Following is another splendid forward from David Bronner of Dr. Bronner's fame.

Hello all:

To comment on the "Made with" versus "Organic" for soaps. One, it is to an extent academic, as the alkali reagent is greater than 5%, so for the most part it doesn't matter if a soap could be organic if the alkali was less than 5%, because that can't chemically happen. Second, I think the pressing need felt by many to make soap "organic" regardless of the % alkali needed is based on the accurate observation that right now, a soap that is made as organic as possible, with all saponfied organic oils and organic essential oils, cannot differentiate itself from conventional surfactant products with floral waters making front panel organic claims that have not one single surfactant ingredient based off organic material. Thus, the perceived solution is to grant soap special "organic" status regardless of the alkali % needed to make it.

But the solution is not to elevate soap to "organic" status versus "made with" conventional surfactant formulations with added floral waters, but to raise the bar such that a "made with" claim cannot be made simply by adding floral water to otherwise synthetic conventional surfactants. Under the NOP, a front panel claim can be made ONLY if the non-water, non-salt weight of the product is greater than 70%. Then, the prominent "Made With Organic Oils" on a cosmetic product is special and meaningful, and not lost among hollow fraudulent organic claims on bodycare store shelves.

Others on this task force feel the necessity for not only an "organic" versus "made with" designation for soap, but also for synthetic surfactant ingredients more complicated than soap that are based off of certified organic materials. I think again this is in part based on the accurate observation that there is no other way to distinguish a product with such ingredients from conventional surfactant products with no organically based surfactants that make prominent front panel claims because of floral water.

What we are engaged in is about a revolution in general surfactant manufacture, where a demand is created for plant-based renewable surfactants based off of sustainable organic agriculture. These are the core ingredients that constitute the active basis of most cosmetic products, not the feel good fluffy water extracts and floral waters. If this task force helps in formalizing the hydrosol scheme, this effectively kills any chance for a revolution in surfactant manufacture to occur. Why would Aveda possibly invest the resources necessary to create the demand for such progressive sustainable ingredients if their front panel claims looks exactly the same as a product with conventional surfactants and added floral water?

I understand that at one point it was represented that there was already a "standard of identity" for floral waters, much like the FDA has set for orange juice or apple juice. But there is no such identity, and the only reason there is an effort to create one now is to cater to the marketing needs of synthetic surfactant products that cheaply fluff up organic content through counting non-agricultural water. But this whole exercise eviscerates the possibility of any substantive change in cosmetic ingredient manufacturing, which is being short-circuited by making up an ingredient standard for complicated tea. Under what authority and on what basis is such a standard being created? It makes sense that the FDA would be the agency to set a standard for something like reconstituted concentrated fruit juice, which approximates the profile of naturally squeezed fruit juice. But what standard is the floral water supposed to approximate? Where is it, who's making it up?

How about the tea tree oil we use, which is obtained through boiling botanical material in water and skimming the tea tree oil off, versus a steam distillation process. I guess the remaining water doesn't get to count as organic as the water didn't turn into steam first, notwithstanding that there is no chemical difference whatsoever in the resulting water byproduct (it's still almost completely water).

How about boiled down powdered hydrosol, that can be reconstituted to 1000 plus times its weight? This will even be self-preserving and not need paraben and whatnot preservatives that floral waters require, and then we truly will have helped create the magic organic pixie dust. Just sprinkle a gram of powdered hydrosol on whatever conventional product, and POOF, it's organic.

To beat the very dead horse: there is not one instance of hydrosol or floral water in any shampoo, body wash or conditioner product in either the mainstream or natural marketplace, aside from in the five or so companies' conventional surfactant products with fluffy front panel organic claims (by counting the water in floral water as "organic"). Let's not vote to sanction the creation of a standard that does not exist for the sake of fluffy cheap organic label claims, and so sabotage a truly amazing revolution in cosmetic ingredient manufacture.

Take care, David