow a quaternised guar derivative (which was phased out of the Ecocert standard some years ago) and a biodegradable, vegetable derived hair conditioning esterquat (DSEDC) which should help achieve hair conditioning at an affordable price. This material is sold (as a blend with cetearyl alcohol) under the trade-name Varisoft EQ 65 by Evonik. As a more natural/green option, Inolex produced a ground breaking cationic hair conditioner / emulsifier under the trade-name Emulsense™ (and Emulsense™ HC for hair care), which has several natural product standard approvals including COSMOS and NSF ANSI 305.  It is derived solely from fermentation and plant materials (such as brassica) using sustainable green chemistry principals. Emulsense™ enables both excellent performance and all-natural claims for hair conditioners. In skin care, it is an emulsifier with an interesting sensory profile, providing an initial silky feel and a powdery after-feel to the skin.

NPA in the USA also has a list of temporarily approved ingredients, a number of which are for hair conditioning. Much more still needs to be achieved in the styling product area as there are almost no styling resins that are naturally derived.

As a formulator of natural & organic cosmetics, one is often asked the question – can natural cosmetics really perform well? How can serious anti-aging skin care, for example, be formulated to produce measurable, consumer relevant results without resorting to slipping in some synthetic high-tech actives? Many companies in the industry now provide a plethora of naturally based actives (and functional ingredients) whose performance is tested in the same rigorous manner as synthetic actives. However, what is not always understood so well is what in a plant extract is responsible for the activity. In fact, studies often find that a combination of phytochemicals is the key, not a single active component.  So, what can you use to drive functionality and sensory / marketing appeal without breaking the bank? There is only space here to highlight a few of the new crop (excuse the pun!) of natural & organic ingredients.


Case Studies:

Oat Cosmetics markets a range of raw materials based on the food cereal crop, Avena sativa – the humble oat, most famously known for the nutritious breakfast dish – porridge. In foods, oat beta-glucan has been shown to lower/reduce blood cholesterol and thus potentially reduce the risk of (coronary) heart disease. The true benefit of oat based materials for cosmetics have, however, been less well characterised until recently. The Oat Cosmetics extruded colloidal oatmeal (Avena sativa Kernel Flour) is manufactured using a unique patented process that enhances the availability of beta-glucan and therefore increases the anti-ageing activity, as well as providing enhanced moisturising, cleansing and soothing activity as compared to alternative colloidal oatmeals. The oatmeal is rich in essential lipids and fatty acids and contains natural antioxidants. It demonstrates skin pH buffering and emulsion stabilising properties plus reduces greasiness in product formulations.

Results of a recent independent consumer research study commissioned by the company have highlighted the moisturisation and skin soothing benefits of the company’s colloidal oatmeal (COM).  The most recent study was conducted over 90 days, using a facial cream with 3% Oat COM (Colloidal Oatmeal) – used once per day. Panellists were asked a number of questions at the initial assessment and on day 30, 60, and 90. Over the period of the trial, for example, 98% felt that the product consistently left their skin feeling moisturised and nourished, 91% felt it created a feeling that the skin was silky soft and 89% agreed that it soothed the skin. Each of these desirable effects can be attributed to one or more specific molecules found within the oat kernel. The effect of all these molecules working together is however synergistic.  For example, Oat COM contains approximately 5% beta-glucan (i.e. approximately 0.15% in the tested formulation), therefore it is unlikely that the beta-glucan is entirely responsible for the overall moisturisation effect but rather a combination of beta-glucan, lipids and other minor components in the oatmeal. This is a great example of the benefit of using whole plant ingredients, whose price is often more affordable than single extracted actives. Oat Cosmetics also market Oat COM ORG, an Ecocert certified organic grade, suitable for cosmetic products that may need to be COSMOS-organic certified. Further details can be found on the company’s website [4].

What about plant derived oils – often known as fixed oils? There seem to be an ever increasing number of emollient oils from all four corners of the planet. These can be organic, cold pressed, fairtrade / ethically sourced, wild harvested or just plain ‘exotic’. One of the newest on the scene is Kahai Nut oil from Columbia, extracted by cold pressing the nuts of the Cacay tree [5].  There is an amazing sustainability and social story associated with this oil and once the plantations are established in Columbia, it could be the next Argan oil success story (until this time, available quantities from wild harvesting are limited). However, perhaps more important to a formulator is the amazing silicone-like, light non-greasy silky skin feel which penetrates the skin rapidly. It also has an exceptionally high content of anti-ageing components such as natural Vitamin E, F and retinol (three times more than rosehip oil).

Sustainability is a much bigger driver in today’s industry than natural & organic certification has, or is ever likely to be. The standards setting bodies do try to embrace emerging technologies, such as green chemistry and biotechnology, but sometimes struggle to keep up with the pace of such changes and the potential benefit of, for example, gene modification for biocatalysis. However, we are already experiencing massive changes in the way cosmetic raw materials are made although apparently we are still lagging well behind the pharmaceutical industry. SCS Formulate 2013 was an exciting place to be and certain discussions always stick in one’s mind. One of these was a fascinating insight into Croda’s Biotechnology programme [6] at their Lunch & Learn session. The terms ‘blue’ and ‘white’ now sit alongside ‘green’. White Biotechnology applies to industrial processes, Green Biotechnology to plant and/or agricultural processes and Blue Biotechnology is applied to marine and aquatic processes. Whole cell biotransformation (White) already leads to biosurfactants, such as sophorolipids. The use of undifferentiated plant cells to ‘synthesise’ target phyto-molecules (Green) is already embraced by the Sederma division for actives such as Resistem™, a plant extract obtained by stem cells culture from Globularia cordifolia. Croda also has a partnership with Nautilus Biosciences, Canada to find novel, actives and ingredients from marine sources (Blue). One such existing marine ingredient is Sederma’s Venuceane™ (INCI name: Thermus Thermophilus Ferment (and) Glycerin) which is produced by fermentation. It is an extremophile microorganism from deep sea hydrothermal vents. The organism survives by synthesising an enzymatic cocktail which have been found to have a variety of skin benefits. New data produced this year shows that this ingredient has efficacy in protecting the skin against both Ultraviolet (UV) and Infra Red (IR) induced photo-ageing.

So, where are standards going? This is difficult to determine without a crystal ball but it does seems that at least for the foreseeable future we will still have quite a few to choose from. Much discussion has taken place at events such as the Sustainable Cosmetic Summits [7] about the desire by product manufacturers for one worldwide standard. However, as there are a number of vested interests and business associated to standards and certification, the likelihood is that this will not happen unless forced upon them by regulation. One hope for some is a voluntary ISO standard for natural and organic cosmetics [8] that is in development. However, this was started once before and abandoned, as the country representatives could not agree even on the definition of natural as related to cosmetics and ingredients. There is an obvious concern that a weak standard would more encourage further ‘greenwashing’. Conversely, a very restrictive ISO standard may just not be adopted as it would end up being too difficult to formulate high performing, consumer acceptable products. Until documents are added to the ISO website it is difficult to judge progress.

Although interest in standards is rising, the adoption rate remains low with less than 50% of natural & organic personal care products certified in the UK. The Soil Association standard is the most popular and it will be interesting to see if going forward, brands continue certification to the COSMOS standard and how natural certification takes off.

The good news is that new extraction and processing technologies, green chemistry, biotechnology and biocatalysis will all help to increase the formulator’s options. Natural & organic cosmetics will become more sustainable with the focus shifting to encompass a variety of other aspects, such as sustainable packaging and reduced energy, carbon and water footprints.



  1. Organic Monitor report 1203-60, The UK Market For Natural & Organic Personal Care Products (3rd Edition), April 2013.
  1. Organic Monitor report 8041-14, Technical Insights: Natural & Organic Cosmetics Brand Assessment, Aug. 2011, www.organicmonitor.com
  2. COSMOS-standard AISBL, www.cosmos-standard.org
  3. Oat Cosmetics – oatcosmetics.com/
  4. Kahai SAS, www.kahai.co
  5. Download Croda’s “Biotechnology and Its Role in Sustainable Design” document from www.croda.com/home.aspx?s=1&r=63&p=3699
  6. Sustainable Cosmetics Summit, Organic Monitor, www.sustainablecosmeticssummit.com
  7. ISO/CD 16128-1 and ISO/CD 16128-2, Guidelines on Technical Definitions and Criteria for Natural & Organic Cosmetic Ingredients and Products parts 1 and Part 2: Criteria for ingredients and products – in development. (www.iso.org).