Cosmetic Organic Standard - Important Facts on Packaging & Labeling

The COSMOS standard is sought globally by cosmetics companies to verify the organic or natural ingredients of associated products.

Definition of Organic

The term "organic" is defined by the COSMOS certification body to comply with existing regulations (EC 834/2007) and standards (Codex Alimentarius GL 32). Different nations have different criteria for organic production standards, but each manufacturer must comply with the COSMOS standard to gain approval from the certification body in order to display COSMOS signatures on products.

Part of the COSMOS standard requires a limit of 2 percent of petrochemical moiety in a finished product. This limit does not include NNIs (non natural ingredients) that come from a petrochemical origin but can also be found in nature. When the minimal particle size for a nanomaterial is over 100 nm, coating particles are allowed, otherwise they are not.

The COSMOS standard does not cover GMO plants as a source from cosmetic raw materials and ingredients. If such genetically modified material is used, the manufacturer must indicate in the Raw Material questionnaire the plant name and the country of its origin. The certification bodies will then determine the level of GMO risk according to Soil Association criteria.

Evaluation of Organic Elements

The following ingredients of animal origin are allowed as long as the processes are in compliance with the COSMOS standard: milk, honey and beeswax. Applicants are not allowed to perform new animal tests to evaluate the contents of an organic ingredient.

Stem cells, when used as active ingredients, are permitted if the culture media is compliant with the standard. Each ingredient must originate from a mineral, vegetable, microbial, animal or marine source, usually with a guarantee of non-GMO elements. Biotechnological processes may be conducted if there is no presence of genetically modified bacteria, fungi and yeast. Enzymes derived from GMOs may be used in production under the following conditions:

enzymes are first purified before use
GMOs are separated in closed vessels
GMOs are deactivated following production
risk assessment of GMO effects on the environment is applied
risk plan developed in the event GMOs are released to the environment
method must be established to prove no DNA of the GMO is detected in the final raw material

Requirements for Storage, Manufacturing and Packaging

Companies that give away free organic product samples at trade shows do not need to be licensed or audited by COSMOS. The product, however, must be made by a COSMOS-approved company. The primary and secondary packaging of organic products, along with their components, must comply with the COSMOS standard for packaging. Accessories to the products, however, are not required to conform. Here is a non-exhaustive list of accepted materials:

cellulose acetate
cellulose
ceramic
glass
metals (aluminum, iron, stainless steel)
paper or cardboard
polyethylene
polyethylene terephthalate
polyethylene terephthalate glycol
polylactic acid
polypropylene
rubber (from nature)
wood

The list of acceptable materials includes any other non-GMO materials that originate completely from nature. This list applies to major packaging materials, such as bottles, tubes, jars and boxes. All types of cosmetics products from skincare to haircare must adhere to this requirement. The only time protection sleeves and over-packaging are permitted are for small products, closure systems, solid soaps and massage bars.

Steps for COSMOS Certification and Labelling

product approval by the certification body
submission of proposed product labelling then approval
provisional approval for product specification that cannot be approved first
printing of labelling following full approval by the certification body
product or labelling changes must be sent to the certification body for approval
labelling must be approved to meet the COSMOS standard prior to the product launch

Essentially, a manufacturer or marketer can only use COSMOS terms and signatures on products with prior authorisation from the certification body. Furthermore, the product label must reveal the certification body if it is not found on the product. Vendors should consult the Labelling Guide to completely understand the requirements for labelling of organic and natural products.

One of the most essential aspects of labelling is that all the product information is accurate and does not mislead the consumer in any way. The use of the word "organic," for example, cannot be used as a brand name if there are no organic ingredients or there is no explanation that clarifies the contents. Any use of non-organic materials that do not comply with the COSMOS standard must be explained on the label. Additionally, the package must not include any logos or symbols
that imply certification in a misleading way.

Use of the COSMOS ORGANIC and NATURAL Signatures

In order for a company to legitimately use the COSMOS signature on packaging, the specific product must meet the COSMOS standard. In other words, just because a company has a line of products that include certified organic or natural products, doesn't mean the company can use the symbol on any other product it releases.

The signature must only be presented in a certain way on the front of the package. It must only be used when displayed in combination with the seal or logo of an organisation that is a member of the COSMOS standard AISBL. Additionally, the signature must be displayed in all capitals on two lines using the "Verdana Regular" font. The letters must each have the same size, width and colour. The width of the signature must be equivalent to that of the associated logo with a gap of 1/10 the width between the logo and the signature.

The colour of the organic signature, unless the applicant requests special permission, should be green, black, white or the same colour as the associated logo. The same requirements apply to use of the COSMOS NATURAL signature, except they pertain to the requirements of certification for natural products and the colour must not be green. The colour can be blue, black, white, the same as the associated logo or another colour by special permission.

Other COSMOS Signatures

The two other COSMOS signatures are COSMOS CERTIFIED and COSMOS APPROVED. The CERTIFIED signature can only be used for cosmetic products with organic ingredients that are certified to meet the COSMOS standard. A key difference between the CERTIFIED signature with the organic and natural signatures is that the colour must be black, white or the same as the associated logo, unless special permission is granted for use of another colour. In the case of an ingredient that can be certified as organic, the manufacturer may use the COSMOS ORGANIC or COSMOS NATURAL signature as an alternative to the COSMOS CERTIFIED signature.

The COSMOS APPROVED signature is not required but can be used only if the non-organic ingredients are approved for use by the certification body. The signature must be used the same way as the others in terms of font, size and placement, except the colour should be black, white, the same as the associated colour or another colour with special permission. Additionally, the associated logo may not include the term "organic" or any of its derivatives.

Since the COSMOS APPROVED signature does not mean a full inspection or certification was conducted, the label cannot state or indicate that the ingredient is certified according to the COSMOS standard. The packaging must not display the COSMOS ORGANIC, COSMOS NATURAL or COSMOS CERTIFIED signatures.