Date: 14th January 2011

Position Paper

Prepared by John R Warby B Sc, Grad Dip (Ind Eng), ASTC, FRACI

First issue: April 2007 – this issue January 2011

Abstract There is much discussion, debate and confusion on the meaning of terms such as ‘natural’, ‘naturally derived’, ‘organic’ etc as applied to personal care products. While there may be some guidelines when these terms are applied to other products (particularly foodstuffs), there are no such guidelines for the application of these terms when applied to personal care products

This paper outlines some appropriate definitions which are intended as a source of informed, reliable information for the lay person (as well as for the cosmetic scientist) but not necessarily intended as legal definitions.

Introduction In reviewing the use of various terms relating to ‘natural’ for the personal care area, it became evident that there appears to be neither regulatory definitions nor pronouncements from a professional/learned society. In the case of the former it has, on occasion, been placed in the ‘too hard basket’ and not necessarily seen as a priority by others.

The marketing of products is such that there is often the inference that if it is ‘natural’ (or ‘naturally derived’, ‘as found in nature’ and similar variations on the theme), then the product is better for you, better for the environment, or safer or more effective or some combination of these factors. There may be some of these benefits but often it is an inferential claim to induce a feeling of well being rather than based upon valid scientific data.

After reviewing definitions in both the Oxford English and Macquarie Dictionaries, statements in the literature and discussions with colleagues locally and overseas, the following definitions are proposed as suitable for both scientific and general communication purposes.

Natural – any material which has been harvested, mined or collected, and which subsequently may have been processed, without chemical reaction, to yield a chemical or chemicals that are identifiable in the original source material.

For the purpose of this statement, ‘without chemical reaction’ would permit washing, decolourising, distilling, grinding/milling, separation and/or concentration of the material by physical means.

Nature Identical – material produced by commercial synthesis which produces an end product chemically identical to that found in nature.

Such materials are usually synthesized due to factors such as difficulty in supply (seasonal variation in quality and/or quantity), harm to the original source material (particularly animals but also plants), inability to produce required commercial quantity by non synthetic means, cost effectiveness, etc.

There is wide spread use of the term ‘naturally derived’ without any indication of what this means – ideal for the marketer but much too vague to be informative.
It can reasonably be argued that everything can be claimed to be ‘naturally derived’ if you care to back track far enough. Clearly this provides a sufficiently large loop hole through which to drive the proverbial truck.

To limit the use of this term to something which is meaningful, the following definition (agreed by the ASCC Technical Committee) is proposed:

Naturally derived – materials where the majority of the molecule (not less than 50% by weight) is derived from natural materials as defined above.

There may be room for debate on the the minimum quantum of natural source material, but it is clear that this figure must be substantial to give any scientific (rather than marketing) credibility to this term.

In an ideal world and perhaps as a longer term objective, there should only be two such terms allowed for label copy – ‘natural’ (as defined above) or ‘synthetic’ (those materials which are not ‘natural’ – i.e. involving some chemical process, regardless of the source material)

While there still may be some debate over the need for all these definitions – specifically Nature Identical and Naturally derived – these are included as they are in common use and are presently needed to inform the consumer.

Once we accept these definitions as applicable to starting materials, then we need to consider the use of such terms for formulated products.

It is here that the matter becomes contentious. Only two classifications are proposed.

The first relates to ‘natural’ (formulated) product. After reviewing various ‘requirements’ found on sites such as Soil Association (UK), Non-Food Certification Co, (UK), EcoCert France, BDIH (Germany), and AIAB (Italy), an appropriate definition may be as follows:

A ‘Natural product’ is one in which ≥ 95% by weight of ingredients (excluding water) are ‘Natural’.

The reason for excluding water is to remove debate over whether water is ‘natural’ (mains water is often treated with biocide/fluoride etc), and at the same time removes a means of artificially inflating the percentage of so-called natural ingredients.

To allow some degree of latitude in products which would not meet these criteria, it may be feasible to have a class of ‘mainly natural’, ‘predominately natural’ or even ‘naturally derived’ (or words of the same import) product, providing that ≥ 50% by weight of ingredients (excluding water) are ‘Natural’ as defined above.


Soil Association (UK) –
Non-Food Certification Company (UK) –
EcoCert –
BDIH (Germany) –
AIAB (Italy) –

Various notes, columns and articles in journals - including Cosmetics and Toiletries; Soap, Perfumery & Cosmetics; Cosmetics, Toiletries & Aerosols in Australia.

ADDENDUM – Organic Personal Care Products

The Technical Committee has approved the following as a discussion draft relating to “organic’ personal care products

This proposal is based on the information provided to the subcommittee, which included a summary of comment/advice from a wide range of sources, and which was discussed at some length.

We recognise that the proposal may not be ideal, but does provide an interim and suitable basis for the ASCC to support. The premise is based upon the terminology used by the US Department of Agriculture for organic foodstuffs and applying this to organic personal care products

The agreed wording is:

A personal care product may be called ‘Organic’ if, excluding water and salt, it contains not less than 95% by weight of organically grown and certified raw materials; and as a consequence may contain not more than 5% by weight of non-organic or non-certified organic raw materials.

Similarly, personal care products containing 70 – 95% of organically grown and certified materials (excluding water and salt content), may be labelled as ‘Made with organic ingredients’.

We have purposely not sought to define, at this time, what ‘certification/certified’ means. We agreed that if asked, we would indicate that certification would be to an appropriate standard such as the UK Soil Association. We did not wish to become involved, at this stage, in determining which ‘standard’ should be the arbiter of ‘organic’.

Written comment, including any alternate proposals on this last section relating to ‘Organic’, will be welcome and considered by the subcommittee.

Any communication/comment should be sent to