What About “Natural”?

calendulaCan you call a cosmetic product “natural”? And what does that really mean, anyway?

Nowadays, there are so many products of all types being marketed as “natural” it’s getting crazy!  I recently saw some piece of furniture marketed as “natural” because it was made (mostly) of wood.  Where does it end?

The first thing to know is that, when it comes to soap and cosmetics, there is no regulatory definition of “natural”.

When I first started making soap and cosmetic products, I struggled over the legal and moral issues of whether my products were “natural” and how I should promote them.  At the time, I was going for the unscented, uncolored niche, so “natural” was pretty important – and very unclear.  At the time, for me “natural”  meant “as close to the way it is in nature as possible”.  So palm oil (even though it’s processed and bleached), essential oils, and tapioca starch – all being plant based – were “natural”, but fragrance oils, Vaseline and paraffin were not.

Since that time, my understanding of chemistry has grown and my own personal view of what’s “natural” has changed.  Things don’t have to be plant-based to be natural. Petroleum products (depending on the amount of processing) come from the earth (and were once dinosaurs), so they can be natural  – a concept I would have argued strongly against not many years back.  And just because something is relatively “natural” (plant-based, for example), doesn’t mean it’s SAFE.

So “natural” is a nebulous term, used (and over-used) more for marketing purposes than anything else.  Check any dictionary and there IS a definition for it – “coming from nature”. Well, everything comes from nature, at least originally.  The question is:  how far can it be removed from its original, undisturbed state and still be considered “natural”?  The answer seems to depend on who you ask.

“Natural” and Cosmetic Labeling

If you ask the FDA, the answer is:

FDA has not defined the term “natural” and has not established a regulatory definition for this term in cosmetic labeling. ~ Small Businesses & Homemade Cosmetics: Fact Sheet

In other words, the FDA doesn’t have a thing to say about what you can or can’t say is “natural” when it comes to labeling cosmetics.  The next time you see a cosmetic that has claims of “natural” but the ingredients include things you feel are far from natural, remember it’s not a regulatory or legal issue.  Moral and ethical, probably; but regulatory … no.

The FDA also notes that “natural” is an “additional description” and doesn’t belong in the ingredient declaration:

Don’t use terms such as “natural” as part of an ingredient statement, because ingredients must be listed by their common or usual names, without additional description. ~ Small Businesses & Homemade Cosmetics: Fact Sheet

“Natural” and Food

Back in 1993 the FDA stated its policy regarding the the term “natural” on  food labeling means:

“nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in the food.” ~ [58 Fed Reg. 2303, 2407 (1993)]

You’ve probably heard of the much discussed, debated and litigated issue of GMO corn.  There have been several lawsuits about the use of “natural” for products containing GMO corn, three of which were referred to the FDA for administrative determination.  On January 6, 2014,  the FDA responded to the courts with a letter and declined to define “natural”. Essentially, the letter said that defining “natural” is much bigger than just GMO issues and it would involve other Federal agencies (i.e. the USDA), competing view of of stakeholders as well as a myriad of other factors, and that “priority food public health and safety matters are largely occupying the limited resources that the FDA has to address to food matters”. This article gives a pretty good overview of the legal aspects of the cases.

In other words — it’s a huge project to develop regulations which define “natural” in terms of food and they don’t have the time or resources to devote to it right now.

Back to Cosmetics

Considering how contentious and complicated the issue of “natural food” is, it’s not surprising that the concept of “natural cosmetics” is confusing, unregulated and filled with opinion.  Also certainly not surprising that the FDA has clearly stated they don’t regulate the use of the word “natural” for cosmetics.

When you label your handcrafted soap and cosmetic products, the use of the term “natural” is up to you.  What it means and how you apply it is also up to you.  The FDA’s policy on the use of the term “natural” for food might be a help in guiding you, but the final decision is yours.

I recommend that if you do decide to use the term “natural” to describe your products, you also work out – for yourself – the definition you are using.  Tell your customers what you mean when you say “natural.”  It will probably engender more trust from your customers and may become a marketing message that won’t get lost in the forest of dubiously “natural” claims that seem to be everywhere.

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