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.
