Natural, organic and hypoallergenic cosmetics: what each word means

Three words, three different rules

All three words are claims. In the EU every claim must meet six common criteria, truthfulness and evidential support among them¹; in the US, labelling must be truthful and not misleading.² Beyond that, the words are treated very differently. For "clean" and "free from", see what clean beauty means.

Natural: no definition in either market

Article 2 of the EU cosmetics regulation defines a cosmetic product, a substance and a mixture, but not a natural cosmetic.³ In a statement published while the ISO standard below was still being drafted, the European Commission said that no European harmonised standard sets criteria for natural and organic cosmetics, and that certification bodies presenting their own standards as one mislead consumers.⁴ The general rules still apply: a product that explicitly or implicitly claims to contain honey, EU guidance says, must contain honey and not only honey flavour.⁹

In the US, none of the FDA's cosmetic labelling regulations defines natural⁵, and the FDA notes that the law treats ingredients from plants the same as those from any other source.¹¹

A voluntary international standard, ISO 16128, defines natural and organic ingredients and describes how to calculate a product's natural origin and organic origin content. By its own description it does not address claims, labelling or human safety.¹² A "natural origin" percentage on a pack is the result of a calculation, not a legal status.

Nor does natural predict how skin responds. A systematic review of marketing terms found that products labelled as having natural ingredients are not necessarily less irritating for people with atopic skin or a history of allergic contact dermatitis.¹³ Some plant oils are named allergens themselves: EU labels must list Citrus Limon Peel Oil once it passes 0.001% in a leave-on product (Annex III, entry 353).³

Organic: the ingredients are certified, not the word

The FDA does not define organic: the term is not defined in the laws under which it regulates cosmetics.⁸ The USDA's National Organic Program defines it for agricultural products. A cosmetic made from agricultural ingredients can be certified if the farms, the handlers and the maker of the final product are all certified by a USDA-accredited agent, and it then falls into one of four categories, with water and salt left out of each percentage:⁷

• 100 percent organic: only organic ingredients. May carry the USDA Organic seal.
• Organic: at least 95% organic ingredients. May carry the seal.
• Made with organic ingredients: at least 70%. Up to three organic ingredients or groups may be named on the front; no seal.
• Less than 70%: organic ingredients may be identified only in the ingredient statement.⁷

Such a product must still meet the FDA's cosmetics rules.⁸ The USDA has no authority over cosmetics that are not made of agricultural ingredients, or that claim no USDA standard, and private or foreign standards and eco-labels are outside its programme.⁷

The EU's organic regulation, (EU) 2018/848, covers agricultural products, food, feed and a short list of other products, among them essential oils and beeswax. Cosmetics are not on that list.⁶ Certification bodies run their own standards for natural and organic cosmetics, and the Commission has said none of them is a European harmonised standard.⁴

Hypoallergenic: conditions in the EU, none in the US

In the US there are no federal standards or definitions for hypoallergenic: the FDA says it means whatever a particular company wants it to mean, and makers need not submit evidence for it to the FDA. A 1975 FDA regulation requiring comparative tests was ruled invalid by a federal appeals court, and the FDA's account of the ruling states that there is no such thing as a "nonallergenic" cosmetic.¹⁰

EU guidance, which is not legally binding, sets conditions. Annex IV of the technical document on claims reserves the word for products designed to minimise their allergenic potential, backed by robust data showing a very low one. Known allergens should be avoided entirely, in particular substances identified as sensitisers by the EU's Scientific Committee on Consumer Safety or other official committees, classified as skin sensitisers under EU chemical rules, generally recognised as sensitisers in the literature, or lacking data on their sensitising potential. Even then the claim does not guarantee a complete absence of risk, and the product should not imply that it does.⁹

National authorities and courts apply it case by case.⁹ In the Commission's 2016 report on claims, seven Member States had found hypoallergenic claims without supporting evidence, and some reported hair dyes claiming to reduce the risk of allergy that contained resorcinol and para-phenylenediamine, which the report calls well-known allergens.¹⁴ For what to check if your skin reacts easily, see cosmetic labels and sensitive skin.

What none of the three words tells you

None of the three is a promise about your skin. The FDA notes that an ingredient's source does not determine its safety, and that many plants, organically grown or not, contain substances that may be allergenic.⁸ A label cannot settle it either, because it gives no concentrations. What it can show is whether a name you already react to is present, and how to patch test a new skincare product explains what a home test can and cannot add.

What to look for on the label

• The USDA Organic seal may appear only in the 100 percent organic and organic categories, with the certifying agent's name and address.⁷
• Other natural or organic logos belong to private schemes, whose own standards say what they mean.⁷⁴
• Plant oils and extracts can carry scent with or without Parfum in the list: see fragrance free vs unscented.
• Hypoallergenic is no reason to skip the list. What is INCI? explains the names you will find there.

The ingredient checker does not judge whether a product is natural, organic or hypoallergenic. It shows what each ingredient does and what official sources say about it, including the EU's named fragrance allergens.