There is currently no official regulatory definition for the cosmetic product claims ‘natural’ and ‘organic’ in the EU. While these claims of ‘natural’ and ‘organic’ are highly appealing to consumers, the lack of a precise regulatory definition runs the risk of exposing the consumer to misleading claims and malpractices known as greenwashing. In order to ensure trust through transparency when it comes to such claims, quality needs assurance. On the basis of the existing regulatory framework for cosmetics in Europe, third-party certification to voluntary private standards offers a means to substantiate such claims. Understandably, the compound costs of only using natural (non-GMO) or certified-organic raw materials that conform with the standards, as well as the need to certify the finished cosmetic product, may influence the price the consumer pays depending on the formulation, product category and brand positioning.

Of course, producing authentic organic or natural cosmetics is more expensive and more challenging, because of the price of ingredients and the limitations on the ingredient range that can be used. In addition to the certification cost, all these are factors that favour greenwashing. Nowadays, greenwashing in cosmetics takes various forms. For example,

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A highly qualified inspection workforce is needed to support organic integrity and promote confidence in organic certification. One widely acknowledged barrier to a sustainable pipeline of organic professionals is access to high-quality apprenticeship. With the global growth of organic demand and the ever-increasing complexity of organic supply chains, can the supply of newly trained inspectors keep up with the demand? In the current environment, with rigorous oversight by accreditors and fraud concerns, there is little room for ‘learning on the job’. Entry-level, inexperienced inspectors must hit the ground running at a higher level of competence. Added requirements, such as the Strengthening Organic Enforcement (SOE) final rule, have increased the number of operations that must be conducted in the USA, for example. And finally, many career inspectors are retiring, with the situation exacerbated by the Covid pandemic and a tight work force in many regions. More inspectors are needed, quality must be maintained and experience must be retained. Inspector burnout and the attractiveness of certifier roles that do not require as much travel lead many inspectors to leave the profession too soon.
The problem in a nutshell? Good inspectors cannot be made overnight. Experience is a critical component in developing the discernment expected of organic inspectors. They must know the regulation intimately, have a depth of technical knowledge, have well-developed communication skills, recognise when to dig further, and demonstrate attributes such as curiosity, tenacity and ethics. Ongoing continuing education and critical, knowledgeable feedback can make that inspector even better.
In the past two years, the International Organic Inspectors Association (IOIA) has been engaged in

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In our article in TOS 189, we described how the rules dealing with pesticide residues in organic products changed when regulations 847/2007 and 889/2008 were replaced by regulation 2018/848. In this second contribution we zoom in on the organic operator. What responsibilities do the farmer, processor, trader and shop owner have?
The new organic regulation requires that all operators take preventive measures. To prevent what? To prevent the operator mixing conventional products with organic ones, to prevent an ingredient declaration missing an asterix for an organic product, to prevent a cow from eating conventional grass, or the organic sweet peas in the field from receiving a dose of fungicide from the neighbouring farm? Remarkably, extra detailed rules have been made for the precautionary measures that prevent prohibited substances from ending up in an organic product. This particular focus on unauthorised substances can only be there through historical justification. In the next two paragraphs, we describe firstly, these precautionary measures and secondly, the situation in which, precautions or not, a non-authorised substance may be found in an organic product.

Precautions to take
It is common sense that it is in the interests of every organic operator to maximally protect the organic integrity of its production and products. After all,

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We are mere months away from 19 March 2024 – the date on which the United States Department of Agriculture (USDA) will require compliance with the Strengthening Organic Enforcement (SOE) Final Rule. If you need a deep dive into the details of this rule, please see articles in The Organic Standard from earlier this year. Here, we offer a quick reminder on who the rule impacts, and what to do if you think you might be impacted by this rule.

The SOE rule is intended to reduce fraud in the organic marketplace; strengthen oversight of organic producers, handlers and certifiers; and improve the USDA’s enforcement mechanisms. Its goal is to boost the integrity of the global organic market, bolster consumer confidence in the USDA organic seal, and transform oversight and enforcement of organic production worldwide. The rule creates stronger tools and processes that help to ensure compliance; implements robust and consistent enforcement of the organic regulations; improves farm-to-market traceability; enhances consumer and farmer trust in the USDA organic label; and creates a level playing field for organic farms and businesses.

Does the rule impact you? The rule impacts most, if not all, entities in organic supply chains that touch the United States – from certifiers and inspectors; to commodity brokers, traders, importers and exporters; to producers, handlers and processors. Some critical areas where you might be impacted are:

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The 2017 Chilean raspberry racket concerned low-cost conventional frozen raspberries that were shipped to another country, where they were repacked and relabelled as coming from that higher-priced country in order to benefit from lower import duties at the final destination. At some point during the process, the product became organic, using fake certificates. This deception was discovered due to industry whistleblowing. The same product was also involved in an outbreak of norovirus, causing a serious food safety issue. In this article below, we mention countries and the product, but not the companies involved.

The conventional frozen raspberries originated in China and were routed via New Zealand to Chile. There, the berries were repacked with the labels ‘Product of Chile’ and ‘Organic’. The majority of the berries were shipped to Canada, where they were again repacked, processed and marketed in North America.

The Chilean importer/packer/exporter had complicated product flows. Over a number of years, it handled different berries from different origins. It was importing some Chinese product directly from China but most of it via New Zealand. It also imported Mexican, Canadian, Polish and Greek products via Canada, but also some Polish and Greek products via France. Turkish products came directly from Turkey and partly via the US. Only Peruvian products came directly from Peru. There were apparently no

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Historical review
The beginning of organic agriculture in Guatemala arose in the 90s due to the need of producers to look for opportunities in new international markets. One of these opportunities was the European market, which requires the compatibility of regulations with the supplying countries, known as ‘third countries’. For this reason, the process for recognition as a third country by the EU began in Guatemala.

In the 1990s, the main crop in organic production was coffee, and this trend continued until 2000. From 2001 to date, organic production in Guatemala has diversified and, in addition to coffee, crops such as cardamom, cocoa, macadamia nuts, green beans, French beans, lettuce varieties, arugula, moringa, black tea, dehydrated lemons, broccoli, sesame, papaya, pineapple, sugar cane, granulated panela, banana, coconut, sávila leaves, ramón seed, fat pepper, latex of chico zapote, citrus fruits, stevia, rambutan and raspberries have all been incorporated into organic production, while the production of pelibuey sheep and honey has also been incorporated into organic certification.

Promotion of organic production
Since 2004, the Department of Organic Agriculture of Guatemala has held a total of 13 events to promote organic agriculture and to publicise the progress of organic agriculture throughout the sector. Since 2020, the situation has been totally different due to the Covid-19 pandemic, but with much effort and despite the hit to the economy, we have reached

On 17 October, the US magazine POLITICO highlighted a lawsuit presented against the USDA/National Organic Program (NOP) by an organic hazelnut producer from Oregon (Patrum Farm) alleging that hazelnuts in Turkey do not comply with the same standards as producers in the US since they are certified under the Grower Group (GG) Scheme. The lawsuit alleges that Grower Group Certification undercuts US producers under an unfair competition.

This lawsuit came after the USDA launched the most significant update on its regulation entitled ‘Strengthening Organic Enforcement’,(SOE), but these new rules do not take effect until March 2024, including for Grower Group standards, which is strongly welcomed by the organic sector. This model is fully recognised by all other organic accreditation systems – worldwide.
This lawsuit can have many negative consequences for some of the world’s poorest farmers, who represent the most significant percentage of organic farmers worldwide. If this suit is successful, this could further accelerate corporate concentration over organic imports by eliminating small-farmer participation.

Grower Group certification is not a familiar certification scheme to the US consumer. Effective and clear communication will be needed to better understand the system. The Grower Group traces its roots back to the fair trade movement as a way for small farmers to have access to