Organic and natural product claims

Food supplements claiming to be organic need to comply with Regulation (EU) 848/2018 on a number of aspects. To claim cosmetic products to be organic or natural it is best to follow to follow ISO 16128-2:2017.
Herman van Zonneveld
By Herman van Zonneveld
Senior Consultant

Market demand

In the health and beauty industry there is a clear trend for going “green”. Consumers are much more aware of the importance of the environment and their personal well-being. Climate change is a big topic and many people feel they should contribute to a better environment by changing their way of consumption and by living a healthier lifestyle.

Today consumers demand products that have proven to be environmentally friendly and produced in a sustainable way to minimize negative impact on the environment. Products with less plastic and/or using biodegradable plastic, with clean labels (natural ingredients) and that have been organically produced. The latter in general means that the farming methods are less polluting, use less energy, conserve water and reduce soil erosion. No GMOs and chemical pesticides are used.

Producers in the health and beauty industry have to respond to this market demand and give consumers a reliable informed choice. This is why today we see many products on the market that are being advertised as being organic or natural.

A question that we often get from our customers: What is needed to carry these “green” claims on our products?  

Food supplements

Only food supplements produced from agricultural ingredients fall under the scope of Regulation (EU) 848/2018 and can be labelled as organic provided that the product complies with the Regulation regarding:

·     Production methods
·     Product labelling
·     Adherence to the control system (code number of the control body)

Food supplements imported from third countries having an organic production standard and control system recognized by the EU for purposes of equivalence, may also be labelled as organic. Organic food supplements imported from third countries will be checked at an EU border post before it will be released on the Union market.

Legally offered organic products on the EU market can be recognized by the code on the label by one of the EU controlling bodies. Each EU member state has one or more controlling bodies.

Food supplements produced including vitamins and minerals as ingredients do not fall under the scope of organic legislation and cannot be labelled as organic under EU Regulation 848/2018.

Cosmetic products

There are quite some European certification bodies that advertise their certification criteria for organic and natural as being the European harmonized standard.

However to this day, the terms natural and organic are not regulated by EU law for cosmetic products. The EU Commission even states that the different criteria used by the certification bodies may lead to unfair and misleading information for consumers.

To give more clarity the International Organization for Standardization provided guidelines on definitions and criteria for natural and organic cosmetic ingredients and products by publishing ISO 16128-2 in 2017.

It is expected that at some point in time EU legislation will be implemented to determine when a cosmetic product may be called natural or organic to promote fair competition in which consumers can make a well-informed choice. For now, it is best to follow the criteria as set in the ISO standard.

Conclusion / Insight

Food supplements claiming to be organic need to comply with Regulation (EU) 848/2018 on a number of aspects. To claim cosmetic products to be organic or natural it is best to follow ISO 16128-2:2017.

In case you are interested to know more about organic and natural claims, please do contact me directly.

Published: March 2020