The answer to this perfect example of double talk is –when it is “ISO 16128 – Guidelines on technical definitions and criteria for natural and organic cosmetic ingredients and products“
Background
The above guidelines are specific to the cosmetics sector, taking into account that most existing approaches are written for the agricultural and food sectors and so are not directly transferrable to cosmetics. The purpose of the guidelines is to encourage a wider choice of natural and organic ingredients in the formulation of a diverse variety of cosmetic products, thereby encouraging innovation. ISO 16128 Part 1 covers definitions for ingredients and ISO 16128 Part 2 is concerned with criteria for ingredients and products.
Comment
However, ISO 16128-1 has not been well received, particularly by awarding bodies. Many have taken issue with Note 1 in Section 2.1 which says, “Ingredients from genetically modified plants can be considered as natural ingredients…”. So much so, that the British Standards Institution has included the following paragraph in its national forward to the ISO standard:
“The UK committee draws users’ attention to Note 1 in Section 2.1. The committee feels that the terms ‘natural’ and ‘genetically modified’ are diametrically opposed by definition and deprecates the potential for GMO-sourced ingredients to be listed in a document that defines the criteria for natural and organic cosmetic ingredients.”
DIN (the German standards body) did not agree to the drafts of the guidelines and continues to comment critically on its contents.
There is a general feeling that ISO 16128 fails to deliver on integrity, transparency and clear standards which will lead to inconsistency and the risk of misrepresentation. The guidelines do not involve certification bodies; the calculated percentages written on products by brands will be based on declarations by suppliers – no certification body will check if the percentages are correct.
The guidelines do not list banned ingredients and forbidden processes. Thus, a brand could indicate ‘contains 80% natural ingredients’ on the label/packaging, without any limitation on any synthetic ingredients that might be present in the rest of the product. If this percentage is equal to or greater than 95% the product can be labelled as ‘natural product’, even if the remaining 5% is made up of controversial synthetic ingredients such as silicones, parabens etc. There are no restrictions on petrochemical ingredients; ‘derived natural ingredients’ can be up to 49.9% petrochemical.
It has been suggested ISO 16128 provides a cut-rate definition of ‘natural’ and increases the likelihood of greenwashing by more ‘creative’, unscrupulous brands. COSMOS goes so far as to say, “…we now have an ISO guideline that is deficient, counterproductive and allows misleading consumer information”. Organisations such as BDIH, Natrue and Cosmebio have also come out strongly against the guidelines.
Many feel the standard is in the interests of the cosmetics industry and not the consumer.
The overall perception is that this is a weak ISO standard which is likely to ‘muddy the water’ further, adding to the confusion in the marketplace.
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