Non-Organic Cosmetic Ingredient Assessment Explained

Global trade in natural ingredients has increased dramatically in the last years, a growth driven by consumers that looks forward to safer cosmetics free of harmful chemicals. While organic certified cosmetics contains a high proportion of organic ingredients certified under several international organic standards, they also contain a small proportion of natural ingredients sourced from vegetable, mineral or marine renewable sources. Those natural ingredients are an important part of the product formula usually acting as moisturisers, surfactants, preservatives, etc.

Natural ingredients are not certified by a third party organisation like organic raw materials, and due to this the lack of regulation the term natural has been applied to ingredients derived from GMO materials, or to ingredients that although initially derived from natural sources, have lost any ‘naturalness’ after so many synthetic chemical treatments.

The Cosmetics Raw Materials Scheme aims to provide comprehensive validation of natural ingredients to be used in ACO and COSMOS certified products, or by conventional cosmetics manufacturers wishing to market a product made with natural ingredients validated by a leading certification body. Through our ingredients database, cosmetics manufacturers and formulators will have at their disposal hundreds of approved ingredients ready to use, and because the database is open, consumers of end products will be able to discern if the so-called natural ingredient in their shampoo meets stringent organic standards requirements.

There are two levels of approval for natural ingredients:

  • Evaluation
  • Registration

Raw material evaluation

Certified cosmetics manufacturers can obtain evaluation of any particular ingredient to be used in their organic ACO or COSMOS formulations. The price for evaluation is $50 per ingredient; per standard and assessment is via a Questionnaire.

IP protection. Validation of an ingredient belongs to the company that has submitted and paid for the evaluation. If a different company re-submits that ingredient as part of their formula, the ingredient will be re-evaluated ($50 fee) even if it has been already approved for a different company.

There is no renewal cost involved, but if there is a change of ingredient manufacturer, a new evaluation will be required.

Raw material registration

A service provided to raw material suppliers or manufacturers that wish to validate their ingredients for inclusion in the ACO Cosmetics Raw Materials Database.

Certified cosmetics manufacturers using registered ingredients would not pay an evaluation fee for the ingredient, resulting in a reduction in the overall certification cost and an advantage to formulators in search of new ingredients to incorporate in their products.

The labelling of ACO or COSMOS registered ingredients must not state or indicate that the ingredient is certified according to the ACO or COSMOS standard and must not include the ACO, COSMOS Organic or COSMOS natural logos. It may only include a statement such as ‘approved for use under the ____ standard’ or ‘accepted as compliant with the ____ standard’.

The registration cost per ingredient is as follows. Discounts apply for submissions consisting of over 10 materials:

ACO Registration Fees

  • 1-10 ingredients - $80 per raw material
  • 11-20 ingredients - $70 per raw material
  • 21-50 ingredients - $60 per raw material
  • more than 50 ingredients - $55 per raw material

COSMOS Registration Fees

  • Registration of already ACO registered ingredient is $30 per raw material. Please note that additional information for evaluating the ingredient will be requested.
  • Registration under COSMOS standard is $100 per raw material.
  • Registration under both COSMOS and ACO standard is $110. Please note that we will evaluate the ingredient under two different standards, so approval under one standard won’t guarantee that it can be approved under the other.
    Fees above include publication in the COSMOS Raw Materials Database
  • A COSMOS Raw Material certificate can be issued at a cost of $44.
  • The annual renewal fee per ingredient is 30% the registration fee for an initial review

Example :
Registration cost for 6 ingredients under ACO = $480
Renewal cost for 6 ingredients under ACO = $144

To claim organic content of chemically or physically processed ingredients that fall outside the scope of recognised organic production standards such as the ACO standard, can be certified according to the COSMOS standard. However, being an ingredient, there is no minimum percentage of organic content.

The labelling of such ingredients must:

  • display clearly the percentage of organic content, calculated according to the COSMOS standard;
  • comply with other aspects of the COSMOS-standard and this labelling guide.

If the ingredient is (or can be) certified as a finished product at a retail level, it may display the COSMOS ORGANIC or COSMOS NATURAL signature, otherwise it may not display these signatures. Instead, it may only include a statement such a “COSMOS-standard certified – X% organic” or “certified as X% organic to COSMOS-standard”.

Please contact ACO in order to start the certification process.

Application Procedure

To progress your ingredient registration, please complete the application document and submit it together with your remittance advice to accounts@aco.net.au or fax 07 3350 5996.

Once payment is processed, you will receive your unique code necessary to complete the online questionnaire.

It is recommended that raw materials manufacturers complete the online evaluation questionnaire on behalf of their raw materials distributors. Submitting the information directly to ACO will help facilitate the exchange of information required to complete the evaluation while minimizing confidentially issues that face raw material distributors and cosmetics manufacturers when they try to obtain the information required by ACO from a raw material manufacturer.

An ingredient SDS and manufacturing flowchart are required to be uploaded when submitting the questionnaire, so please prepare those documents in advance. If additional information is required for the evaluation, a certification officer will contact you.

Successfully registered materials will be listed on the ACO Cosmetics Raw Materials Database and in the COSMOS Raw Materials Database if the material was evaluated under COSMOS standard.