Organic My Ass - Part 1

Rejoice science geeks, it's another exciting installment of Show Your Working! Today we'll be looking at the increasingly valuable label "organic", and what it actually means it terms of cosmetics.

(spoiler alert: very little)

I'll be doing this in two sections, one for Australia and one for the US, because the relevant legislation is quite different, and putting it together would turn this into a Masters essay rather than a blog post.

Before we really get into the nitty gritty, I just want to put it out there that I don't actually give a damn if something is organic or not, so please don't try and start a comment war on the pros and cons. I just...I don't care. I know, I know, I should, and it's probably better for me, but honestly when you have as many allergies as me, adding extra restrictions to what you consume is just more effort than I have in me. (In case you were wondering, my complete list of allergies is currently dairy, gluten, alcohol, peanuts, seafood, aspartame and related fake sugars) Also, I smoke, for heavens sake. Unless I quit sucking in noxious chemicals five times a day, the amount of parabens in my mascara is pretty moot.

BUT I know that it's really important to other people - people like David Lynch, who made a brilliant ad for his signature coffee blend, in which he points out several times that it's both organic and fairly traded. It's also incredibly creepy.

Because I'm a much less compassionate person than I should be, every time I hear someone ask if something is fairly traded, I can't help but hear it in Lynch's weird Barbie voice, and then I can't possibly take them seriously anymore.

However, something that I DO care about rather a lot is truth in advertising. I was enormously pleased to see Estee Lauder coming up against a class action for using misleading claims on their Clinique products, and I wish that sort of thing happened more often. Pseudo science claims like the kind used by Physicians Formula for their "happy blush" make me so angry I virtually froth at the mouth. Way back in the way back times I used to be part of the marketing industry, and one of the reasons I would never go back is the incredible amount of dishonesty involved in the way products are marketed.

EUPHORYL(TM) IS NOT A REAL THING. The marketing department MADE IT UP.

The first time I became aware of how dodgy a lot of the cosmetic industry is was when I was working for a small business owner who was trying to start a line of amenities to sell to hotels - tiny soaps, little shampoos and conditioners, yada yada. The owner wanted our product to be SLS free, paraben free, not tested on animals, and organic. All lovely aspirations, but he also needed it to be as cheap as possible, so he was sourcing the products from the first seller he had found on Alibaba.com. I had taken over the job from another person, so it took me a couple of weeks to get up to speed and ask the apparently ridiculous question - did we have any proof from our supplier to support their claims about this all natural product we were planning on selling? I asked pretty casually, because I was SURE the owner wouldn't have been so silly - I just wanted to be sure. I was more than a little concerned to find out that we didn't have any kind of proof whatsoever. While the regulations around what you can claim on cosmetic packaging is relatively lax in Australia, there is a consumer protection body called the ACCC (Australian Competition and Consumer Commission), and I was worried we would get hauled in front of them if it turned out we were making false claims (the legal term for saying things that aren't true on your packaging or in your advertising). I brought this up with the owner, and he declared this line of investigation a waste of time. Off my own bat, I decided to try and get an ingredients list from our supplier, at the very least. To say they were reluctant to give this up would be a gross understatement. I did eventually get a list out of them, and after giving it a quick scan, took the list straight to the owner. The ingredients they were using not only included SLS and related substances, but also parabens, and ingredients that couldn’t possibly be organic, like dimethicone. The only claim we'd made on our packaging that this list didn’t refute was the question of animal testing, and all the suppliers would give me in relation to that was some documentation entirely in Mandarin that they refused to translate. Unfortunately, the owner was utterly unconcerned by these revelations. When I pointed out our company could be taken down by the ACCC if our false claims were discovered, he said it didn’t matter because we were told by the suppliers that our claims were true, and we could claim ignorance. This is just one of the reasons I no longer work for that company.

I firmly believe that regardless of my personal feelings about the advantages vs disadvantages of things like organic, paraben free, etc, if you're going to claim something about your product, it should be at least MOSTLY true. At the very, very least. If you're selling something as paraben free, it shouldn't have any parabens in it. And if you're labeling it as organic, it should bloody well be organic. Consumers pay an enormous premium for these products, and using unsubstantiated claims to take advantage of that is pure charlatanism.Words have meanings, and in the case of a word like "organic", there is a very specific meaning, and a set of expectations created when you use that word.

Organic food is a pretty simple concept - it's foodstuffs grown without synthetic pesticides, or chemical fertilizers. Instead, organic farmers often use biodynamic methods designed to encourage the development of a self sustaining system where soil, plants, and animals all work together in a sustainable way. Two interesting facts about this kind of farming - firstly, it was invented by Rudolph Steiner, who is also responsible for the Steiner or Waldorf style of education, which bumps him even further up my list of Dead People to Have Dinner With. Secondly, one of the fertilization methods employed by biodynamic farmers is filling up cow horns full of manure, then burying them for six months or so. They then dig the horns back up again, mulch the nicely fermented cow dung, and spray it over the field.

To be classed as organic, a product can't be treated with irradiation, industrial solvents, or chemical additives - you would hope this isn't so much of a problem when it comes to apples, but when you're talking about making a shampoo or foundation that meets these requirements, it can get complicated. All ingredients sourced must be organic, all methods used to make the product must be within certain guidelines - although from what I could find it seems you can do what you like it terms of packaging said product.

It turns out, in Australia, there isn't really anything stopping anyone slapping the word "organic" on their cosmetics, unless a complaint is raised and taken to the ACCC. While there has been a standard developed for determining whether or not something is actually organic, this standard is totally voluntary. If you are making claims you can't back up, and it gets to the ACCC, you are of course in all sorts of trouble. But that's a great big IF. There are also a bunch of weasel words you can use to get around this - "natural" and "natural ingredients" can be interpreted so broadly that they are virtually meaningless. Here's an example;

.

The label states the product is made up of "88% natural ingredients", with no indication as to what they would consider "natural". And even assuming all the products they have deemed "natural" are ones you're comfortable using, there is even less indication what the fuck the remaining 12% is made up of. If a food was 12% sugar, I imagine you would consider that to be quite a lot of sugar. But apparently 12% of this product being a mystery is fine.

Once we take a look at the back, you get a pretty good idea why they're not so keen on drawing your attention to that mystery 12% - turns out it's largely synthetic chemicals, with a few organic ingredients thrown in to balance it out. Does that balance though? If I put enough organic hemp oil in, does that make the toxins less toxiny? I'm not a chemist, but I'm guessing probably not.

Another fun way manufacturers can get around the ACCC is to use the word organic in a brand name, in a way that IMPLIES the product is organic, but doesn't actually SAY it is. Just take a quick look over the website for Nature's Organics, an Australian cosmetic company that mostly sells through supermarkets. They have data sheets available for all their products - awesome! They use plant based packaging, and have made a commitment to sourcing palm oil responsibly - also awesome things. But you notice one thing missing? That's right, any indication these products are actually organic, or even made from organic ingredients, beyond the trademarked company name.

Not actually organic.

This is total horseshit. Their products are probably perfectly good, and they're doing all sorts of other ethically awesome things - so why use the word "organic", when it's NOT FUCKING ORGANIC!?

*ahem*

A slightly less manipulative trick, but a trick all the same, is to have one or more organic ingredients, and draw attention to that so as to distract from the fact the product itself isn't actually organic.

Oh look, it's organic!

....wait a minute...

Oh, I see. organic olive oil, plus parabens, alcohols, and dimethicone

So how do you know you're getting what you paid for?
While there isn't anything really stopping companies putting "organic" on their products, there IS however a very strict certification process they can go through so as to be able to label their products as "certified organic." They can get this certification by applying either to the ACO (the certification arm of the Biological Farmers of Australia), or NASAA if they want to export overseas. Interestingly, in order to be certified organic by the ACO, a cosmetic product only has to consist of 95% organic ingredients - the remaining 5% however must be "naturally produced plant products and/or natural, non toxic preservatives/additives." To be certified organic by NASAA the definition is slightly looser - a cosmetic product only has to be between 70% and 95% organic ingredients, and the remainder can be made up of "products that are in compliance with the NASAA Standards (eg clays and minerals) and whilst not harmful, are not from an agricultural origin so cannot be certified as “Organic”. If you're curious, a copy of the full requirements for each type of certification can be found here (NASAA) and here (ACO).
The easiest way to be sure that what you're buying is really, truly, as completely as possible organic, is to look for one of these logos on the product. As far as I'm aware, the ACO "bud" logo is much more commonly used within Australia.

There has been some criticism of the certification process for organic products - it's been rightly pointed out that the process can be expensive, and extremely time consuming, as it requires a whole lot of testing be done of every aspect of your business. Every ingredient you use also has to have a paper trail ensuring you are able to absolutely verify your organic supply chain, and keeping up with this amount of paperwork can be overwhelming for small businesses. I can certainly see this as a valid criticism - but the alternative is letting people make claims without having to verify them, and I think we can see from the examples above that there are plenty of companies out there more than willing to take advantage of any laxness in the relevant legislation. I was pleased to note that the ACO at least has taken notice of these criticisms - they have a whole separate stream of certification for very small producers, with much less paperwork and vastly reduced costs. It only applies to farms selling products domestically, but it's at least an effort to ensure small farms are included and allowed to take full advantage of the effort they've put into producing something truly organic, as opposed to the bigger businesses worming their way into the market with half truths and clever logos.
  
For more detailed information on what "organic" actually means from a legal point of view, and what you can do if you see a company making false claims, check out these linkies
ACCC (Australian Competition and Consumer Commission)
ACO (Australian Certified Organic)

Have you seen any similar "eco" marketing tricks? I'd love to hear about any weaselly labeling you've seen.