OTA Position on the Regulation and Labeling of “Organic” Personal Care Products in the U.S. - Organic Trade Association
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OTA Position on the Regulation and Labeling of “Organic” Personal Care Products in the U.S.


OTA supports mandatory public (federal government) regulation of organic labeling claims on personal care products.

Public (federal government) regulation of personal care products making “organic” claims is the option most consistent with
OTA’s Mission and Core Values.  This option is the best way to accomplish:

  • mandatory third-party certification of PC products making “organic” claims
  • strong mechanisms for compliance and enforcement
  • removal of products from the market that have no organic content but make an organic claim.
  • Public (federal government) regulation will guarantee that organic personal care products meet a consistent standard and will assure that consumers can trust the organic claim.

OTA supports the development and adoption by NOP of an organic personal care standard and will work with its members, with USDA/NOP and with Members of Congress, as necessary, to reach this goal.

Regulation by USDA/NOP is the best way to achieve:

  • consistency with existing NOP product labeling

  • mechanisms for oversight by experts in organic handlingminimizing consumer confusion and supporting public confidence in the organic label, given   that the USDA Organic seal is seen as the “gold standard."

  • OTA recognizes that there are distinct needs of personal care product formulation. Any federal standard for organic personal care should safeguard the integrity of organic as well as take into account materials and processes distinct to the production and processing of personal care products.

  • A “new” organic personal care standard could incorporate the best of existing private standards as well as the existing NOP organic standard to which some products have been certified.

  • An organic personal care standard should aim to minimize public concern about synthetics in organic; have ways to involve experts in cosmetic formulation; and strive to support international trade given the global nature of organic markets.

  • OTA understands that it will take significant time and resources to reach the goal of federal regulation under NOP. However, we believe it is the right solution for the long term. OTA is developing an advocacy plan and identifying the resources needed to advance this goal.

  • OTA commits to advocating for additional resources and expertise for NOP so that the program has the capacity to reasonably address personal care products and is not overburdened by a significantly broader scope without the requisite resources.

  • In the interim, OTA will recommend industry best practices regarding how companies should be communicating and marketing their organic personal care products in the absence of mandatory federal regulation.

Adopted by OTA’s Board of Directors, April 13, 2010

2014 Annual Fund

Research and Promotion 2012