Starting January 2020, NATRUE implemented a new option to further facilitate and promote the formulation of NATRUE certified finished products. From now on, raw material producers can submit their products for evaluation under the Raw Materials Scheme with any of NATRUE’s Approved Certifiers (NACs) to benefit from the use of the NATRUE Label.
What does the Scheme means?
For producers of raw materials:
- All raw materials presently used in NATRUE certified finished products will have a transitional period until 1st July 2024 to be either certified or approved.
- New raw materials, not already in use, require approval or certification (cf. Annex 3.2).
For producers of finished products:
- Before 1st July 2024 preliminary certificates issued for finished products can list formulas containing raw materials not yet approved or certified
- After 1st July 2024 all newly certified finished products will have to include only approved or certified raw materials.
- After 1st July 2025 all products will have to include only approved or certified raw materials when re-certified.
- After 1st July 2025 preliminary certificates issued for finished products can be only granted if the formulations include only approved or certified raw materials.
- Finished products producers have until 30th June 2027 to formulate their products using NATRUE approved or certified raw materials if re-certified before 1st July 2025.
Please, find the following timeline below:
- From 01/07/2024: all new products must include only approved/certified raw materials.
- From 01/07/2025: all re-certified products must include only approved/certified raw materials.
* * * *
Illustration of the Raw Material Scheme
Raw Material approval, certification or acceptance?
Approval refers to the process covering applicable natural or derived natural substances (not from organic agriculture) aimed at verifying compliance to the NATRUE standard by documentation review by a NAC.
Certification refers to the two-step process covering applicable organic grade raw materials aimed at verifying compliance to the NATRUE Standard by documentation review and production site audit by a NAC.
Acceptance refers to organic grade raw materials certified to a standard or regulation in the IFOAM Family of Standards.
Points to consider for organic raw materials:
- Does your raw material contain substances from organic agriculture but is not certified to a regulation / standard in the IFOAM Family of Standards?
Your raw material will be certified by a NAC and require a documentation check plus an on-site audit every 2 years*.
* Please note that where a finished manufacturer has uniquely subcontracted raw material processors for customized raw materials (i.e., those not sold on the open market) this is consider a subcontracted production where only a part of the finished product is manufactured. Customised raw materials are controlled by the NAC when this raw material is used in the finished product undergoing NATRUE certification (for an example please see customised fragrances).
- Is your raw material certified organic to a regulation / standard in the IFOAM Family of Standards and has been repacking / relabelling outside the scope of these standards or regulations?
Your raw material will be assessed by a NAC by a documentation check plus one on-site audit in the first year.
- Is your raw material certified organic to a regulation / standard in the IFOAM Family of Standards including any repacking / relabelling?
Your raw material is accepted without further checks.
You can find more details about NATRUE’s Raw Materials Approval scheme in Annex 3.2.
Derogations: Raw Materials
For organic raw materials falling under the scope of a Regulation or Standard listed in the IFOAM Family of Standards without further processing: default acceptance of organic quality with no need for approval.
Raw materials that are certified as organic but falling outside the scope of a Regulation or Standard listed in the IFOAM Family of Standards are accepted by default with no need for approval provided that the so-called “analogous organic certificate” meets the following criteria:
- the organic substance(s) were certified by an accredited and duly recognized certification body or authority (e.g., a certification body accredited to control the EU Organic Regulation) and
- the certificate indicates that the control activities and requirements for organic are equivalent to a standard or regulation in the IFOAM Family, and not a private standard out of scope of the IFOAM Family.
- For conformity, please refer to the NATRUE Standard Section 2.4 and the Perfume Decision Tree found here.
Raw Material Customisation:
- The conformity of a customized raw material, compliant with NATRUE requirements, is determined as part of the certification of the finished product.
- A customised raw material includes, but is not limited to, raw materials such as a personalised fragrance blend(s) i.e., not those sold on the open market
- To ensure correct allocation, the finished product manufacturer, either the new applicant or existing Label User, must clearly communicate and provide evidential support to their NAC that the customized raw material is an exclusivity in order to qualify for the derogation.
- Customised raw materials do not need to be approved (as control is carried out by the NAC when the finished product containing these substances undergoes certification).
- Customised raw materials do not need to be displayed on the NATRUE raw material database list.
- N.B.: for fragrances, single substances, which are aromatic raw materials applicable for fragrances (such as natural essential oils etc.), can still be eligible for approval/certification as described in Annex 3.2 on a voluntary basis.
Raw materials consisting only of a nature-identical substance(s), do not need to be approved or certified although producers may choose to voluntarily enter the NATRUE Label scheme. Nature-identical substances are accepted by default when listed in the Annexes (2 or 4a respectively).
Preservatives listed on Annex 4b (derived natural) and raw materials that contain mixtures of natural and/or derived natural substances in addition to nature-identical substances (e.g., a water-based plant extract preserved with a nature-identical substance listed on Annex 4a) require approval or certification.
Questions for the finished product manufacturers when sourcing for raw materials
- Availability – Is the raw material listed on the NATRUE database?
- Compatibility – if not, assess whether that raw material is controlled to other schemes and if those certificates are automatically accepted by NATRUE.
- Encouragement – if the answer is no to the above points, the raw material or the raw material producer does not wish to enter the scheme, you, the FP producer, can initiate the process.
- Costs – if you initiate the scheme, decide who and how the costs of control will be allocated.
Who can initiate the Scheme?
- The raw material producer or finished product manufacturer using a particular raw material may initiate the process for approval.
- The raw material producer is be the one who signs the Label Usage agreement (LUA), has the right to use the seal for their product and who are responsible to inform the NAC if there is a change to their formula.
- Costs of the raw material certification/approval remain the responsibility of the NAC.
- Costs for the NATRUE Label would be invoiced to the applicant signing the LUA. The party making payment of the Label fee can be arranged internally by arrangement with NATRUE where the party signing the LUA may be different to who may pay the fee.
You can find more details about the costs linked to the NATRUE Label here.
List of approved raw materials and label use
From February 2020 onwards, all NATRUE approved raw materials are listed in NATRUE’s public database on NATRUE’s website. This procurement database provides raw material producers with a platform to advertise their products whilst informing and assisting manufacturers wishing to certify finished products with the NATRUE Label. Where there is any confidential information about the approved raw material, this will not appear in the public database. When listed on the database the trade name and manufacturer will be disclosed. Other details listed on the database includes the NATRUE substance classification and the corresponding percentage distribution for each substance(s), and the INCI.
More NATRUE certified/approved raw materials in the market
With the implementation of this new approval scheme, NATRUE reaffirms its position as a strict benchmark for the certification of natural and organic raw materials for the formulation of high-quality natural and organic cosmetics. Dr Mark Smith, NATRUE’s Director General, celebrates the implementation of this new system: “NATRUE has long supported formulators and manufacturers of raw materials through our certification scheme. By implementing NATRUE’s new Raw Materials Approval Scheme, NATRUE has created a platform to hand-in-hand benefit international producers of raw materials and finished products of all sizes to identify, procure, formulate and promote products which jointly adopt the NATRUE Label as established sign of their high-quality, and match the fundamental consumers expectations of authentic natural and organic cosmetics.”
You can access all documents about NATRUE’s Raw Materials Approval Scheme under the section “Certification and approval process” at NATRUE’s website.