What Does “Natural” Really Mean in Cosmetics? Understanding COSMOS Standards

One of the questions I’m asked most frequently about ingredients or formulas is, “Is it natural?” The short answer is maybe; the longer answer is also maybe. The problem is that we don’t really have a good definition for “natural.”

The “Naturally Derived” Dilemma

You’ll often see ingredients or products described as “naturally derived,” meaning an ingredient is sourced, then processed, from something found in nature. This label might appear on a foamy, bubbly surfactant like sodium cocoyl isethionate (derived from coconuts) or an emulsifier like cetearyl olivate (derived from olives), but this terminology is quite ambiguous.

If we define “natural” as something we find in nature, then every ingredient we could possibly use is “naturally derived”:

• Coconut oil is natural as it’s derived from coconuts
• Lactic acid and sodium lactate are natural – often derived from milk
• Decyl glucoside, caprylyl/capryl glucoside, and coco glucoside are natural as they’re derived from oils, like coconut oil, and glucose
• Silicones like cyclomethicone and dimethicone are natural because they’re derived from sand
• Mineral oil is natural as it’s composed of ancient plant matter (and free-range, cruelty-free dead dinosaurs!)

If “derived from nature” is our only criterion, then silicones and petroleum products would qualify as natural. Clearly, we need a more stringent definition.

A Better Approach: Certification Standards

The concept I prefer is “naturally compliant” – ingredients that meet certification standards set by organizations like ECOCERT, NaTrue, COSMOS, or ISO 16128. These organizations have established clear criteria for what qualifies as natural or organic.

Let’s use the COSMOS Natural certification standards as our framework.

COSMOS certification is guided by principles to:

• Promote products from organic agriculture and respect biodiversity
• Use processing and manufacturing that are clean and respectful of human health and the environment
• Follow “Green Chemistry” concepts in all aspects of ingredient and product creation

Reference: COSMOS Standard

Reference: What Green Means for Cosmetics

Green Chemistry Goals

The goals of Green Chemistry include:

• Reducing pollution
• Using less energy
• Using more biodegradable ingredients and packaging
• Using renewable resources that biodegrade or are designed to biodegrade

Reference: Green Chemistry Principles

Reference: Cosmetics & Toiletries August 2013

There’s a preference for using less energy when formulating. Cold-processed products are preferred over those that need to be heated and cooled, like some lotions, creams, body butters, and hair conditioners.

For example, creating a body oil with different liquid natural oils at room temperature uses less energy than a solid lotion bar or lip balm with butters, waxes, and oils that need to be heated above 72.5°C (162.5°F). This doesn’t mean the lotion bar isn’t natural—it’s just less “green” than something that doesn’t require heating.

Safety Note

It’s important to note that ingredients not approved under COSMOS standards aren’t necessarily dangerous or unsafe—they simply don’t fit those specific standards. There’s a common misconception that personal care products aren’t regulated, making ingredients unsafe. In reality, every ingredient used in formulating has been deemed as generally recognized as safe (GRAS) for skin and hair care products. The Cosmetic Ingredient Review scientific panel assesses every ingredient, determining suggested usage rates and appropriate product types.

What COSMOS Allows and Disallows

Disallowed:

• Mineral oil, petrolatum, ozokerite wax, other petrochemicals
• Derived colorants
• Animal testing of ingredients or products
• Nano-forms of titanium dioxide and zinc oxide
• Silicones

Allowed with Limitations:

• Ingredients with a small percentage of petroleum-derived compounds (less than 2% of the product), such as:
  • Cocamidopropyl betaine (foamy surfactant)
  • Carbohydrate methyl cellulose (water thickener)
  • Guar Hydroxypropyl Trimonium Chloride (conditioning ingredient)
• Petroleum derivatives in the extraction of some ingredients like lanolin, carrageenan, or lecithin
• Titanium dioxide and zinc oxide (non-nano forms)

COSMOS Ingredient Categories

COSMOS defines five categories “in ascending order of human intervention”:

1. Water

Includes spring, reverse osmosis, distilled, sea, and potable water. Some products replace water with:

• Hydrosols and distillates (water left over after distilling plants for essential oil)
• Infused waters (teas that replace water in a formula)

2. Mineral-Based Ingredients

• Colorants like micas or iron oxides
• Silver, gold, and glass
• Minerals like calcium, magnesium, iron, potassium, or sodium
• Salts (magnesium chloride, magnesium sulfate/Epsom salts, sodium chloride)
• Clays and diatomaceous earth

3. Physically Processed Agro-Ingredients

This includes nearly every plant imaginable (excluding GMOs) and materials from dead vertebrates (disallowing tallow and lard).

This category encompasses:

• Oils, butters, waxes, and other botanical ingredients
• Compounds found in plants (resveratrol, proanthocyanins, lutein)
• Derivatives of plant ingredients

Animal products are allowed if they don’t cause “pain, stress, or death,” including:

• Milk
• Honey
• Wool
• Silk
• Carmine (red color produced by crushed beetles)

Note: Being COSMOS compliant doesn’t mean a product is vegan. Products labeled as plant-based or plant-derived aren’t necessarily vegan unless confirmed on the label.

4. Processing Methods

Almost all cosmetic ingredients undergo mechanical processing—nothing goes from farm to bottle without refinement to remove bugs, plant matter, unpleasant odors, and other undesirable properties.

Allowed Processing Methods:

• Oil refining (cleaning and removing compounds that accelerate rancidity or create unpleasant odors)
• Processing botanical extracts (drying, grinding, infusing, macerating, freezing, squeezing, crushing, sifting)
• Essential oil extraction
• Chemical processing (within limits)
• Saponification (creating soap from lye and fats)
• Fermentation (converting sugars into alcohol or acid)
  • Example: Xanthan gum (fermented sugar with Xanthomonas campestris bacteria)
  • Example: Fermented algae and botanical extracts as active ingredients
• Hydrogenation (breaking double bonds on fatty acid chains to increase resistance to rancidity)

Disallowed Processing:

• Ethoxylation (an industrial process where ethylene oxide reacts with fatty acid or fatty alcohol)
  • This process produces emulsifiers for lotions, solubilizers for fragrance sprays, and foamy surfactants
  • Identifiable by “PEG-” or “-eth” in the name (e.g., PEG-100 stearate, polysorbate 80, ceteareth-20, sodium laureth sulfate)

5. Product-Protecting Ingredients

For products containing or exposed to water, protection from microbial growth and rancidity is essential. This typically includes:

1. Anti-oxidants like Vitamin E (allowed under COSMOS)
2. Preservatives:
   • COSMOS-approved options include benzoic acid, dehydroacetic acid, Leucidal*, and combinations like Caprylyl Glycol (and) Glyceryl Laurate (and) Glyceryl Undecylenate
   • Non-approved (but commonly used) preservatives include parabens, phenoxyethanol, and diazolidinyl urea
3. Chelating ingredients to bind metals:
   • Sodium phytate (some versions COSMOS-approved)
   • EDTA (not allowed)

Note: Studies have shown that some “greener” preservatives like grapefruit seed extract and Leucidal may contain non-approved preservatives that contribute to their effectiveness.

Label Analysis Example

Let’s examine a eucalyptus and lime scented coconut & buriti body milk:

Ingredients: Water, caprylic/capric triglycerides, Buruti oil (INCI: Mauritia Flexuosa (Buriti) Fruit Oil), Olivem 1000 (Cetearyl olivate and sorbitan olivate), glycerin, propanediol 1,3, glyceryl stearate, Acacia senegal gum, xanthan gum, sodium phytate*, mixed tocopherols (Vitamin E), eucalyptus essential oil, lime essential oil, Germall Plus* (Propylene glycol, diazolidinyl urea, iodopropynyl butylcarbamate)

This body milk is 99.3% naturally compliant:

• COSMOS-compliant ingredients:
  • Caprylic/capric triglycerides (medium chain triglycerides/fractionated coconut oil)
  • Emulsifiers (cetearyl olivate and sorbitan olivate – non-ethoxylated)
  • Glyceryl stearate (allowed ester)
  • Acacia senegal gum and xanthan gum
  • Mixed tocopherols (anti-oxidant)
  • Essential oils
• Potentially non-compliant:
  • Sodium phytate (only certain versions approved by COSMOS)
• Non-compliant:
  • Germall Plus preservative system (propylene glycol, diazolidinyl urea, iodopropynyl butylcarbamate)

Recommended Alternative Preservation System

For COSMOS compliance, consider:

• A combination of COSMOS-approved acids (benzoic acid, sorbic acid, or dehydroacetic acid)
• 0.2% mixed tocopherols as anti-oxidant
• 0.2% sodium phytate (if using a COSMOS-approved version)
• Package in an airless pump for extended shelf life

For “clean” (but not COSMOS) compliance, consider:

• Phenoxyethanol with ethylhexylglycerin plus approved acids
• This would provide effective preservation for a year or longer

---

For more information, refer to the complete COSMOS Criteria: COSMOS Standard v4.1