Is there really an organic mattress? – Part 2 – the Global Organic Textile Standard and OE Standards

The NOP just issued a new Policy Memo on May 20, 2011, on textiles that contain organic ingredients. I’ll cover reactions to and implications from this memo in the Part 3 blog.

In my Part 1 blog on the U.S. Department of Agriculture’s (USDA) National Organic Program (NOP) Certification, I introduced these questions:
• (marketer) How do I assure consumers that my mattress is organic? – or –
• (consumer) Isn’t there some way to ensure that the mattress I’m buying is as organic as possible?

To remind my readers, indicating that a finished mattress is “USDA organic” is strictly forbidden by the USDA’s regulations and is what one mattress retailer was warned could warrant up to an $11,000 penalty. (See Worden blog: Is there really an organic mattress – Part 1 – the National Organic Program Certification.)

Now introducing…drumroll…the Global Organic Textile Standard (GOTS), and Part 2 of the Worden blog series on “Is there really an organic mattress?” The writing of this multi-part series hastened my coining of the term “more-ganic” (definition: once you think you understand organic you realize there’s always “more” the story).

The Standards
It is difficult to boil down complex standards, so I ask the reader to bear with me as I dissect the process of developing a “certified organic mattress.”

This path forward requires use of and understanding of NOP (covered previously), GOTS, and Organic Exchange (OE) standards.

For those without patience, this entire blog article boils down to this: NOP = certified crops/livestock (e.g., cotton fiber, wool, sap from a rubber tree (for latex), etc.). GOTS = certified textiles/finished products (e.g., fabric, apparel, blankets, sheets, pillows, mattresses, etc.). OE = certified organic cotton purchased and used by the manufacturer equates to a verifiable percentage of organic cotton in the finished product.

GOTS

For your first introduction to GOTS, you need to know that it was developed to define world-wide recognized requirements about the organic status of textiles, from post-harvest handling of the raw materials, through environmentally and socially responsible manufacturing and labeling. Its purpose is to provide credible assurance to the consumer that a finished product is “certified organic.” To achieve GOTS certification, a product must meet one of its definitions for organic products and be certified by an independent third-party certification organization approved by the GOTS International Working Group (IWG). Licensing and labeling are governed by the GOTS IWG.

GOTS can be used to certify a finished product as “certified organic” if 95% of the product’s ingredients are certified organic and the manufacturer is in compliance with other GOTS requirements. GOTS also allows a claim of “made with x% organic material…” if 70% or more of the product’s ingredients have been certified organic and the manufacturer, likewise, is compliant with other requirements.

To understand exactly what this means, I’ll follow a mattress through the process of achieving certification under GOTS.

Step 1: Obtaining crop materials that are certified organic

Mattress manufacturers must start to build an organic mattress by using primarily materials that are “certified organic.” This means, each component must be certified as organic, and the organic “chain of custody” or tracking of product from one supplier to another starts with obtaining crop-based materials, such as cotton, wool, flax, silk, etc.. Any crop-based product sold in the U.S. as “certified organic,” regardless of the country it originated from, must be certified to be in compliance with the NOP standards. The USDA website provides a list of USDA accredited certifiers.

To recap, organic fiber must be certified to the NOP crop or livestock production criteria. The fiber is then processed into fabric, quilt, or core materials, which are essential components to a mattress. (Note: it is our belief at this time that only fiber or steel based mattress cores can qualify for GOTS certification and that latex and other foam product cores are not eligible for certification at this time.) How then does the finished mattress with certified components achieve GOTS certification?

Step 2: Purchasing component materials that have been certified organic

Crops must be processed into textiles or core materials. In my Part I blog, I noted that the NOP certification frequently does not work for a finished textile product because its standards were written with food in mind, not necessarily the secondary processes involved with processing fiber or producing textiles that frequently include various treatments, dying, and other chemical processing. Enter GOTS. To comply with GOTS, textile manufacturers must follow strict standards for processing and manufacturing that were specifically written to address textiles. Fabric, for instance, must be processed in such a way that during the cleaning, treatment, and dying processes, the textile manufacturer is using only processes and treatments approved by GOTS.

The key criteria of GOTS requirements for organic textile processing are:

• At all stages through the processing, organic fiber products must be separated from conventional fiber products and must to be clearly identified;

• All chemical inputs (e.g. dyes, auxiliaries and process chemicals) must be evaluated and meet basic requirements on toxicity and biodegradability/eliminability;

• Prohibition of critical inputs such as toxic heavy metals, formaldehyde, aromatic solvents, functional nano particles, genetically modified organisms (GMO) and their enzymes;

• The use of synthetic sizing agents is restricted; knitting and weaving oils must not contain heavy metals;

• Bleaches must be based on oxygen (no chlorine bleaching);

• Azo dyes that release carcinogenic amine compounds are prohibited;

• Discharge printing methods using aromatic solvents and plastisol printing methods using phthalates and PVC are prohibited;

• Restrictions for accessories (e.g. no PVC, nickel or chrome permitted, any polyester must be post-consumer recycled from 2014 onwards);

• All operators must have an environmental policy including target goals and procedures to minimize waste and discharges;

• Wet processing units must keep full records of the use of chemicals, energy, water consumption and waste water treatment, including the disposal of sludge. The waste water from all wet processing units must be treated in a functional waste water treatment plant;

• Packaging material must not contain PVC. From 1st January 2014 onwards any paper or cardboard used in packaging material, hang tags, swing tags etc. must be post-consumer recycled or certified according to FSC or PEFC;

• Technical quality parameters must be met (s.a. rubbing, perspiration, light and washing fastness and shrinkage values);

• Raw materials, intermediates, final textile products as well as accessories must meet stringent limits regarding unwanted residues; and

• Minimum social criteria based on the key norms of the International Labour Organisation (ILO) must be met by all processors

A mattress manufacturer will want to obtain component materials from sources that can produce documentation from throughout the supply chain that their processing operation and thereby finished textiles have been certified to meet GOTS standards. Each manufacturer in the supply chain must be certified by GOTS and provide downstream product users with a transaction certificate. GOTS certification can be obtained from any of the international bodies approved by the International Working Group that governs GOTS. This link provides the list of approved GOTS certifiers.

Step 3: Certifying the finished mattress

Just like the textile/component manufacturers, U.S. and Canadian mattress manufacturers that assemble the components into a finished product must meet GOTS requirements for their manufacturing processes and facility. GOTS certification bodies, like Control Union, One Cert, and Oregon Tilth, require that the manufacturer document through an application process that their component materials (the fiber) have achieved NOP certification as appropriate and GOTS certification as appropriate (finishing stages). The application process is then followed up with an annual inspection by the certifier. As long as a manufacturer passes the inspection each year, the products manufactured in that facility under GOTS approved methods will retain their certification.

Retailers do not need GOTS certification but should verify that the manufacturer is indeed certified under GOTS and should not repackage or relabel a product that has been certified through the manufacturer under GOTS. Retailers should also provide reference to the GOTS certified manufacturer’s name and note which certifier was used.

An example of language a manufacturer or retailer could use as a claim would be: “This mattress was certified organic in compliance with the Global Organic Textile Standard. The certification was provided to ABC Mattress Manufacturer by xxx certifier.”

As noted previously, indicating that a finished mattress is “USDA organic” is strictly forbidden by the USDA’s regulations and is what one mattress retailer was warned could result in fines. (See Worden blog: Is there really an organic mattress – Part 1 – the National Organic Program Certification.)

Retailers or consumers can look for GOTS certified mattress manufacturers using this link and by typing in the word “mattress.” At the time of this writing, two U.S. based companies are the only North American companies to achieve GOTS certification: Naturepedic and Organic Mattresses, Inc. (OMI). Readers are encouraged to check the GOTS website periodically as more manufacturers are working to comply with the Specialty Sleep Association’s (SSA) Environmental & Safety Program , which encourages truth in advertising through proper use of terminology and certifications such as GOTS. With the SSA program online, awareness of organic certifications is growing.

Gaming the System (definitely more-ganic)

As I was writing this blog, I received an email from someone concerned that a particular company was making claims of certification (of one or more of the certifications detailed in this series) without actually having achieved said certification.  I will note that each of these certification bodies is as vigilant as possible in maintaining the integrity of their brands by pursuing and preventing false certification claims. “Greenwashing” as it’s called (i.e., making false or generic claims) comes in many forms. Consumers should be equally vigilant as they do their homework before a purchase. The websites provided within this blog allow the opportunity to verify if certification has been achieved.

Organic Watch-dogs:  OE 100 and OE Blended Certifications

As I investigated more about false certification claims, I learned about two more certifications that are highly relevant. They were created by the Organic Exchange (OE for short, and now OE has been renamed the Textile Exchange). This is a membership organization sponsored by some of the biggest companies throughout the supply chain including, Nike, Nordstrom, Walmart, as well as mills, input suppliers, and others from around the world.

OE created two standards that help assure consumers that the organic fiber in a finished product truly came from an organic farm: OE 100 and OE Blended.

OE 100 is for products that want to claim the volume of cotton fiber in a product is at least 95% organic. OE Blended was created to encourage use of some organic product even when a majority of the product is non-organic cotton fiber or traditional fiber. OE Blended certifies the percentage of organic cotton fiber in a product.  For OE Blended, the finished product must have at least 5% of organic cotton to be certified.

These standards address chain of custody and organizations that are certified to either OE 100 or OE Blended standards open their facilities to inspectors who will pull a mattress from a product line, for instance, and request all documentation demonstrating where the organic cotton in that product originated as well as proof that it was certified organic (to NOP standards in the U.S., right? Right!). The OE standard requires in-depth documentation so that inspectors can “do the math” and ascertain whether the volume of organic product purchased is likely to be reflected in the products being manufactured.

The extra step to achieve OE certification is one more proof point manufacturers may pursue to demonstrate that they are committed to providing organic and responsibly manufactured products.

Conclusion

I encourage readers to think of the building of an organic mattress as similar to the building of a really great sandwich.  You first need the tasty ingredients (certified to the NOP and OE standards), components that are layered in an appropriate way (certified to the NOP and/or GOTS), and finally a product sealed together with a lip-smacking, final certification by GOTS.

Stay tuned in for “Is there really an organic mattress? – Part 3 – Correctly applying “organic” to your products.”

Worden Associates, Inc. welcomes your questions, inquiries and perspective on the content of this blog entry.

Is there really an organic mattress? – Part 1 – the NOP Certification

It’s amazing the amount of confusion that exists around the application of the term “organic.”  Perhaps it should be renamed “more-ganic.”  Every time one thinks they might understand the term, or the organic certifications, there seems to be yet “more” to learn.

Since I have been trying to nail down how the word organic should and shouldn’t be applied to certain products, I thought it would be beneficial to share my findings. This blog has been titled with a Part 1 because I can already envision Part 2, 3, and potentially many more installments before I feel I’ve completely covered this topic.

Based on my client roster, this series will be evaluating how organic is applied to textiles and finished products, like mattresses.

First of all, what is the definition of organic? In the United States, we need to consult the U.S. Department of Agriculture’s (USDA) National Organic Program (NOP).  The NOP regulates the term organic as it applies to agricultural products through its NOP regulation, 7 CFR Part 205.

The NOP regulation does not have a one-stop shop definition, but instead provides requirements for meeting organic farming standards and crop/livestock production standards.

• What is organic? (from http://www.ams.usda.gov/AMSv1.0/nop)
  
• Organic production is a system that is managed in accordance with the Organic Foods Production Act (OFPA) of 1990 (PDF) and regulations in Title 7, Part 205 of the Code of Federal Regulations to respond to site-specific conditions by integrating cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity. The National Organic Program (NOP) develops, implements, and administers national production, handling, and labeling standards.

It goes on to specify in guidance documents that raw natural fibers, such as cotton, wool, flax, etc., are agricultural products and covered.  However, to earn NOP certification of a finished textile product, the textile must fully meet the crop/livestock production standard, which is considered challenging for many textiles because these standards were written for crops and, for example, certain dyes and other treatments are not addressed in the regulation and therefore not allowed.

If a product cannot meet the full NOP production standards, it still may be identified as having “organic fibers certified to the NOP crop/livestock standards.”  The marketer may also state the percentage of organic fibers contained in the final product, and the Specialty Sleep Association (SSA) encourages manufacturers to do this to help bring clarity to consumers and substantiate their claims. Manufacturers may not, however, use the USDA Organic seal or imply that the final finished product is certified organic by NOP.

One retailer that mistakenly advertised a mattress containing organic cotton fiber as a “USDA organic” mattress in its store catalog and its advertising was unfortunately the subject of a complaint and NOP investigation (Complaint Case NOPC-107-10, resolved 4-4-11).  The investigation resulted in the store having to remove all such claims and further, having to prove that the crop components that comprise the mattress had indeed been certified as organic by NOP.  Once proof was provided, the mattress store was warned that future violations of the NOP regulations could result in civil penalties of up to $11,000 per violation.  (SSA has learned from 4/14/11 meeting with NOP staff that a Policy Memo will shortly be issued to provide further clarification for textile manufacturers and hopefully help them to avoid fines. Once issued, the Worden blog will provide additional examples of proper and improper labeling and advertising for mattresses.)

The threat of an $11,000 fine is enough to make any manufacturer or retailer sit up and pay attention.  It also begs the question: If the NOP program doesn’t apply to finished mattresses, how do I assure consumers that my mattress is organic? Or for consumers, isn’t there some way to ensure that the mattress I’m buying is as organic as possible?

Enter the Global Organic Textile Standards or GOTS, and Part 2 of  the Worden blog “Is there really an organic mattress?”

Worden Associates, Inc. welcomes your questions, inquiries and perspective on the content of this blog entry.

FTC’s Proposed Changes to Green Guides

By Vicki Worden, President, Worden Associates, Inc.

On October 6, the Federal Trade Commission (FTC) announced that its long-awaited proposed changes to the  Green Guides have been released. FTC seeks public comment on the changes, which include new guidance on marketers’ use of product certifications and seals of approval, “renewable energy” claims, “renewable materials” claims, and “carbon offset” claims. The FTC is seeking public comments on the proposed changes until December 10, 2010, after which it will decide which changes to make final.  Our blog today provides background on the Green Guides and a brief analysis of the proposed changes.

Background

FTC introduced its “Green Guides” in 1992 (updated in 1998 and this version likely to be finalized in 2011), which specifically address the application of Section 5 of the FTC Act.  Section 5 of the FTC Act protects against unfair methods of competition or deceptive acts affecting commerce.  The Green Guides, more formally known as the FTC’s Guides for the Use of Environmental Marketing Claims, provide significant direction to advertisers in areas relevant to most green product claims.  The guides provide the basis for voluntary compliance with truth in advertising laws.  A short list of relevant marketing Dos & Don’ts from the Green Guides can be paraphrased as:

Do:

1. Tell the truth
2. Substantiate environmental claims with competent and reliable evidence
3. Be specific by using clear and prominent qualifications

Don’t:

1. Unintentionally mislead, for example, a) by highlighting one environmental attribute while completely ignoring other potentially more serious environmental issues or b) by highlighting the environmental attributes of the package but allowing the consumer to presume the claim applies to the product within
2. Don’t overstate product claims
3. Don’t use generic words that provide no specific benefit to the consumer, for example, eco-friendly and eco-safe do not allow consumers to compare one product against another based on these claims.

The FTC also makes clear that the emphasis in its enforcement is based on the consumer’s perception of what a claim is saying.

Oct. 6 Proposed Changes

FTC Chairman Jon Leibowitz says, “The proposed updates to the Green Guides will help businesses better align their product claims with consumer expectations.” Here’s a rundown of some of the more interesting changes.

Use of “sustainable,” “natural,” “organic” – Proposed changes don’t address use of the terms “sustainable,” “natural,” and “organic.” Just for the record, the word sustainable might as well fall into the FTC’s “general environmental benefit” category.  It is too general, and therefore difficult to substantiate.  Natural, is most often used in environmental marketing to describe the use of biobased content in the construction of the product.  However, no federal agency currently defines natural as it applies to most products (other than food, where USDA does step in). Worden Associates, Inc. has recommended that industries consider moving toward the use of “natural/biobased” to promote greater understanding of what is meant when using this word in marketing. The USDA does define biobased material and there is an ASTM test that can be used to substantiate claims of biobased content in a product.  Organic is defined by USDA as it is applied to crops…and the yield from those crops can be certified under the National Organic Program.  However, once those crops are turned into a finished products, for instance, cotton into a t-shirt or blanket, the USDA certification does not apply.  Our understanding is that the Global Organic Textile Standard (GOTS) is the leading international certification for finished products. Many believe the USDA will be broadening its reach in this area. We welcome and encourage knowledgeable commenters to let us know what you know in this area.

Certifications and Seals of Approval - This is a new section in the Guides. It notes that these certs/seals are covered by the FTC’s Endorsement Guides. It provides more examples and makes clear to marketers that they should substantiate use of the Seals by clearly and prominently qualifying the attribute(s) that are addressed by the Seals. It also makes clear that third-party certification does not remove the marketer’s obligation to substantiate claims.

Degradable – is clarified as must completely degrade within one year.  It also specifies that marketers cannot make degradable claims if the product is destined for landfills, incinerators, or recycling facilities because the product won’t degrade within one year.  It will be interesting to see how marketers respond to this change.

Recyclable – the proposed changes would force marketers to determine if their product falls into one of three categories and make appropriate qualifications (i.e., “may not be recyclable in your area” or “is only recyclable in a few communities”).  On the latter, if less than a “significant percentage” of consumers have access to recycling programs, you are supposed to note this.  This is a very specific change and may nullify any benefit marketers previously had when using this term.

Made with Renewable Materials – the FTC wants marketers now to be specific about what is renewable, how it is sourced, why it is renewable.  They should also note what specifically is renewable and not apply the term generally when there are also non-renewables in the product.  One example of substantiation provided by FTC is: “Our packaging is made from 50% plantbased renewable materials. Because we turn fast-growing plants into bio-plastics, only half of our product is made from petroleum-based materials.”

Made with Renewable Energy – must now be specific about the kind of renewable energy used. Also, marketers cannot make this general claim if any part of the product is made with fossil fuels.  It must be “virtually all” made with renewable energy or conventional energy offsets using RECs.

All in all, the changes were not sweeping.  I can’t quite say that it’s “much ado about nothing.” There are important messages made clear by the FTC’s proposed changes and all marketers should review the proposed changes as you plan your upcoming marketing campaigns.  To review a detailed summary, visit the FTC’s website at http://www.ftc.gov/opa/2010/10/greenguide.shtm.

We at Worden Associates, Inc. look forward to hearing your comments.

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Welcome to Worden Associate’s Blog

Hello and welcome to our blog.

Worden Associates, Inc. is an environmental consulting firm specializing in development and promotion of innovative technologies, concepts, programs and services. We work with a variety of industries, corporations, and non-profit associations promoting environmentally-oriented products and messages.

Originally founded in 2005 in Annapolis, Maryland, Worden Associates, Inc., is now headquartered in beautiful Camden, ME.  President Vicki Worden and her husband/business partner Dr. Greg Worden have helped clients from coast to coast and throughout North America with services that include:

• Market analysis;
• Planning & business development;
• Environmental program development, consensus standards, rating systems, and ecolabels;
• Project management, stakeholder engagement, technology management; and
• Integrated public relations, marketing, sales and advocacy campaigns.

For more information on our firm, visit us at www.wordenassociates.com.  Thanks for dropping by!