Chemical Watch: November 2013
Marketers know from a host of consumer studies that the first time most consumers become acquainted with products is at the point-of-purchase, which still primarily occurs in a brick-and-mortar store. Not only that, but also the majority of purchase decisions—despite the consumer's previous exposure to advertisements and other forms of promotion—are made at the point-of-purchase, sometimes rather spontaneously. All of this means that labelling and packaging decisions should be of paramount importance to product developers. Therefore, the decisions involved are not just about what is put into a product, but what goes on the product package—and to this latter point, the rules pertaining to desired claims.
For example in the United States, regulations surrounding most labelling decisions are under the purview of the U.S. Food and Drug Administration (FDA). There are labelling requirements for both categories of topical products, i.e., cosmetics and drugs, as well as certain claims that are allowed and disallowed depending on the product category—a rule that seems randomly enforced. By now, this area should be well-understood by marketers, although it is often abused as too many cosmetics companies continue to make claims that are not allowed, such as "reduces wrinkles" or "reverses aging." These drug claims are monitored by the FDA, although it has the resources to address only the most egregious of offenders.
Beyond Claims: The Proliferation of Certifications
In the world of natural and organic products, where many highly questionable active ingredient claims abound, there is another confusing labelling aspect through which consumers must sort: various third-party certifications. These relate to products that are greener, and more naturally derived and processed, but have become a source of further confusion for both consumers and marketers alike. On the other hand, having such certifications is helpful since government regulation is lacking in this high growth segment, resulting in "green washing" and product puffery among marketers.
Important North American Certifications
USDA: In the United States, there are a few highly recognizable seals commonly displayed on the labels of natural and organic personal care products. One of these is backed by the U.S. government. The U.S. Department of Agriculture (USDA) oversees a program that allows third-party organizations to denote products as "Certified Organic" if they meet the stringent requirements of the National Organic Program1 (NOP). The USDA standards were originally developed solely for food and not for topical products, so in the past there has been some difficulty in adapting them for personal care. This is the preferred seal in the United States if one's product is positioned as organic.
Another certification issued by the National Science Foundation (NSF) for products having less organic content, or for companies that do not wish to qualify their products for the USDA seal. This seal is a relatively recent introduction, developed to provide a distinction for products that contain lower levels of organic ingredients. It has yet to gain wider use by branded product manufacturers.
NPA Natural seal: Another certification that has proliferated in the United States is a seal whose origins lie in a task force organized and managed by this author, back in 2003. The task force, called the International Association of Natural Products Producers (IANPP), consisted of three dozen organizations from throughout the supply chain, which after three years finally succeeded in drafting a definition for "natural." Note that natural and organic are two different designations, and the Natural Products Association (NPA) seal deals only with "natural" and not "certified organic."
If the USDA Certified Organic and NPA Natural seals are achieving notoriety in the United States, what about other regions? As one might expect, the landscape is scattered with not-for-profit efforts to certify products as being something other than synthetically derived and/or synthetically processed.
Products are generally analyzed and rated along several different parameters, including the origin and processing of their ingredients, and the total composition of them in the product; their storage, manufacturing and packaging; environmental management; labelling and communication; inspection; and certification and control. The bottom line is that the certification must resonate with consumers in that particular country or region. Some markets, such as the U.S., have been a little late to the game of natural and organic personal care product certification. This is why the Ecocert seal (detailed later in this article), offered by a French certifier, is found on so many products in the United States. Until relatively recently, it was one of the only options available to American manufacturers.
COSMOS: While there are a number of different certifiers in Europe, the good news is their standards have been harmonized under the Cosmetics Organic and Natural Standard (COSMOS). This means that an Ecocert-labeled product will have been subjected to the same scrutiny as a BDIH product, for example; following, these are described in more detail.