Green Claims Dces


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  • That’s what I’m here to do today – talk about it! Talk about it because most are confused about it and yet everyone is trying to capitalize on it. However, it is a vast subject matter and there is no way that I can discuss it exhaustively in 40 min. What I hope is to put a little perspective on the subject matter. Specifically I will be…
  • I believe “Green” is more than just a trend. As I have discussed in 2 recent HAPPI articles, green is a pervasive global phenomenon HAPPI (Household and Personal Products Industry)
  • So going “Green” or developing a “Green” product is not an all or none situation It is a progressive phenomenon – a balancing act whose goal is to reach ever darker shades of “Green” In other words there is no such thing as a totally “Green” product or process but only shades of “Green”
  • My model if you will, is an equilateral triangle lens that looks at 3 essential elements: 1-Respecting Living Things; 2-Respecting the Environment; 3- Economic Development The shade of “Green” that a product or process is, depends on the balance of these 3 essential elements
  • They may do so willingly – that is set up green programs – or unwillingly.
  • As regards to external factors, as ones customers and consumers are becoming more “Green” conscious they want to do business with partners who are also “Green” To obtain economic growth and stay competitive one would need to meet the demands of the “Green” conscious consumers These “Green” conscious consumers will increase in numbers as the “Green” ideals are popularized Back in September of 2007, Susan and I discussed some of Wal*Mart’s Green initiatives and if you are interested in knowing more – I refer you to this article.
  • Harvey, F. August 13, 2007. A chance for shoppers to start counting the carbon. Financial Times.
  • So I ask, can your company afford not to become a “Green” company in the public’s eye? To me, making a conscious and concerted effort to become a darker shade of “Green” makes economic sense for any Company Stay competitive Increase efficiency Meet demands of a new and ever increasing “Green” conscious customers & consumers
  • And besides, if one looks at the financial news regarding Green companies it becomes apparent that investors favor them. Deutsch, C.H. August 25, 2007. Green and Fashionable. Saturday Interview, The New York Times, Business Day.
  • A global mega-trend to be more accurate.
  • 2 characteristics of green that need clarification are the terms natural and organic. Hmmm!, what is a natural ingredient? If one can clarify that, one would be able to formulate a natural cosmetic. 1-Organic Consumers Association. 2006. Natural Cosmetic Boom in EU, Though Debate Continues Over Which Brands are Actually Organic. Press Release. NPIcenter, Mississauga, ON, Canada, Sept. 19 (, retrieved 8/16/07).
  • Because of the heightened Industry interest and lack of clear guidance I made an attempt to address what is “natural” and to perhaps galvanize the Industry to action by publishing my views in HAPPI (Household and Personal Products Industry) Magazine, back in December of “04. 1-as shown
  • More recently… If you want to know what these guidelines are one may look them up at this web address… Laus, Molly. May 28, 2007. Burt’s Bees & Natural Products Association to Develop standard for Naturals. The Rose Sheets, page 3.
  • Fueled by the lack of U.S. industry standards and the increased harmonization efforts of similar policies and standards in the EU, several US companies in the natural and organic cosmetic sector got together to form OASIS. The organization has 30 founding member companies which include both product and ingredient manufacturers as well as distributors.
  • Anyway, besides these efforts from the industry to come to a consensus, to date…
  • E.g. of 2 nd subbullet  Coconut oil can be squeezed from the coconut, but can also be made synthetically to the exact same qualities. The synthetic can be made more efficiently and is cheaper. So if you apply my green model the synthetic may turn out to be more green than the natural one.
  • 3 rd bullet  CA is the only state that regulates “Organic” claims for all products, including cosmetics, as I will discuss next.
  • Even if one does not consider keeping pace with the competition, new chemical scares and unverified or unsubstantiated claim about health benefits of natural & organic personal care products will continue to drive sales growth. Furthermore, these sales growths will continue to be fueled by the “Green” movement.
  • Bird, Katie. (11/13/07). Chemical concerns drives UK naturals market. Cosmetics (, as retrieved on 11/13/07).
  • So, if your company decides to take advantage of the eco-friendly trend.. Basically, anything sourced from the biosphere and minerals (e.g. talc, mica, etc.) without chemical modification.
  • The USDA NOP has a definition of what is organic. Because it is wordy I did not make a slide of it but if one is interested one may view it at the given web address.
  • National Organic Program: (retrieved 8/29/70) The USDA recently allowed NOP-approved agents to grant its seal on cosmetic products if indeed they meet all NOP requirements.
  • Official Journal of the European Union, 20.7.2007 EN L 189/1-23. Council Regulation (EC) No 834/2007 of 28 June 2007 on organic production and labelling of organic products and repealing (EEC) No 2092/91.
  • As I mentioned before, to date, CA is the only state that regulates organic cosmetics. Steinberg, D. June 20, 2007. Natural Ingredients in Cosmetics. IntertechPira Workshop. Washington DC, USA. California Health and Safety Code. Article 7. The California Organic Products Act of 2003, Division 104, Part 5.
  • We already discussed the USDA organic seal. The E COCERT & BDIH seals are the ones most likely to be found on cosmetic packaging. In a moment I will discuss the difference between the ECOCERT & BDIH guidelines to show you how varied they can be.
  • The next 2 slides are some R&D guidelines for developing an ECOCERT product. If your product follows the ECOCERT guidelines and get approved by them you may claim one of the following… & display the ECOCERT logo on the PDP of your product.
  • These are generally the guidelines that your products must meet to be certified by ECOCERT.
  • The BDIH guidelines are less stringent than the ECOCERT. Note: Most of these I took from the ECOCERT guidelines.
  • Note: Most of these I took from the ECOCERT guidelines.
  • This is why I said the BDIH guidelines are less stringent than the ECOCERT (1 st bullet).
  • Now, what do seals mean to the consumer? Again, although they may not differentiate one seal from another, they do give the consumer confidence that the product has met certain criteria and they may trust such a product more. Organic Consumers Association. Septrmber 19, 2006. Natural Cosmetics Boom in EU, Though debate continues over which brands are actually organic. Press Release, NPIcenter, Mississauga, ON, Canada. Bird, Katie. (11/13/07). Chemical concerns drives UK naturals market. Cosmetics (, as retrieved on 11/13/07).
  • Bird, Katie. (10/30/07). Multinationals flex natural muscle. Cosmetics (, as retrieved on 11/11/07).
  • Green Claims Dces

    1. 1. Green Claims: A Regulatory Perspective on the “Eco-friendly Movement By Lambros Kromidas, M.S., Ph.D.
    2. 2. Points of Discussion <ul><li>What is this thing we call “Green”? </li></ul><ul><li>Can your company afford not to be “Green”? </li></ul><ul><li>What are natural cosmetic products, who regulates them, and should your company make them? </li></ul><ul><li>What are organic cosmetic products and who regulates them? </li></ul><ul><li>Introduce you to the most recognized certifications/seals and show you how varied their standards are. </li></ul>
    3. 4. Disclaimer <ul><li>“ The viewpoints expressed in this presentation are those of the author and do not necessarily reflect those of Coty Inc.” </li></ul>
    4. 5. What is this Eco-friendly Concept We Call “Green”? <ul><li>Not clearly defined anywhere </li></ul><ul><ul><li>It is a concept, life-style, and or code of ideals whose essential elements are: </li></ul></ul><ul><ul><ul><li>Sustainability, </li></ul></ul></ul><ul><ul><ul><li>Naturalness, </li></ul></ul></ul><ul><ul><ul><li>Wholesomeness (organic), </li></ul></ul></ul><ul><ul><ul><li>Environmentally friendly, </li></ul></ul></ul><ul><ul><ul><li>Cruelty free, </li></ul></ul></ul><ul><ul><ul><li>Safe for use or consumption, and </li></ul></ul></ul><ul><ul><ul><li>economic vitality, and </li></ul></ul></ul><ul><ul><ul><li>more </li></ul></ul></ul><ul><ul><li>The more of these elements a process or product meets the “Greener” it is </li></ul></ul>
    5. 6. <ul><li>It is a pervasive global phenomenon </li></ul>What is this Eco-friendly Concept we call “Green”? On the Road Toward Green, Part I & II. HAPPI, March & April, 2008, Issues.
    6. 7. <ul><li>Refers to a process, product, or both </li></ul><ul><ul><li>Example: </li></ul></ul><ul><ul><ul><li>One makes a biodegradable product but the energy used to make it and transport it was not optimal (i.e., used too much or was petrochemical) </li></ul></ul></ul><ul><ul><ul><li>***Light shade of “Green”*** </li></ul></ul></ul><ul><ul><ul><li>Solar energy was used to make this biodegradable product </li></ul></ul></ul><ul><ul><ul><li>***Medium shade of “Green”*** </li></ul></ul></ul><ul><ul><ul><li>Solar energy was used to make this biodegradable product and wind energy to transport it </li></ul></ul></ul><ul><ul><ul><li>***Dark shade of “Green”*** </li></ul></ul></ul>What is this Eco-friendly Concept we call “Green”?
    7. 8. “ Green” Model Respect for the Environment Respect for Living Things Economic Development
    8. 9. <ul><li>In my view, due to external and inevitable pressures, companies have to become more “Green” in order to stay competitive. </li></ul>What is your Company’s Shade of “Green”?
    9. 10. <ul><li>There are external factors that are driving your company to take on a darker shade of “Green” </li></ul><ul><ul><li>Customers </li></ul></ul><ul><ul><ul><li>Wal*Mart </li></ul></ul></ul><ul><ul><ul><li>Carrefour </li></ul></ul></ul><ul><ul><ul><li>Boots </li></ul></ul></ul><ul><ul><ul><li>etc. </li></ul></ul></ul><ul><ul><li>Consumers </li></ul></ul>What is your Company’s Shade of “Green”? Happi, September 2007
    10. 11. <ul><li>Boots and bunch of other European companies – most in the UK </li></ul><ul><ul><li>Putting carbon labels on their products  “Carbon Footprint” </li></ul></ul><ul><ul><ul><li>A calculation of the amount of the CO 2 expelled into the atmosphere as a result of the process that went into the items production </li></ul></ul></ul><ul><ul><li>>50% of UK people value information on a product’s carbon footprint when making a buying decision </li></ul></ul><ul><ul><li><50% however will use this information to switch to a product or service with a lower carbon footprint </li></ul></ul><ul><ul><li>60% do not think company’s claims of “Green” to be credible </li></ul></ul><ul><ul><li>And yet! </li></ul></ul><ul><ul><li>Tesco, a supermarket chain in 12 countries pledges to have carbon labels on every one of its 70K products on its shelves </li></ul></ul>“Green” at Work
    11. 12. <ul><li>Can you afford not to become a “Green” company in the public’s eye? </li></ul><ul><li>Making a conscious and concerted effort to become a darker shade of “Green” makes economic sense for any company </li></ul><ul><ul><li>Stay competitive </li></ul></ul><ul><ul><li>Increase efficiency </li></ul></ul><ul><ul><li>Meet demands of a new and ever increasing “Green” conscious customer & consumer </li></ul></ul>What is your Company’s Shade of “Green”?
    12. 13. <ul><li>Saturday, August 25, 2007 – The New York Times Business Day </li></ul><ul><ul><li>In an interview of George Feldenkreis, Perry Ellis Chairman </li></ul></ul><ul><ul><li>“ Investors seem to favor green companies these days, too. If Wall Street will pay for green, it means they think customers will pay for green.” </li></ul></ul>What is your Company’s Shade of “Green”?
    13. 14. <ul><li>“ Green” is a global mega-trend! </li></ul>Is “Green a Global Trend?
    14. 15. <ul><li>Although there is increasing consumer awareness and interest in naturals and organics, the same cannot be said of the definitions of these terms </li></ul><ul><ul><li>As such, a lot of problems relate to definitions and perceptions of what actually is natural </li></ul></ul><ul><li>Unlike organic foods, there is no US or EU regulations for natural and organic cosmetics </li></ul><ul><ul><li>But there are private standards of natural and organic cosmetics </li></ul></ul><ul><ul><li>As a result, some conventional cosmetics are marketed as “natural” only because they contain some natural ingredients at low levels </li></ul></ul><ul><ul><li>No clear definition + no regulatory standards  confused consumers </li></ul></ul>What’s a Natural Product?
    15. 16. What’s a Natural Product?
    16. 17. <ul><li>Burt’s Bees Chief Marketing Officer, Michael Indursky, Chaired a working group convened by the Natural Products Association (NPA) to create guidelines for what constitutes a natural product </li></ul><ul><ul><li>Make the concept comprehensible to consumers </li></ul></ul><ul><ul><li>Work on a seal to id natural products </li></ul></ul><ul><li> </li></ul>What’s a Natural Product?
    17. 18. <ul><li>Companies sitting on the Founding Board of Directors </li></ul><ul><li>Aimed at providing clear industry standards. </li></ul><ul><ul><li>Perfect Organics Inc. </li></ul></ul><ul><ul><li>Cosway Company </li></ul></ul><ul><ul><li>Hain Celestial </li></ul></ul><ul><ul><li>Private Label Select </li></ul></ul><ul><ul><li>Aveda Corp. </li></ul></ul><ul><ul><li>Cognis Corp. </li></ul></ul><ul><ul><li>Oh, Oh Organic Inc. </li></ul></ul><ul><ul><li>Depth Body LLC </li></ul></ul><ul><ul><li>L'Oreal </li></ul></ul><ul><ul><li>Foodwise, Inc. </li></ul></ul>
    18. 19. <ul><li>A group established to lobby for the interests of the leading natural cosmetic firms in Europe </li></ul><ul><li>Founding companies include: </li></ul><ul><ul><li>laverana/lavera </li></ul></ul><ul><ul><li>Logocos/Logona </li></ul></ul><ul><ul><li>Primavera </li></ul></ul><ul><ul><li>Santaverde </li></ul></ul><ul><ul><li>Wala/Dr. Hauschka </li></ul></ul><ul><ul><li>Weleda. </li></ul></ul>
    19. 20. <ul><li>There is no legal definition of “natural” for drugs, CFT, dietary supplements, or most foods </li></ul><ul><li>The only governmental definition is that given by USDA for meat and poultry </li></ul><ul><ul><li>USDA allows this term only if the product contains no artificial ingredients, coloring agents, and chemical preservatives </li></ul></ul><ul><ul><li>Also, the product and its ingredients are minimally processed </li></ul></ul>What’s a Natural Product?
    20. 21. <ul><li>Since there is no legal definition for what is “natural,” defining it in a cosmetic sense is especially confusing </li></ul><ul><ul><li>For some in the industry, anything synthetic or chemically modified is absolutely not “natural” </li></ul></ul><ul><ul><li>Others argue that ingredients that are made synthetically to an exact “counterpart” in nature can be considered natural </li></ul></ul><ul><ul><li>Some insist that anything refined is not “natural” </li></ul></ul><ul><ul><li>Some believe mixtures of naturals (as primary ingredients) that include a small amount of solvent, not found in nature, and are mixed with water can be classified as “natural” </li></ul></ul>What’s a Natural Product?
    21. 23. <ul><li>CFT are not regulated by the USDA but by the FDA </li></ul><ul><li>The FDA & EU Cosmetics Directive have no specific regulations regarding the claim “natural” </li></ul><ul><li>Furthermore, unlike “organic” claims there are no state regulations regarding the claim “natural ” </li></ul><ul><li>“ Natural” claims are regulated just like any other claim </li></ul><ul><ul><li>Truthful </li></ul></ul><ul><ul><li>Not misleading </li></ul></ul>L. Kromidas -- 7/21/04 Bottom-Line
    22. 25. Should Your Company Produce Natural Cosmetic Products? <ul><li>Competitors are doing it </li></ul><ul><li>Chemical scares </li></ul><ul><li>Health benefits of natural and organic products </li></ul><ul><li>“ Green” movement </li></ul>
    23. 26. Chemical Scares <ul><li>Nov. 13, ’07 – Organic Monitor reported that 89% of UK consumers are concerned by toxic chemicals </li></ul><ul><ul><li>Especially preservatives and surfactants </li></ul></ul><ul><li>As such, consumer attempts to avoid negatively publicized chemicals are driving the UK market for natural cosmetic products </li></ul>
    24. 27. What Should your Company’s Definition of a Natural Product Be? <ul><li>Should be composed of ingredients that are not chemically synthesized or intentionally chemically modified by man </li></ul><ul><li>Must be market competitive </li></ul><ul><ul><li>i.e. Burt’s Bees & NPA </li></ul></ul><ul><li>Should be capable of acquiring various “Green” seals (e.g. USDA Organic, Ecocert, BDIH, etc.) </li></ul>
    25. 28. <ul><li>USDA’s National Organic Program: (retrieved 8/29/70) </li></ul><ul><li>Basically, it is an agricultural practice that denotes </li></ul><ul><ul><li>food materials were grown without the aid of genetically modified organisms (GMO), </li></ul></ul><ul><ul><li>grown without the use of synthetic pesticides, </li></ul></ul><ul><ul><li>synthetic fertilizers, </li></ul></ul><ul><ul><li>and the exclusion of sewage sludge </li></ul></ul><ul><li>It denotes such a product was packaged and processed </li></ul><ul><ul><li>without synthetic ingredients, </li></ul></ul><ul><ul><ul><li>Unless found under the National List provision </li></ul></ul></ul><ul><ul><li>synthetic preservatives, </li></ul></ul><ul><ul><li>and irradiation </li></ul></ul>Definitions: Organic
    26. 30. Definitions: Organic Claims <ul><li>4 levels of organic claims for foods </li></ul>
    27. 31. Definitions: EU Organic Regulations <ul><li>No specific regulations regarding the labeling of organic cosmetic products </li></ul><ul><li>June 28, 2007 – Organic regulations were published strictly regarding food and feed </li></ul><ul><ul><li>No reference to cosmetic products </li></ul></ul><ul><ul><li>As regards processed food at least 95% of its agricultural origin ingredients by weight must be organic </li></ul></ul><ul><ul><ul><li>Otherwise, similar to those of USDA’s NOP </li></ul></ul></ul>
    28. 32. <ul><li>Applies to foods and cosmetics sold in CA </li></ul><ul><li>70%, certified organic by NOP </li></ul><ul><li>30%, no restrictions </li></ul><ul><li>Claims </li></ul><ul><ul><li>Certified Organic </li></ul></ul><ul><ul><li>Made With Organic Ingredients </li></ul></ul><ul><li>No USDA seal </li></ul>Definitions: California Organic Products Act (COPA) of 2003
    29. 33. Definitions: Certification & Seals <ul><li>There are numerous recognized “Green” based certificates and seals that one may apply for depending on the product and what it is one wants to convey about their product </li></ul><ul><li>Certification is a process based management system </li></ul><ul><ul><li>Protects integrity of product </li></ul></ul><ul><ul><ul><li>Defines standards, practices, and material </li></ul></ul></ul><ul><ul><ul><li>Covers entire production and distribution process – from field to shelf </li></ul></ul></ul><ul><ul><li>3 rd Party verification or accreditation </li></ul></ul><ul><ul><li>May have government backing/recognition, trade group backing or simply self made </li></ul></ul><ul><ul><li>Provides consumer confidence </li></ul></ul>
    30. 34. Example of Self Made Seal
    31. 35. Most Recognized Seals The certified bio and ecologic cosmetics (organic). Non-governmental organization established in France but recognized by many others in Europe. BDIH Certified Natural Cosmetics. Non-governmental organization established in Germany but recognized by other countries in Europe. UK Association of the organic agriculture. Non-governmental organization used for organic cosmetics in UK. Note: not an exhaustive list. Ecoflower/ecolabel. EU non-governmental organization whose purpose is to identify and promote products and services that are green oriented. US Government certification for organic food but now also allowed on cosmetics. US independent non-profit organization whose purpose is to identify and promote products and services that are green oriented.
    32. 36. <ul><li> </li></ul><ul><li>Ecological </li></ul><ul><li>Ecological and Organic </li></ul>ECOCERT Claims/Advertising/Labeling PDP
    33. 37. ECOCERT Product Formula
    34. 38. <ul><li> </li></ul><ul><li>Produced according to the BDIH guidelines </li></ul><ul><li>Other possible claims </li></ul><ul><ul><li>Ecological </li></ul></ul><ul><ul><li>Environmentally-friendly </li></ul></ul><ul><ul><li>Wholesome care </li></ul></ul><ul><ul><li>Claims related to organic </li></ul></ul><ul><ul><li>Ethoxylated products and glycols have not been used </li></ul></ul><ul><ul><li>The finished product has not been tested on animals </li></ul></ul><ul><ul><li>Paraben has not been used </li></ul></ul>BDIH Claims/Advertising/Labeling
    35. 39. <ul><li>Other possible claims </li></ul><ul><ul><li>100% free from synthetic: preservatives, Perfumes, Colorants, Mineral oil, etc. </li></ul></ul><ul><ul><li>100% pure vegetable oils, active plant agents, essences, etc. </li></ul></ul><ul><ul><li>Produced according to the BDIH guidelines against animal testing. </li></ul></ul>BDIH Claims/Advertising/Labeling
    36. 40. BDIH Plant Raw Material <ul><li>As far as possible, raw materials obtained from plants should be used from: </li></ul><ul><ul><li>controlled biological cultivation (i.e., organic), taking quality and availability into account, or </li></ul></ul><ul><ul><li>controlled biological wild collections (i.e., certified wild harvest) </li></ul></ul>
    37. 41. Plant Ingredients/Raw Material <ul><li>List of plants that must be organic: </li></ul>
    38. 42. <ul><li>There is no level of natural/organic content </li></ul>BDIH Product Formula
    39. 43. <ul><li>Sept. ’06 -- Organic Monitor </li></ul><ul><ul><li>consumers are unable to differentiate between products that are certified by organizations like BDIH and Soil Association </li></ul></ul><ul><li>Nov. ’07 – Organic Monitor </li></ul><ul><ul><li>79% of natural/organic cosmetic buyers are willing to pay extra for certified products </li></ul></ul><ul><ul><li>However only 35% of consumers looked for certification logos when buying natural products </li></ul></ul>Definitions: Certification & Seals
    40. 44. <ul><li>Recently some European certification bodies, including Ecocert, BDIH, and Soil Association, are attempting to harmonize their respective systems </li></ul><ul><ul><li>They plan to introduce the natural and organic standards in June 2008 </li></ul></ul><ul><ul><li>It’s a 1 st step in introducing European wide standards </li></ul></ul>Definitions: Certification & Seals
    41. 45. THANK YOU!