NATRUE speaks up for consumers

Why the ISO 16128 guidelines for natural and organic cosmetics do
not have consumer interest at heart
In September 2017, the International Organisation for Standardisation (ISO) officially issued Part 2 (ISO
16128-2:2017) of the guidelines covering the technical definitions and criteria for natural and organic
cosmetic ingredients and products. Part 1 (ISO 16128-1:2016) was issued in February 2016, and now
with this second part complete a producer or manufacturer can now freely use these guidelines.

ISO is an independent, non-governmental international organisation that creates documents setting

specifications, requirements or guidance on a topic. The process brings together expertise from a sector
to address solutions to global challenges. Generally speaking through standardisation complexity can
be reduced, and with it barriers to trade. As such, this approach is something that could have been of
considerable benefit to the natural and organic cosmetic sector.

“Without prejudice, NATRUE welcomes internationally agreed initiatives aimed at reducing complexity
and barriers to trade, with an emphasis on combating ‘greenwashing’, which is the reason why the
NATRUE Label exists. We believe strongly that consumers should not be misled by products claiming
‘natural’ and organic’ but this requires strict criteria to benchmark them”, comments Dr Mark Smith,
Director at NATRUE.
Unfortunately, the outcome of this international process, the ISO 16128 guidelines, has fallen short of
current private standards’ requirements, and there is no guarantee that products made to ISO guidelines
will be consistent with consumer expectations, especially within established markets such as the EU.
The broad permissions and flexibility of approach of the ISO guidelines fail to combat greenwashing
that, at heart, still misleads consumers, fragments the market place, and impacts those innovative
producers of authentic products. As such, even if both are voluntary schemes, use of the ISO guidelines
cannot provide the same immediacy and transparency to reassure consumers and match their
expectations as current private standards.

The 3 critical points overall regarding the ISO 16128 guidelines which do not improve the current status
quo regarding greenwashing, and significantly differ from private standards, are:

 General lack of transparency for consumers

The guidelines can only be accessed by paying and, even if purchased, the guidelines alone will not
clarify how they have been used in practice.

 Permitted ingredient origin

Petrochemical Ingredients

Users of the guidelines are not obliged to restrict the use of petrochemicals whatsoever. Consumers
would not expect mineral oil to be in authentically natural products but ISO 16128 allows it. This is an
example of how the guidelines are fundamentally inconsistent with the principles of the sector, and do
not help the evolution and growth of the sector or solve the core issue surrounding greenwashing.

GM plants

Consumers do not expect cosmetic ingredients coming from sources like genetically modified plants
(GMOs) to be permitted in natural and organic cosmetics. Consumers are currently reassured on this
point as each of the most established private standards for natural and organic cosmetics guarantees
a ban on such ingredients.
  Verification, control and identification of finished products

Part 2 of the guidelines provides calculations to determine the natural or organic ingredient content;
these can be voluntarily authenticated by certification. However, ISO certification using ‘flexible’
guidelines is not on a par with certification to a recognised set level of naturalness or organic content
by a private certification standard that certifies to specific criteria.

Certification to ISO 16128 only authenticates that the calculation was carried out correctly, as the
guidelines have no benchmark to establish at what percentage content a product can claim or be
considered natural or organic. These are out of scope of ISO 16128 and remain the responsibility of the
regulator.

Consumers have grown to expect some kind of verification logo or seal on a product to assure them of
its authenticity. In a study commissioned by NATRUE from research organisation GfK it emerged that
over 60% of consumers are reassured by the presence of a label on natural and organic cosmetics.
There is no proposed stamp or seal for the ISO guidelines.

Now we’re here, what do we want from our future?

It should be remembered that the ISO guidelines are purely voluntary; their availability does not
represent an automatic change in the regulatory framework for natural and organic cosmetics. Countries
might choose to adopt the ISO guidelines but there is no obligation.

For the time being ISO 16128 does not change the status quo and leaves space for products that
continue, at best, or increase at worst, greenwashing. If a regulatory body were to adopt the guidelines
directly in their current state, the market risks being swamped with legitimate but “nature-inspired”
products, as opposed to truly authentic natural products, thereby generating confusion amongst
consumers and negatively impacting authentic producers.

To provide consumers with the products they expect, NATRUE advocates that any future regulatory
procedure for natural and organic cosmetics, including an official definition or specific guidance for
product claims ‘natural’ or ‘organic’, must be strict.
One crucial factor is to maintain trust for future sector growth. This means proactive commitment to stop
greenwashing, and nurturing an environment of transparency and authenticity where products deliver
claims that meet established consumer expectations for natural and organic cosmetics.
“NATRUE is the only association uniquely placed to represent the natural and organic cosmetic sector
through its seat at the European Commission Working Group on Cosmetics. This privileged position
allow us to directly participate and contribute to evolving legislation, like claims, and actively campaign
to support initiatives that help the whole sector to progress and prosper without undermining consumer
trust”, concluded Dr Smith.

Press Contact:
Dr. Mark Smith, NATRUE Director
msmith@natrue.eu
Tel.: +32 2 613 29 32