OTA Comments Regarding
NOP’S Draft Guidance Statement for Public Comment:
Certification and Labeling of Soap Products Made From Agricultural Ingredients
August 24, 2009
The Organic Trade Association (OTA) welcomes the clarification offered by this guidance document, and always appreciates NOP’s efforts to “create a consistent, fair policy that can be applied uniformly in a variety of situations.” Because such guidance supports greater consistency among certifying agents entrusted with interpretation and implementation of the rule, it is critical to the trade.
We believe that the labeling guidance in this document is consistent with both the Organic Foods Production Act and the current NOP rules, as well as with previous guidance issued for comparable issues. Soap products have been allowed to be certified as organically produced since at least 2005. This NOP guidance document brings the labeling of soap products into compliance with the NOP rule. We support the position that soap products must now have an ingredient statement which labels all the organic ingredients so that it is consistent with NOP requirements. Certifiers will now have clear guidance for labeling certified soap products, consistent with the labeling requirements for “organic” and “made with organic” food.
In addition, we understand that NOP and the National Organic Standards Board are working on broader issues concerning the certification and labeling of personal care and cosmetic products that contain organic ingredients. OTA has convened a Task Force to draft a white paper on organic personal care, to be completed by late September. The white paper will include a summary of the issues facing the organic industry due to the current state of the organic personal care sector. The white paper will also identify and analyze the policy and regulatory options for organic personal care products, including the application of the NOP rule to personal care products, so that OTA, other stakeholders, and policymakers can be more informed during future deliberations. We look forward to ongoing dialog with the NOP and NOSB on this subject.
OTA is committed to protecting and growing the organic industry. Our overall stance is one of support for third-party certification to transparent standards, whether public or private, in an effort to harmonize standards and maintain consumer confidence in the organic label. We appreciate there are a number of positions regarding the certification of personal care products within the industry and within the OTA membership. Until our white paper is completed and we have more information on this topic, OTA supports consistency in the labeling provisions of the NOP regulations.
OTA is very appreciative of NOP putting out documents for public comment. OTA looks forward to submitting further comments after the completion of our white paper and during the NOSB’s upcoming review of this issue.