# USDA certified organic soap?



## joy. (Nov 29, 2015)

I was under the impression that soaps made with sodium hydroxide or potassium hydroxide couldn't be certified organic, until I stumbled across this today:

http://shop.mercola.com/product/organic-peppermint-shampoo-for-pets,977,547,0.htm 

Have the regulations changed, or am I missing something? Looking at the label, it's just liquid soap, but it has the usda organic logo on it.


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## KatyP (Dec 30, 2015)

I'll be honest, without an ingredient list it's pretty hard to say what is in that bottle, especially since it is a pet product. It may not contain lye at all. Who knows? But I was having a similar thought when I saw this:
https://www.drbronner.com/DBMS/ORGANICPUMPSOAP/SD0504.html

This is clearly soap, and it clearly is made with lye. And we all know that it takes at least 8% lye to make any soap (and could be as high as 34%). So there is no way that an organic label and logo should be on that bottle. It has to have less than 5% lye for that to be feasible. Unless it has a super fat of over 50%, that's not possible. The only thing I have noticed is that on the label they asterisk the lye and state that "none remains after saponifying oils into soap & glycerin." This seems like twisting the facts at best. Because while it is true that the lye is gone, so are the majority of the oils! If you can just "skip" the lye because it gets used, then the label should also reflect the loss of oils and the addition of the salts formed.  I am very surprised that no one has called them out on this. Unless this is okay with the USDA? Because if it is, I know a lot of "natural" soap makers that will be calling themselves "organic" soap makers in the amount of time it takes to print up a new label...


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## topofmurrayhill (Dec 30, 2015)

You can probably get there with liquid soap if it's fairly dilute and you include the water amount in the calculation to get the caustic percentage lower. You do that by using something other than water, such as grape juice in the case of Dr. Bronner. It's a bit of a cheat, but what's the difference really? It's arguably a fair cheat. Why should adding organic grape juice make your product LESS organic? It's all based on technicalities of the rules.

If Certified Organic is important to people in the context of soap, then soap really should be in a special class that excludes the caustic just like water and salt are excluded for food. That way you at least level the playing field for those who can't or don't want to take advantage of the technicalities, but who otherwise make their products in the same spirit.

So I would guess that Dr. Bronner is too big a brand to be illegally labeled. The pet shampoo, who knows? They might be flying under the radar, or they could be using the same trick. I remember seeing aloe vera mentioned as an ingredient, so that's at least one thing that can help them get in under the wire.


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## Susie (Dec 30, 2015)

They have a "contact us" at the bottom of the website page.  Why not ask them?


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## LBussy (Dec 30, 2015)

I had nothing to do this morning so I found a few applicable regulations:



			
				
Title 7 said:
			
		

> (1) A production or handling operation that sells agricultural products as “organic” but whose gross agricultural income from organic sales totals $5,000 or less annually is exempt from certification under subpart E of this part and from submitting an organic system plan for acceptance or approval under §205.201 but must comply with the applicable organic production and handling requirements of subpart C of this part and the labeling requirements of §205.310.


That implies labeling as organic is feasible for a smaller operation, and they will likely never get caught.  Dr. Bronner probably does not fall under this with gross sales.  As I type this I wonder if he really was a doctor?

Anyway, without further adeiu, here's how they can be "Organic:"



			
				
Title 7 said:
			
		

> Potassium hydroxide—prohibited for use in lye peeling of fruits and vegetables except when used for peeling peaches.
> Sodium hydroxide—prohibited for use in lye peeling of fruits and vegetables.


Pretty much covers it ... soaps can be "Organic."


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## topofmurrayhill (Dec 30, 2015)

LBussy said:


> I had nothing to do this morning so I found a few applicable regulations:
> 
> 
> That implies labeling as organic is feasible for a smaller operation, and they will likely never get caught.  Dr. Bronner probably does not fall under this with gross sales.  As I type this I wonder if he really was a doctor?
> ...



True but the issue is not whether they can be organic but how. The caustics are allowed, but the product still has to consist of 95% organic ingredients, not including water. CP bar soaps can't get there. Liquid soaps potentially can if you substitute an organic product in place of plain water.


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## LBussy (Dec 30, 2015)

topofmurrayhill said:


> True but the issue is not whether they can be organic but how. The caustics are allowed, but the product still has to consist of 95% organic ingredients, not including water. CP bar soaps can't get there. Liquid soaps potentially can if you substitute an organic product in place of plain water.


I don't find that as a requirement ... source?  

Also, I believe since this is not a restricted ingredient it does not count as non-organic.


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## Susie (Dec 30, 2015)

In liquid soaps, you can use "non-water" products only as batch water.  Dilution MUST be water, as anything else contributes to pathogen growth.


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## topofmurrayhill (Dec 30, 2015)

Susie said:


> In liquid soaps, you can use "non-water" products only as batch water.  Dilution MUST be water, as anything else contributes to pathogen growth.



You should be directing that to Dr. Bronner in case they are doing it wrong. Point is, their non-certified liquid castile lists water whereas their organic liquid soap lists organic grape juice instead. I have seen people discussing this particular type of cheat. Your water quantity is included as part of some organic product and suddenly your percentage of caustic is much lower because it's no longer on a dry weight basis.


LBussy said:


> I don't find that as a requirement ... source?
> 
> Also, I believe since this is not a restricted ingredient it does not count as non-organic.



I don't think this part is controversial. Caustic is non-organic but doesn't disqualify the product. There is, however, a limit to the percentage of non-organic ingredients. Info is here:

http://www.ams.usda.gov/sites/default/files/media/OrganicCosmeticsFactSheet.pdf

Edit to clarify: I think we were discussing the fact that the products above were using the USDA Organic seal. If you are at least at 70%, you can indicate organic ingredients on the main label but you can't use the seal unless it's at least 95%.


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## LBussy (Dec 30, 2015)

Is a product for dogs "personal care" I wonder?

The Dr Bronner stuff does not bear the seal that I see but does say "made with certified organic ingredients" which is allowable at => 70% of these ingredients.


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## Misschief (Dec 30, 2015)

In the soap making process, lye is used but, if made correctly, there is no lye left in the final product as it is used to turn one ingredient, oil, (or many as the case may be) into another, saponified oil (soap). Lye may not be an organic ingredient but all the other items used in the soap making process can be, and certainly could be, certified organic. 

Yes? No?


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## KatyP (Dec 30, 2015)

LBussy said:


> The Dr Bronner stuff does not bear the seal that I see



The seal is on the front panel of the bottle in black (the rest of the label being in blue). Unless I need to find my glasses. 

So for Dr. Bronner's to legally use the USDA seal, they have to be a minimum of 95% organic. Which means no more than 5% is lye + citric acid + tocopherol. For the sake of argument, I'm just going to assume that the whole 5% is lye and ignore the other two ingredients. I've been running some scenarios, and trying to give them the benefit of the doubt but I am hindered a bit by the fact that I've never made liquid soap. Here's what I've come up with, if someone more experienced could take it from here??

I made the following assumptions in order to stack the cards in their favor:
*20% SF (what is the high end for SF in liquid soaps?)
*I input as much jojoba as possible because it has the lowest SAP value, while keeping all the oils in their proper weight order in relation to each other and to the location of the lye on the label.
*I did NOT check the 90% KOH box as that raises the lye amount a bit.

In order for the lye to be 5% or less of the total, that total needs to be 52.8 ounces (2.64/.05). Subtract the 16 ounces of oils and the 6.08 ounces of grape juice substituted for the water leaves 30.72 ounces that would need to be included in the recipe. I see Shikakai powder on the label, and it would have to fall between the olive and hemp oils, so that's 2.64 ounces, still leaving 28.08 ounces unaccounted for. The first ingredient on the label is sucrose, so it has to weigh more than the 4.16 ounces of coconut oil I came up with. How much sugar is it reasonable to add to a liquid soap? Certainly not 28.08 ounces... But again, I'm running numbers having never made liquid soap myself. My guess is that you need to add far more than the recommended 6.08 ounces of grape juice, and that the tocopherol is the preservative needed for all that liquid. Is it possible we are looking at perhaps 5 ounces of sucrose and 23 additional ounces of juice (for a total of 29 ounces liquid)?

I hope that's the case. If that's just way out of the ballpark for a liquid soap, then I have one other possible scenario but I don't like it. It might be legal, but it would certainly be an abuse of the process. What if they start with a massive amount of sucrose and grape juice, and that they reduce the mixture by cooking it down before actually making the soap. If that was reduced by half it would be like using syrup instead of water, but I think it would still work.

I love science when I have the answers. This is slightly less fun. :?


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## topofmurrayhill (Dec 31, 2015)

KatyP said:


> The seal is on the front panel of the bottle in black (the rest of the label being in blue). Unless I need to find my glasses.
> 
> So for Dr. Bronner's to legally use the USDA seal, they have to be a minimum of 95% organic. Which means no more than 5% is lye + citric acid + tocopherol. For the sake of argument, I'm just going to assume that the whole 5% is lye and ignore the other two ingredients. I've been running some scenarios, and trying to give them the benefit of the doubt but I am hindered a bit by the fact that I've never made liquid soap. Here's what I've come up with, if someone more experienced could take it from here??
> 
> ...



The soap you're calculating wouldn't be a liquid. Their product (and liquid soap in general) would be much more dilute. It's interesting that sugar is the first ingredient, no? I'll speculate that it's used as a thickener.

It's all pretty fair and square. One of the stated objectives of the NOP program is to promote organic agriculture, so mission accomplished with the unconventional ingredients. The rules as they apply to soaps are debatable, but there's at least a supportable argument that they are best as they currently are.


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## joy. (Jan 3, 2016)

LBussy said:


> Is a product for dogs "personal care" I wonder?



I hadn't thought about that. I was just assuming the regulations were the same, but they're probably not.

The pet shampoo is made with potassium hydroxide. Ingredients attached... It seems like a pretty big company, so I don't think they're sneaking under the radar. I could be wrong though.

I thought if something was only 85% organic, it had to say that - "made with 85% organic ingredients" or similar, in order to use the usda label?


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## Arimara (Jan 3, 2016)

KatyP said:


> The seal is on the front panel of the bottle in black (the rest of the label being in blue). Unless I need to find my glasses.
> 
> So for Dr. Bronner's to legally use the USDA seal, they have to be a minimum of 95% organic. Which means no more than 5% is lye + citric acid + tocopherol. For the sake of argument, I'm just going to assume that the whole 5% is lye and ignore the other two ingredients. I've been running some scenarios, and trying to give them the benefit of the doubt but I am hindered a bit by the fact that I've never made liquid soap. Here's what I've come up with, if someone more experienced could take it from here??
> 
> ...



Looking at this now, I'm of a mind that THAT soap recipe is for cleaning purposes only. That's what I use Dr, Bronner's for now anyway. I would love to get that almond scent for a batch of LS though.


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## Dana89 (Jan 4, 2016)

Susie said:


> In liquid soaps, you can use "non-water" products only as batch water.  Dilution MUST be water, as anything else contributes to pathogen growth.



Susie really? I am thinking about making IL's GLS soap recipe next week but I thought diluting it with Aloe and water would be nice.
I do intend to add Liquid Germall Plus at 0.3%, would it be ok then?

On another note I hate the "organic" and "Natural" words, but it looks like it is legal to call M&P "organic".

http://www.brambleberry.com/SFIC-Organic-Melt-Pour-Base-P4382.aspx
Here are the ingredients in this "organic MP soap".
Ingredients: 
*Common Name:  Organic Coconut Oil, Organic Palm Oil, Glycerine (kosher, of vegetable origin), Purified Water, Sodium Hydroxide (saponifying agent), Sorbitol (moisturizer), Sorbitan oleate (emulsifier), Oat protein (conditioner)
Botanical Name:  Organic Cocos Nucifera Oil, Organic Elaeis Guineensis Oil, Glycerin, Aqua/Water/Eau, Sodium Hydroxide, Sorbitol, Sorbitan Oleate, Avena Sativa Protein Extract*

I guess there is a lye nut tree after all!


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## LBussy (Jan 4, 2016)

Arimara said:


> I would love to get that almond scent for a batch of LS though.


Never smelled that soap, but an Almond scent I love (and use in HP) is Soapalooza's "Almond Silk:"

http://soapalooza.com/index.php?main_page=product_info&cPath=1&products_id=783


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## HoneyLady (Jan 19, 2016)

This is curious.  *My* understanding (warning!) is that oils may be labeled organic, if the crops they are pressed from are certified organic, and nothing awful like hexanes are used in the processing.

I learned this while researching why soy waxes are being labeled organic, when the USDA certifies NO waxes, and solvents like hexane are used to make soy oil into wax.  Ergo, any soy WAX you see labeled USDA organic is illegally labeled as such.  Alas, USDA won't crack down on it, unless they receive enough complaints.

On the other end of the spectrum of USDA organic labeling is the "logic" of how honey is labeled organic.  There are 2 (to the best of my knowledge as of Oct. 2015) and only 2 genuine USA USDA organic honey producers:  One on the Big Island of HI, and one on the Olympic Peninsula.  As a beekeeper myself, I would have to certify that everything in the radius of my bees' range is being raised organically.  That equals about 7,000 acres or so, since bees can fly in a 6 mile radius from the hive.

HOWEVER, if you are an importer, and bring in honey from, say, Argentina, and you claim it is organic,  USDA will slap their label on it for you.  The reason?  USDA doesn't have jurisdiction in Argentina, and can't dispute whether it is organic or not so they just label it so.  :shock:

I would not be surprised if some sort of similar "logic" is at work here.

~HL~


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## joy. (Jan 25, 2016)

HoneyLady said:


> On the other end of the spectrum of USDA organic labeling is the "logic" of how honey is labeled organic.  There are 2 (to the best of my knowledge as of Oct. 2015) and only 2 genuine USA USDA organic honey producers:  One on the Big Island of HI, and one on the Olympic Peninsula.  As a beekeeper myself, I would have to certify that everything in the radius of my bees' range is being raised organically.  That equals about 7,000 acres or so, since bees can fly in a 6 mile radius from the hive.
> 
> HOWEVER, if you are an importer, and bring in honey from, say, Argentina, and you claim it is organic,  USDA will slap their label on it for you.  The reason?  USDA doesn't have jurisdiction in Argentina, and can't dispute whether it is organic or not so they just label it so.  :shock:
> 
> ~HL~



Sometimes you just have to wonder who the heck comes up with these regulations. That's ridiculous, but I'm not surprised. 

Honey is one of those things I'm very particular about. I've read that most imported honey, regardless of where the label says it came from, is actually from China and is likely contaminated with heavy metals. I go directly to a local beekeeper to buy my honey and beeswax.


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