June 2, 2008

Tim Iudicello
President, Botanie Soap, Inc.

Re: Soap as an organic product in material and practice

Soap is the result of a chemical reaction between a triglyceride and an alkali base. Thetriglyceride can be any fat or oil, and the alkali base is usually either sodium hydroxide (used for bar soaps) or potassium hydroxide (used for liquid soaps). In the reaction, called
saponification, the original components are both completely transformed. This reaction differs from the manufacture of other skin care products, which tend to be mixtures or emulsions.

In a mixture or emulsion, the starting materials retain their original form. They are simply blended and/or held together by an emulsifying agent. A lotion made from the emulsion of water and organic oils still contains the organic oils in their original forms, and the only factors influencing whether or not it qualifies as organic are the organic percentages, by weight, of the original ingredients and whether or not the lotion contains any ingredients that can be connected to the NOP’s list of prohibited materials and processes.

There is no soap without the saponification reaction. But since the very reaction that creates organic soap* chemically transforms the original, organic agricultural products into something other, we need to answer the question of whether, since the final soap product does not contain actual, original organic content, soap made from organic oils should be allowed to qualify as an organic product. In other words, is it truly organic? We can certainly say that organic soap has been made with organic ingredients, but does this catch the spirit and meaning of “organic?”

Organic certification seeks to provide a standard for consumer confidence. In the case of soap, the consumers’ question is not whether saponification, which is the only way to have soap, significantly alters the molecular structure of the original certified organic ingredients, but whether or not an overwhelming majority of the ingredients have organic origins, whether or not the production of these ingredients is in accord with clean agricultural practices, whether or not the final product is safe and even healthy for them, and whether or not the product is free of known or suspected irritants and carcinogens, petroleum products, and, in most cases, animal products. The true starting point to this question is whether the manufacture of soap from organic oils is true in its essence; that is, can soap making keep in spirit with the meaning and purpose of organic agriculture and organic consumer products?

One approach to making this determination involves comparing soap to other organic products whose manufacture includes transformation, such as cheese. Although several insightful examples may be found for this comparison, none will be strictly analogous, and the question won’t be answered without making vague leaps.

Instead, a defining line can be drawn in the sand, a line based on the phrase “minimally processed” found in the NOP’s literature. Unfortunately, “minimally processed” is an ambiguous term implying a different standard for each industry or product type. For example, the minimal processing required for cold-pressed organic olive oil will be very different than the minimal processing of organic milk that has been pasteurized, homogenized, and fortified with vitamins A and D. However, within a given product family, “minimally processed” can be defined and used as a standard of comparison for products within that family.

For soaps, the following guidelines might form the basis for defining what “minimally processed” organic soap means and might serve as the line in the sand for separating organic soap from the others. To avoid complication, these standards do not address the addition of color or fragrance which, of course, should be derived solely from plant origin, and they do not address the use of accepted additives for preservation.

  • All triglycerides used in saponification should be organic vegetable oils
  • No organic soap should be made with processed animal fats or any petroleum products.
  • No blending of organic and non-organic base oils should occur (even if this blending still keeps the total organic content of the ingredients above 70%). This is in keeping with the NOP’s policy that organic ingredients must be used when they are available rather than their non-organic counterparts, and it assures that soap manufacturing embraces the purity and wholesomeness that underlie the term organic.
  • Organic soap should be made from whole, organic oils and not from pre-split fatty acids, even if they were processed from organic origins. This standard favors the cold-process, semi-boil, and full-boil production methods and calls into question some continuous saponification processes.
  • Sodium hydroxide should be the only synthetic, non-agricultural ingredient.
  • The salting out (removal) of glycerin is an unnecessary processing step that demeans the wholeness of the original organic ingredients. In addition to adding an unneeded, mechanical processing step to the soap making process, the removal of glycerin is a step that actually reduces the percentage of final product with organic origins.

With these six, simple guidelines, soap manufacturing fits within the “spirit of organic” in both its ingredients and processes. Most importantly, these guidelines keep soap manufacturing within the understanding and grasp of the average consumer, instilling confidence in him/her that the soap product on the shelf whose packaging includes the word “organic” was minimally processed and produced with organic ingredients.

* Because of the minimum quantity of sodium or potassium hydroxide required for saponification, soap made from organic oils cannot ever reach the 95% mark to qualify as “organic” under the NOP’s guidelines, and it will always fall into the “made with organic…” category. For purposes of this memo, I will use the term “organic soap” to refer to a soap product whose original ingredients have an organic content of at least 70% of the total ingredients to distinguish this type of soap from soap made from animal fat or non-organicvegetable oils.