The term “organic” has 3 different meanings: organic farming, organic (carbon-carbon bond) chemistry and natural cosmetics based on defined provenience.
It is often linked to environmentally friendly farming practices – avoiding fertilizers, pesticides, GMOs, antibiotics, radiation, and focusing on soil health, biodiversity, and human safety. These principles apply only to the raw materials used in organic and natural cosmetics, but not to the finished cosmetic product.
In cosmetics, the label „organic“ refers only to the provenience of the raw materials, not the manufacturing process or the product’s environmental impact after use by consumers (unlike organic food).
The Cosmetic Products Regulation (CPR) focuses on products that are applied to the skin, including how they’re used and the claims made. While environmental issues matter, they are not part of the CPR’s scope. Instead, they are covered by other laws like EmpCo and the German Act Against Unfair Competition (UWG).
Why a definition is needed in article 20 of the CPR: a clear legal definition of “organic and natural cosmetics” in article 20 would help separate cosmetic regulations from environmental or competition laws.
The cosmetic „organic“claim is misleading: it has no importance to enviroment, but only gives information on raw material provenience.
A legal definition of „organic and natural cosmetics“ has a variety of advantages in addition:
- Small cosmetic companies that meet high natural standards are often excluded from the market since they can’t afford expensive certification or licensing fees. Only one free of charge label (“Natural Alliance”) is currently available.
- An official definition in the CPR would allow these small and medium-sized businesses to legally market their products without paying for a label.
- Consumers would benefit from more product choices and lower prices, as companies wouldn’t need to pay for certification licenses.
- Market access would be fairer, and quality would matter more than the ability to afford a label.
- The industry would no longer be dominated by a few certifying bodies, which currently hold a near-monopoly in countries like Germany.
Including a definition of “organic and natural cosmetics” like natural alliance standardin article 20 of the CPR would:
- Protect small businesses
- Increase consumer choice
- Lower product costs
- Encourage fair competition based on quality
- Clarify legal responsibilities, separating them from unrelated environmental and competition laws