Natural & Organic

Natural and organic are among the most powerful claims in the market and among the least defined in law. Neither term has a legal definition in EU or UK cosmetics law, so a brand cannot simply assert them. The discipline lies in the claims rules, the voluntary certification standards, and the harder reality that a natural formulation is not automatically a safe or stable one.

No legal definition, so the claims rules govern

Because “natural” and “organic” are not defined in the Cosmetics Regulation, any such claim is controlled by Article 20 and Commission Regulation (EU) No 655/2013, the six Common Criteria, and the Commission’s Technical Document on claims. A claim has to be truthful, supported by evidence, honest, fair and able to support an informed decision. “Free-from” claims are particularly constrained: the Technical Document does not permit a “free-from” claim that denigrates a legally permitted and safe ingredient, so “free from parabens” or “free from preservatives” cannot be used to imply that an otherwise safe ingredient is harmful. The claim, not just the formula, is part of what we assess.

The voluntary standards

Certainty comes from the voluntary standards rather than the law. ISO 16128 provides a common method for calculating the natural, naturally derived and organic content of an ingredient and a product, but it is a calculation framework, not a certification or a safety standard. The recognised certification schemes are COSMOS (operated through Ecocert, the Soil Association, Cosmebio, BDIH and ICEA) and NATRUE, which set thresholds for natural and organic content and audit against them. Certification is private and optional, but a certified claim still has to satisfy the law, and an uncertified “natural” claim has to be substantiated just the same.

The preservation challenge

Natural positioning narrows the preservative options, since many effective synthetic preservatives are excluded by the standards or by the brand’s own promise. That raises the microbiological risk, and the safety report and preservative-efficacy (challenge) testing to ISO 11930 have to demonstrate that the chosen natural system actually protects the product across its in-use life. “Preservative-free” is itself a claim that needs care, because a product must still be microbiologically safe by some means.

Natural is not safe

The most important point for an assessor is that natural origin carries no presumption of safety. Botanical extracts and essential oils can be potent sensitisers, phototoxic or rich in fragrance allergens, and they are assessed with exactly the same rigour as synthetic ingredients. A natural claim does not lower the safety bar; if anything it raises the attention paid to the actives.

How we help

We substantiate natural and organic claims against the Common Criteria and the Technical Document, keep “free-from” and “preservative-free” claims on the right side of the guidance, assess and challenge-test the natural preservation system, and treat botanical actives at full rigour. Where a brand is pursuing COSMOS or NATRUE certification, we align the safety file and the claims with the standard.