To support an organic skincare claim, a brand needs verifiable evidence that a meaningful proportion of the product’s ingredients are certified organic, sourced from certified organic agriculture, and that this status is documented through a recognised third-party certification body. The claim must be truthful, substantiated, and not misleading to consumers. Below, we answer the most common questions brands face when navigating organic cosmetics claims and labelling regulations.
A skincare product qualifies to use the word ‘organic’ when it contains a verifiable proportion of organically grown ingredients and can demonstrate this through traceable sourcing documentation or third-party certification. The term is not legally defined in EU cosmetics law, which means brands bear the responsibility of ensuring any organic skincare claim is accurate and substantiated.
Because there is no single EU-wide legal threshold for organic cosmetics, the word ‘organic’ is considered a voluntary claim. This places it under the general obligation that all cosmetic claims must be truthful, evidenced, and not misleading under EU Regulation 655/2013 on cosmetic claims. In practice, this means a brand cannot simply add the word ‘organic’ to a label without being able to back it up with ingredient-level documentation or a recognised certification standard.
The safest and most credible route is to obtain third-party certification from an accepted standard body, which sets out clear criteria for what qualifies as organic and audits compliance independently.
The most widely accepted certifications for organic cosmetics claims in Europe are COSMOS Organic (administered by ECOCERT, BDIH, COSMEBIO, SOIL ASSOCIATION, and ICEA), NATRUE, and NATRUE’s organic tier. These certifications provide independent, audited evidence that a product meets defined organic standards and are recognised by retailers, regulators, and consumers across the EU and beyond.
COSMOS Organic is the most commonly referenced standard in the European market. It is managed by COSMOS-standard AISBL and sets specific requirements for organic ingredients, processing methods, packaging, and manufacturing practices. Products certified under COSMOS Organic must display the certifying body’s logo rather than simply the word ‘organic’ on its own, which adds transparency for consumers.
Other internationally recognised certifications include the USDA Organic seal for brands targeting the US market, and Soil Association Organic for the UK. Each standard has its own thresholds and criteria, so brands selling across multiple markets should confirm which certification aligns with their target regions and retail requirements.
Under COSMOS Organic standards, at least 95% of the physically processed agro-ingredients (plant-derived ingredients) must be certified organic. Across the total product formulation, a minimum of 20% of the total ingredients must be certified organic for leave-on products, and at least 10% for rinse-off products with a high water content. These thresholds vary by product type and standard.
It is important to understand that water, minerals, and certain other ingredients cannot be certified organic and are excluded from the organic percentage calculation. This means a moisturiser with a high water content will naturally have a lower overall organic percentage, which is why COSMOS applies different thresholds depending on the product category.
Brands that do not meet the full COSMOS Organic threshold may still be able to claim COSMOS Natural certification, which does not require the same organic percentage but still prohibits synthetic ingredients. Making a partial organic claim, such as “made with organic aloe vera,” is also possible but must be clearly scoped so it does not imply the whole product is organic.
The EU’s Green Claims Directive, proposed in 2023 and progressing through the legislative process, requires that any environmental or sustainability claim made on a product, including organic claims, must be substantiated with scientific evidence before it appears on packaging or in marketing. Once adopted, brands will need to pre-verify claims with an accredited third party before using them publicly.
For organic beauty products, this represents a significant shift. Currently, brands can make voluntary claims as long as they can substantiate them if challenged. Under the Green Claims Directive, substantiation must happen proactively, not reactively. This means certification will move from being the recommended best practice to effectively the minimum standard for defensible organic claims in the EU.
Brands should begin preparing now by reviewing all organic and natural claims on their current product range, ensuring each one is backed by certification or robust ingredient-level documentation. Cosmetic labelling regulations are tightening across Europe, and early compliance will reduce risk and build consumer trust.
No, a product containing synthetic preservatives cannot be certified as COSMOS Organic or meet most recognised organic cosmetics standards. These standards prohibit synthetic ingredients, including synthetic preservatives such as parabens, phenoxyethanol (in some standards), and formaldehyde-releasing agents. If a product contains synthetic preservatives, it cannot carry an organic certification label.
This is one of the most common points of confusion for brands transitioning to organic formulations. Natural preservation is achievable, but it requires careful formulation work using approved natural antimicrobials such as certain plant extracts, fermentation-derived ingredients, or approved natural alcohols. The challenge is ensuring the final formula meets both preservation efficacy requirements and the ingredient restrictions of the chosen organic standard.
Products that use synthetic preservatives alongside organic plant ingredients can market specific organic ingredients, for example “contains organic shea butter,” but cannot claim the product itself is organic without breaching consumer protection rules around misleading claims.
Brands making an organic skincare claim should retain certificates of organic status for each organic ingredient, supplier declarations, batch traceability records, and any third-party certification documents. This documentation forms the evidence base that regulators, retailers, or certification auditors may request at any time.
Specifically, the documentation trail should include:
Under the EU’s existing cosmetics regulation and the incoming Green Claims Directive, brands must be able to demonstrate the accuracy of their claims on request. Keeping this documentation current and well-organised is not just good practice, it is increasingly a legal requirement. Brands should also review claims periodically, as ingredient sourcing can change and a supplier’s organic status may not automatically renew.
At Rebel Nature, we understand that making a credible organic cosmetics claim starts long before the product reaches the shelf. It begins with the raw materials we select, the formulations we develop, and the documentation we maintain throughout the process. Here is how we help brands get it right:
Whether you are launching a new organic beauty product or reviewing claims on an existing range, we are here to help you build a solid, defensible foundation. Learn more about how we work or get in touch with our team to discuss your formulation and certification needs.
Using the word ‘organic’ to describe the overall product when only one or two ingredients are certified would likely be considered misleading under EU Regulation 655/2013 and the incoming Green Claims Directive. Instead, you should scope the claim precisely — for example, ‘formulated with organic rosehip oil’ — and ensure it is visually and contextually clear that the claim applies only to that specific ingredient, not the product as a whole. Broad organic claims require broad organic substantiation.
These are distinct claims with different substantiation requirements. ‘Natural’ generally refers to the origin of ingredients (derived from nature rather than synthesised), while ‘organic’ specifically refers to how those natural ingredients were grown and processed — under certified agricultural practices without prohibited pesticides or synthetic inputs. You can use both claims on the same product, but each must be independently substantiated. A product can be natural without being organic, but a certified organic product will also meet natural ingredient criteria under standards like COSMOS.
The timeline for COSMOS Organic certification typically ranges from a few months to over a year, depending on the complexity of your formulation, your supply chain’s existing documentation, and the certifying body you work with. The process begins by selecting an approved COSMOS certification body — such as ECOCERT, SOIL ASSOCIATION, or ICEA — and submitting your product formulation, ingredient certificates, and manufacturing details for review. Starting with a formulation that already uses COSMOS-approved ingredients and suppliers significantly reduces the time and cost involved.
Yes, it can. Your organic claim is only as strong as your current supply chain documentation, and if a key ingredient supplier loses or fails to renew their organic certification, your product’s claim may no longer be substantiable. This is why it is essential to set up a system for monitoring supplier certification renewal dates and to request updated certificates at least annually. Having alternative certified suppliers identified in advance is a practical safeguard that many brands overlook until it becomes an urgent problem.
Yes — COSMOS Organic accounts for the formulation characteristics of rinse-off products by applying a lower minimum organic threshold (10% of total ingredients) compared to leave-on products (20%), specifically because rinse-off formulas typically contain a high proportion of water, which cannot be certified organic. NATRUE similarly distinguishes between product categories. When seeking certification for rinse-off products, it is worth discussing your specific formula with your chosen certification body early in the process, as water content, surfactant types, and approved ingredient lists all affect feasibility.
Organic claims must be substantiated wherever they appear — on-pack, on your website, in social media posts, in paid advertising, and in influencer briefs. EU Regulation 655/2013 and the Green Claims Directive apply to all consumer-facing communications, not just physical labels. This means a claim that would be misleading on a jar is equally problematic in an Instagram caption. Brands should audit their full marketing ecosystem — not just their packaging — to ensure consistency and compliance across all channels.
The most frequent mistakes include assuming that swapping in a few organic ingredients is sufficient for an organic claim, underestimating the documentation burden across the full supply chain, and overlooking the impact of synthetic preservatives or processing aids that are prohibited under organic standards. Brands also commonly fail to update their marketing materials and digital content in line with reformulated products, creating inconsistencies that can attract regulatory scrutiny. The most effective transitions are planned holistically — starting with formulation, then supplier documentation, then certification, and finally claim review across all consumer touchpoints.
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