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Labeling compliance for a non certified organic cosmetic

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Posted 03 April 2017 - 03:06 PM

I would like to know if I can write in large print on the information panel of the label 70 % organic for my hand and body lotion or should i move the 70% Organic to smaller print under the ingredient list?


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Posted 06 April 2017 - 08:11 PM

If the rules in the States are anything like those in the UK then I would tread carefully in this area. Although over here there are currently no legal definitions for 'organic' within cosmetics it could still be considered misleading if the other 30% is non-organic or are ingredients that would never be allowed in an organic product.

In food our rules are quite strict and if you want to use the term in whatever form you would need to gain certification.  We permit the use of the term within the ingredients list but you wouldn't be allowed to make a statement such as "made with 70% organic ingredients".  Furthermore even including the term organic in the ingredients list would require certification. The basic rule of thumb is that either a product is organic or it isn't.


The following links may be of some interest to you 






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Posted 06 April 2017 - 09:35 PM

Unless you get your plant and product certified, you cannot make Organic claims on the principal display of your product. You can list the organic ingredients by name and their percentage of the product on the information panel.



Can a product be labeled “organic” without being certified?

Overall, if you make a product and want to claim that it or its ingredients are organic, your final product probably needs to be certified. If you are not certified, you must not make any organic claim on the principal display panel or use the USDA organic seal anywhere on the package*. You may only, on the information panel, identify the certified organic ingredients as organic and the percentage of organic ingredients.

*Some operations are exempt from certification, including organic farmers who sell $5,000 or less.

Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

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