What COSMOS, Soil Association and NATRUE actually check before a balm is certified

Certification audits sourcing, processing and paperwork. It says nothing about how well a balm performs or how gently it will treat your skin.

A certification mark answers one question thoroughly and a different question not at all. It tells you that somebody with audit rights has traced where the plant material came from, how it was processed and what the packaging is made of. It tells you nothing about whether the balm will suit your skin, last a year in a warm bathroom or outperform an uncertified one. This page sets out the thresholds each scheme applies, what the auditor looks at, and the questions certification is the wrong tool for.

• COSMOS ORGANIC: 95% of agro ingredients
• 20% organic of whole product
• ISO 16128 is a calculation, not a certificate
• Audited annually

Organic has no legal definition on a cosmetic

The EU organic regulation, Regulation (EU) 2018/848, covers agricultural products, food and feed. Cosmetics are outside its scope, and the retained UK regime works the same way. So an olive can be legally organic, and the olive oil pressed from it can carry an organic certificate, but the finished balm sits in a legal gap where nobody has defined the word at all. In the United States the position is stated plainly by the regulators themselves: the FDA does not define or regulate the term organic for cosmetics, while the USDA National Organic Program regulates it only where a producer chooses to certify a product containing agricultural ingredients.

Private standards grew into that gap, and they are contracts rather than statutes. A brand pays a certification body, agrees to be audited against a published document, and buys the right to print a mark. That structure is why the marks mean something concrete and why they mean something narrower than most buyers assume. It also separates them cleanly from the unregulated vocabulary covered in chemical free, clean and non toxic claims, where nobody is checking anything.

What COSMOS actually requires

COSMOS-standard is owned by an association formed by BDIH, Cosmebio, Ecocert, ICEA and Soil Association. Since 2017 those bodies certify cosmetics to this single document, so a Soil Association beauty mark and an Ecocert beauty mark are the same standard audited by different organisations with different logos and fee schedules. There are two grades, and they are easy to confuse on a shelf because the wording differs by one word.

COSMOS ORGANIC needs two thresholds met at once. At least 95 percent of the physically processed agro ingredients, meaning the plant and animal derived materials that have only been pressed, filtered, ground or similar, must come from certified organic production. And at least 20 percent of the total product by weight must be organic, dropping to 10 percent for rinse-off products, non-emulsified aqueous products and products that are at least 80 percent mineral. COSMOS NATURAL applies every other rule in the standard but sets no organic minimum at all, which is the distinction most shoppers miss.

Both grades carry the same prohibitions. No ethoxylation, so no PEGs. No GMO material, no irradiation, no animal testing. Petroleum-derived emollients are excluded, so mineral oil and petrolatum cannot appear, a decision made on origin rather than on the safety evidence discussed in natural versus petroleum. Synthetic ingredients are capped at 5 percent of the product and must come from a short permitted list, which is where the handful of allowed preservatives sit. Materials from dead animals are prohibited, which is why beeswax and lanolin are permitted, both being produced by living animals, and why tallow can never be COSMOS certified no matter how the cattle were raised.

Why an anhydrous balm clears the maths almost by default

Water cannot be organic. Neither can a mineral. Those two facts decide who finds COSMOS ORGANIC easy and who finds it painful, because the 20 percent whole-product threshold counts everything in the jar including the parts that can never qualify.

A balm is close to a best case. Every component is an agro ingredient, most are available with organic certificates, and there is no water taking up two thirds of the formula. A cream maker has to reach 20 percent organic content from the roughly 28 percent of the jar that is not water, while also paying for an emulsifier and a preservative out of that same budget. That is a genuinely hard formulation problem, and it is why cream ranges lean on organic plant juices and hydrosols whose plant water can count as organic under defined conditions.

The traps for a balm maker are elsewhere. Certified organic beeswax comes from certified organic apiculture, which is far rarer and dearer than certified organic sunflower oil, and one conventional wax at 20 percent sinks the whole agro calculation, as the second row above shows. Wild-harvested waxes such as candelilla and carnauba need certified wild-collection status to count, which not every supplier holds. Minerals behave differently from conventional agro ingredients: zinc oxide or iron oxide pigments pull the whole-product percentage down but leave the 95 percent agro figure untouched, so a heavily pigmented balm can still certify.

How the schemes differ in practice

The practical consequences of those differences are worth stating. NATRUE calculates on the natural substance fraction rather than the whole product, so a water-rich product is not penalised the way COSMOS penalises it, and a NATRUE organic tier claim is not directly comparable with a COSMOS ORGANIC one. The USDA seal likewise excludes water and salt from the sum, which means an American organic body lotion and an American organic balm are held to arithmetic that treats them identically. And the NOP is an agricultural standard: it does not carry the packaging rules, process restrictions or the ban on petroleum-derived emollients that COSMOS applies, so the two marks encode different values as well as different numbers.

ISO 16128 is arithmetic, not a certificate

ISO 16128 comes in two parts, definitions published in 2016 and calculation criteria published in 2017. It defines a natural index, a natural origin index, an organic index and an organic origin index for ingredients, and gives the rules for rolling ingredient indices up into a figure for a finished product. What it does not do is certify anything. There is no audit, no certifier and no licence, and a brand can calculate and print the number itself.

Two features make the resulting percentages hard to compare with a certification. Water counts as natural with an index of 1, so a product that is 90 percent water starts at 90 percent natural origin before any plant material is added. And the standard sets no restrictions on how an ingredient may be processed, so a material made by a route COSMOS explicitly forbids can still carry a high natural origin index. Both COSMOS and NATRUE have publicly cautioned against treating ISO 16128 figures as equivalent to certification. When you see "98 percent natural origin, ISO 16128" on a pack, read it as a calculation the brand performed under a published method, which is more than nothing and much less than an audit. Where that sits among the other things printed on a jar is covered in reading a balm label.

What an auditor actually looks at

The audit is a paperwork exercise about provenance and process, and knowing its shape tells you exactly which claims a mark supports.

• Ingredient dossiers. Every raw material needs a specification, an INCI name, a stated origin and manufacturing route, and for organic materials a valid certificate naming the operator and the product. Suppliers who cannot produce that paperwork are unusable regardless of quality, which is one of the real constraints discussed in sourcing ingredients.
• Chain of custody and mass balance. The certifier reconciles what you bought against what you made and what you sold. Batch records are the evidence, and they have to exist before the audit rather than being assembled for it.
• Permitted processes and solvents. Physical processing is largely unrestricted. Chemical routes are limited to a defined list, and extraction solvents are restricted to materials such as water, ethanol, vegetable oils, glycerin and carbon dioxide, so a hexane-extracted oil generally cannot be used as a certified ingredient.
• Segregation and cleaning. If certified and uncertified products share equipment, the cleaning and changeover procedures are inspected.
• Packaging. Certain plastics, notably PVC, polystyrene and other chlorinated materials, are prohibited, and there are requirements around recyclability and pack information. That is a prohibited materials list rather than an environmental assessment, so it overlaps with sustainable packaging choices without being the same thing.
• Label approval before printing. The certifier signs off the exact artwork, the percentage statements and the placement of the mark and licence number.
• An annual inspection, usually on site, with the possibility of unannounced visits and market sampling.

What certification never checks

Nothing in that list involves human skin. A certified balm has not been tested on anybody, compared with anything, or measured for any physical property. Specifically:

Allergenicity. Essential oils are permitted and encouraged by every natural standard, and they are the single largest source of declarable fragrance allergens in cosmetics. A COSMOS ORGANIC balm can carry a long allergen tail on the label and provoke reactions that a plain petrolatum ointment would not, as set out in fragrance allergens and the labelling rules in fragrance allergen labelling.

Irritation and breakouts. No scheme runs a patch test, a use test or a comedogenicity assessment. Whether a balm suits acne-prone skin is a formulation question addressed in will a balm break me out, and the mark has no bearing on it.

Performance. Occlusivity, water loss reduction, hardness, glide and slip are never measured. Two balms with identical marks can differ enormously on the measurements described in measuring occlusivity.

Stability in your bathroom. Organic sunflower oil oxidises at the same rate as conventional sunflower oil, because the fatty acid profile is what matters, not the farming method. Certification restricts synthetic antioxidants, which can leave a certified balm less protected against rancidity and oxidation than an uncertified one containing a synthetic stabiliser.

Safety in the legal sense. In the UK and EU, a cosmetic product safety report signed by a qualified assessor is a separate legal requirement, described in safety assessment and the CPSR. A certification body does not perform it and holding a mark does not discharge it.

What it costs, and why competent small makers stay uncertified

The published fee structures share a shape: an application fee, an annual licence fee usually scaled to turnover, an audit charge based on inspector days plus travel, and per-product or per-formula listing fees. As at 2025, a European micro business that certifies a small range is typically looking at a four figure annual total in pounds or euros before a single ingredient changes.

The larger costs are indirect. Certified organic raw materials cost more and are less reliably available, so a supply gap can force a reformulation. Every formula change goes back to the certifier for approval, and every label change too, which suits a stable range and punishes an experimental one. You must hold and file a current certificate for every batch of every certified material. Set that against the margin on a fifteen product range sold from a market stall and it is easy to see why many capable makers never apply.

The inference to draw is therefore weak in one direction and reasonable in the other. An uncertified balm may be made from identical organic materials by someone who simply could not justify the licence. A certified balm does tell you the brand could afford the process and chose to submit to it, which is a real signal about intent and a poor one about quality, as do expensive balms work better works through in more detail.

Reading a certified pack properly

Three things distinguish a certification from a graphic. The scheme name and grade, spelled out, so COSMOS ORGANIC rather than a leaf. The certifying body named, such as Soil Association or Ecocert Greenlife. And a licence, certificate or operator number that could in principle be checked against the certifier's public register. A mark with no certifier and no number is a design element the brand drew.

The percentage statements are worth reading closely, because two different denominators are in play. "95 percent of the total ingredients are of natural origin" and "20 percent of the total ingredients are from organic farming" are the standard COSMOS wordings and refer to the whole product. A claim that a given percentage of the plant content is organic is a different and usually larger number. Beyond that, the parts of a label that carry regulated meaning are the ingredient list, the allergen tail and the period after opening, and for anyone selling into the UK or EU the full requirements are in selling balms in the UK and EU.

The decision rule

Use a certification for provenance questions and the ingredient list for skin questions. If what you want to know is whether the shea was grown without synthetic pesticides, whether the supply chain is traceable, whether petroleum-derived materials or ethoxylated surfactants were used, or whether the packaging passed a screen, the mark is good evidence and hard to fake. If what you want to know is whether this balm will sting your eczema, block your pores, hold together at 30 C or still smell right in eight months, the mark is silent and the INCI list is not.

Certification also encodes values that are not skin science at all. The exclusion of tallow is an origin rule rather than a performance judgement, and the separate question of how the material behaves is dealt with in is tallow good for skin. The exclusion of petrolatum is the same kind of rule. Vegan status is not covered by these schemes, since beeswax and lanolin are permitted, and needs the different marks discussed in vegan and cruelty free labels. None of it substitutes for trying a small amount on your own skin first, which is why the last step before committing to a jar of anything is still a patch test.

Reviewed and updated 6 September 2026. Spotted an error? Tell us and we will fix and log it.