Can tap water be considered an organic ingredient?

March 2, 2004
The Organic Trade Association's Personal Care Task Force meeting at Natural Products Expo West in California plans to study whether tap water can be considered an organic ingredient.

OTA Task Force vote for "organic water" scheme revoked; Rutgers University study highlights need for USDA action

ANAHEIM, CA, March 2, 2004 -- Can tap water be considered an organic ingredient? That was the fundamental question personal care companies were going to grapple with at the Organic Trade Association's (OTA) Personal Care Task Force (PCTF) meeting at Natural Products Expo West at the Anaheim Convention Center on Saturday, March 6 at 11:00 am to 1:00pm in room 202b.

It is the first meeting of the OTA PCTF since the Organic Consumers Association (OCA) filed a Complaint on February 18 against Bayliss Ranch and their certifier Quality Assurance International (QAI) with the USDA's National Organic Program (NOP), for counting ordinary water in "hydrosol water extracts" as organic in violation of the fundamental purpose of the National Organic Program, which mandates products must be at least 70% organic WITHOUT counting water.

On March 8, 2002, having been misinformed by Bayliss Ranch that the FDA counts ordinary water in hydrosol water extracts like a fruit juice, the OTA PCTF had voted that such water can count as "organic".

However, in a surprise development last week, OTA President and PCTF Chair Phil Margolis formally stated: "It is the chair's understanding that the vote on hydrosols taken on March 8, 2002, was revoked, because the vote was based on the mistaken assumption that at that time hydrosols had an FDA standard of identity, and that by this re-affirmation of that understanding, the percentage calculation will be governed by NOP method of calculating the percentage of organic ingredients."

"The OCA is certainly pleased that the OTA has formally revoked that position, as it served to sanction the organic water scheme long enough for it to get a strong foothold in the marketplace," says Craig Minowa, Environmental Scientist for the OCA. "Now, because of QAI's certification, the USDA's NOP must also formally reject this scheme in order to have meaningful organic labeling standards for food and personal care products." USDA must respond to the OCA complaint by May 19 this year. "The question for the USDA is whether the U.S. government will allow unethical companies who violate NOP regulations to profit off the word 'organic'," says Minowa.

Rutgers University case study finds Hydrosol water extract is mostly ordinary water

Contained in the Complaint (see is a study performed by the New Use Agricultural Natural Plant Products Program at Rutgers University (NUANNP; Pierre Tannous, Rodolfo Juliani, Mingfu Wang and Jim Simon, Water Balance in Hydrosol Production Via Steam Distillation: Case Study Using Lavandin (Lavandula x intermedia).

This provides a first scientific study of the minimum theoretical contribution of water from the steam versus the plant material to a hydrosol water extract while essential oil is distilling. Even with extremely unrealistic conservative assumptions, study found that the minimum contribution of water from steam was at least 71%.

Currently, an increasing number of brands, such as Avalon Natural Products, JASON, and Nature's Gate, are misleading consumers into thinking 70% of the ingredients in their products are "organic". (70% organic content enables a product to make a front panel organic label claim under the National Organic Program.)

All these companies are supplied organic hydrosol water extracts by a single supplier, Bayliss Ranch, certified by QAI, the largest organic certifier in the world. Similar to an infusion or tea, which is made by boiling plant material in water, hydrosol water extracts are made by steaming plants, and then cooling the steam back to water.

Products made with infusions or teas cannot count the water in such teas or infusions as organic in calculating organic content under NOP food standards. However, it has become distressingly common practice to use "Steam Tea" as the main "organic" ingredient in many products by misleadingly counting the ordinary water in such "Steam Teas" as organic.

The OCA is a grassroots nonprofit organization concerned with food safety, organic farming, sustainable agriculture, fair trade and genetic engineering.


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