The Premium Vegan Guideline
Various groups of raw materials are used in vegan natural cosmetics:
1) Natural substances; NCS/Natural Complex Substances
Substances from nature (plants, no animal substances, biotechnological raw materials, mineral/inorganic substances)
2) Natural substance derivatives; NCS derivatives/Natural Complex Substances derivatives
Substances produced from natural substances according to permitted methods
3) Perfume and flavourings according to ISO 9235
4) Synthetic substances with defined use permissions
1) Natural substances; NCS/Natural Complex Substances
Natural substances are used as such or obtained from physical processes. 4 natural sources are differentiated:
a) Vegetable raw materials
As far as possible, the use of vegetable raw materials must consist of certified organic starting material / organic quality / certified organic cultivation. The obligation is regulated by a positive list (annex 1 to the directive), the scope of which depends on
- quality
- availability
- reasonable pricing
Since not all cosmetic raw materials from the plants on the list of organic obligations are available in organic quality, special cosmetic raw materials are excluded in the documented case. The organic portion is determined according to the association’s own organic calculation rule SOP (annex 2) and can be shown on the packaging label. Using the same calculation method, the proportion of natural ingredients without organic quality (all raw materials of group 1) can be determined and indicated on the packaging.
Alternatively, the use of plant material from certified wild collection is permitted. Only plant material that is not available from the sources thus defined may be used from conventional cultivation.
b) Animal raw materials: vegan qualification
The use of substances from animals is not permitted. The abandonment must be documented. This documentation is part of the conformity test by a certifier. He must expressly mention the confirmation of this point in his report.
c) biotechnologically produced cosmetic raw materials
Since microorganisms are just as much components of nature as plants and animals, their metabolic products and components are also permitted for use in vegan natural cosmetics. The inclusion of GMOs in the biotechnological production of cosmetic raw materials is prohibited.
d) Mineral and inorganic substances
Minerals of any form are part of nature and therefore permitted. The formation of inorganic salts, acids and alkalis (e.g. sodium chloride, magnesium sulphate…) corresponds to natural processes and is also permitted.
2) Natural substance derivatives; NCS derivatives/Natural Complex Substances derivatives
For the production of vegan natural cosmetics, natural raw materials may also be used which are produced from natural substances/ncs. The use of organic raw materials as starting materials is ideal. A compilation is made according to the state of the art in annex 4. Permitted manufacturing processes are hydrolysis, hydrogenation, esterification also with inorganic acids (exception: hydrogen halide acids), redox processes, other cleavages and condensation reactions. Existing documentation on the environmental compatibility of these substances shall be collected in the product documentation. Nature-identical substances according to these procedures are permitted if nature is not sufficient as a source for starting materials.
3) Perfume and flavourings according to ISO 9235
The approval criterion for natural fragrances and flavours is ISO Standard 9235. In addition, fragrances and flavours obtained from processes based on natural processes such as biotechnological production are permitted for use.
4) Synthetic substances with defined use permissions
The consumer rightly expects microbiologically flawless quality from vegan natural cosmetics as well. The following nature-identical preservatives can be used for this purpose:
- Benzoic acid and its salts and ethyl esters
- Sorbic acid and its salts
- Formic acid
- Salicylic acid and its salts
- Propionic acid and its salts
- Benzyl alcohol
When using these preservatives, the addition: „Preserved with …[name of preservative]“ is required.
Vegan natural cosmetics deliberately do without:
a) Groups of raw materials that are not compatible with the idea of nature
- Synthetic organic dyes
- Synthetic fragrances
- Ethoxylated raw materials
- Contaminations in considerably higher ratios than those occurring in nature. The substances regulated in the cosmetics regulation §1 sentence 2 are not regarded as contamination.
- Silicones
- Halocarbon compounds and intermediates
- Petrochemical products such as paraffin oil and waxes
- Raw materials whose sustainability and environmental compatibility is not known
- Solvents, other than water, ethanol from vegetable raw materials, vegetable oils, vegetable fats, glycerol from vegetable raw materials, carbon dioxide and other solvents necessary for the extraction of defined natural substances, if these are subsequently removed from the defined natural substances.
- Herbal materials under nature protection
- Without traceability in storage and production
- Cleaning and hygiene material that does not correspond to the natural working method
b) Radioactive irradiation
A germ reduction of natural substances/NCS (exception: minerals) or cosmetic end products by radioactive irradiation is not permitted.
c) Nature-harmful packaging
Elaborate packaging, single-use packaging, non-reusable packaging materials, halogenated plastics, compressed gas packaging must be avoided
Control
The verification of compliance with the above criteria for cosmetic products and raw materials used is guaranteed by independent testing institutes. Compliance with the criteria is made visible by a vegan label on the cosmetic packaging and raw material containers. The labelling is limited to a single label with all statements on the standard and organic content. A statement about the organic portion is optional and can be made in percentages and/or by asterisk marking within the INCI declaration. The certification company does not have to be mentioned on the packaging.
Guideline Application
Vegan natural cosmetic products in accordance with this guideline must of course comply with all European and additional national legislation such as
- EU Cosmetics Regulation 1223-2009
- EU REACH Legislation – Regulation n° 1907/2006
- EU Eco-Regulation – Regulation n° 834/2007
The concrete application of the Premium Guideline in cosmetic products and in the production of raw materials is regulated in detail by an SOP/manual.
„Global ethics“ criteria are documented and resolved as mandatory for this policy and then listed in Annex 3. The following points are currently under discussion:
- GMO-free
- Waste management
- Fair Trade
- Third World projects
- Packaging definitions
- Solvent avoidance
- Catalyst restriction
- Social working conditions
- Environmental management
- Certified sustainability
- Organic NCS derivatives mandatory
- Degradability according to OECD 301 A-F
- Green chemistry rules
- Carbon dioxide balances
- Transportation expenditure/regionality
- Energy yield
- Water consumption
- Resource awareness (mica, talc, zinc..)
and much more.
This list and annex 3 will be extended by the corresponding items as soon as the respective technical status permits.
The use of this symbol is reserved only for natural cosmetics companies with the appropriate prerequisites. The authorisation of natural cosmetics companies to use the label is restricted and is ensured by contractual regulations within the association.
Annex 1: Organic plant list of obligations
Annex 2: Organic calculation rule SOP
Annex 3: „Global ethics“ list of obligations (not yet a mandatory)
Annex 4: Natural substance derivatives from list of organic raw material obligations (not yet a mandatory)
If you are interested in our Premium Vegan label for vegan natural cosmetics, please apply at the contact form