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Is there really
an organic mattress?
Part 2 – the Global Organic
Textile Standard & OE Standards
By: Vicki
Worden, President,
Worden Associates, Inc.
and Consultant to the
Specialty Sleep Association
The NOP just issued a new
Policy Memo on May 20, 2011,
on textiles that contain organic
ingredients. I’ll cover
reactions to and implications
from this memo in the Part 3
blog.
May 23, 2011 -
In my
Part 1 blog on the U.S.
Department of Agriculture’s
(USDA) National Organic Program
(NOP) Certification, I
introduced these questions:
• (marketer) How do I assure
consumers that my mattress is
organic? – or –
• (consumer) Isn’t there some
way to ensure that the mattress
I’m buying is as organic as
possible?
To remind my
readers, indicating that a
finished mattress is “USDA
organic” is strictly forbidden
by the USDA’s regulations and is
what one mattress retailer was
warned could warrant up to an
$11,000 penalty. (See Worden
blog: Is there really an
organic mattress – Part 1 – the
National Organic Program
Certification.)
Now introducing…drumroll…the
Global Organic Textile Standard
(GOTS), and Part 2 of the
Worden blog series on “Is there
really an organic mattress?” The
writing of this multi-part
series hastened my coining of
the term “more-ganic”
(definition: once you think you
understand organic you realize
there’s always “more” the
story).
The
Standards
It is difficult to boil down
complex standards, so I ask the
reader to bear with me as I
dissect the process of
developing a “certified organic
mattress.”
This path
forward requires use of and
understanding of NOP (covered
previously),
GOTS, and
Organic Exchange (OE)
standards.
For those without patience, this
entire blog article boils down
to this: NOP =
certified crops/livestock (e.g.,
cotton fiber, wool, sap from a
rubber tree (for latex), etc.).
GOTS = certified
textiles/finished products
(e.g., fabric, apparel,
blankets, sheets, pillows,
mattresses, etc.). OE =
certified organic cotton
purchased and used by the
manufacturer equates to a
verifiable percentage of organic
cotton in the finished product.
GOTS
For your first
introduction to GOTS, you need
to know that it was developed to
define world-wide recognized
requirements about the organic
status of textiles, from
post-harvest handling of the raw
materials, through
environmentally and socially
responsible manufacturing and
labeling. Its purpose is to
provide credible assurance to
the consumer that a finished
product is “certified organic.”
To achieve GOTS certification, a
product must meet one of its
definitions for organic products
and be certified by an
independent third-party
certification organization
approved by the GOTS
International Working Group (IWG).
Licensing and labeling are
governed by the GOTS IWG.
GOTS can be used
to certify a finished product as
“certified organic” if 95% of
the product’s ingredients are
certified organic and the
manufacturer is in compliance
with other GOTS requirements.
GOTS also allows a claim of
“made with x% organic material…”
if 70% or more of the product’s
ingredients have been certified
organic and the manufacturer,
likewise, is compliant with
other requirements.
To understand
exactly what this means, I’ll
follow a mattress through the
process of achieving
certification under GOTS.
Step 1:
Obtaining crop materials that
are certified organic
Mattress
manufacturers must start to
build an organic mattress by
using primarily materials that
are “certified organic.” This
means, each component must be
certified as organic, and the
organic “chain of custody” or
tracking of product from one
supplier to another starts with
obtaining crop-based materials,
such as cotton, wool, flax,
silk, etc.. Any crop-based
product sold in the U.S. as
“certified organic,” regardless
of the country it originated
from, must be certified to be in
compliance with the NOP
standards. The USDA website
provides a list of
USDA accredited certifiers.
To recap,
organic fiber must be certified
to the NOP crop or livestock
production criteria. The fiber
is then processed into fabric,
quilt, or core materials, which
are essential components to a
mattress. (Note: it is our
belief at this time that only
fiber or steel based mattress
cores can qualify for GOTS
certification and that latex and
other foam product cores are not
eligible for certification at
this time.) How then does the
finished mattress with certified
components achieve GOTS
certification?
Step 2:
Purchasing component materials
that have been certified organic
Crops must be
processed into textiles or core
materials. In my Part I blog, I
noted that the NOP certification
frequently does not work for a
finished textile product because
its standards were written with
food in mind, not necessarily
the secondary processes involved
with processing fiber or
producing textiles that
frequently include various
treatments, dying, and other
chemical processing. Enter GOTS.
To comply with GOTS, textile
manufacturers must follow strict
standards for processing and
manufacturing that were
specifically written to address
textiles. Fabric, for instance,
must be processed in such a way
that during the cleaning,
treatment, and dying processes,
the textile manufacturer is
using only processes and
treatments approved by GOTS.
The key criteria
of GOTS requirements for organic
textile processing are:
• At all stages
through the processing, organic
fiber products must be separated
from conventional fiber products
and must to be clearly
identified;
• All chemical
inputs (e.g. dyes, auxiliaries
and process chemicals) must be
evaluated and meet basic
requirements on toxicity and
biodegradability/eliminability;
• Prohibition of
critical inputs such as toxic
heavy metals, formaldehyde,
aromatic solvents, functional
nano particles, genetically
modified organisms (GMO) and
their enzymes;
• The use of
synthetic sizing agents is
restricted; knitting and weaving
oils must not contain heavy
metals;
• Bleaches must
be based on oxygen (no chlorine
bleaching);
• Azo dyes that
release carcinogenic amine
compounds are prohibited;
• Discharge
printing methods using aromatic
solvents and plastisol printing
methods using phthalates and PVC
are prohibited;
• Restrictions
for accessories (e.g. no PVC,
nickel or chrome permitted, any
polyester must be post-consumer
recycled from 2014 onwards);
• All operators
must have an environmental
policy including target goals
and procedures to minimize waste
and discharges;
• Wet processing
units must keep full records of
the use of chemicals, energy,
water consumption and waste
water treatment, including the
disposal of sludge. The waste
water from all wet processing
units must be treated in a
functional waste water treatment
plant;
• Packaging
material must not contain PVC.
From 1st January 2014 onwards
any paper or cardboard used in
packaging material, hang tags,
swing tags etc. must be
post-consumer recycled or
certified according to FSC or
PEFC;
• Technical
quality parameters must be met (s.a.
rubbing, perspiration, light and
washing fastness and shrinkage
values);
• Raw materials,
intermediates, final textile
products as well as accessories
must meet stringent limits
regarding unwanted residues; and
• Minimum social
criteria based on the key norms
of the International Labour
Organisation (ILO) must be met
by all processors
A mattress
manufacturer will want to obtain
component materials from sources
that can produce documentation
from throughout the supply chain
that their processing operation
and thereby finished textiles
have been certified to meet GOTS
standards. Each manufacturer in
the supply chain must be
certified by GOTS and provide
downstream product users with a
transaction certificate. GOTS
certification can be obtained
from any of the international
bodies approved by the
International Working Group that
governs GOTS. This link provides
the list of approved
GOTS certifiers.
Step 3:
Certifying the finished mattress
Just like the
textile/component manufacturers,
U.S. and Canadian mattress
manufacturers that assemble the
components into a finished
product must meet GOTS
requirements for their
manufacturing processes and
facility. GOTS certification
bodies, like Control Union, One
Cert, and Oregon Tilth, require
that the manufacturer document
through an application process
that their component materials
(the fiber) have achieved NOP
certification as appropriate and
GOTS certification as
appropriate (finishing stages).
The application process is then
followed up with an annual
inspection by the certifier. As
long as a manufacturer passes
the inspection each year, the
products manufactured in that
facility under GOTS approved
methods will retain their
certification.
Retailers do not
need GOTS certification but
should verify that the
manufacturer is indeed certified
under GOTS and should not
repackage or relabel a product
that has been certified through
the manufacturer under GOTS.
Retailers should also provide
reference to the GOTS certified
manufacturer’s name and note
which certifier was used.
An example of
language a manufacturer or
retailer could use as a claim
would be: “This mattress was
certified organic in compliance
with the Global Organic Textile
Standard. The certification was
provided to ABC Mattress
Manufacturer by xxx certifier.”
As noted
previously, indicating that a
finished mattress is “USDA
organic” is strictly forbidden
by the USDA’s regulations and is
what one mattress retailer was
warned could result in fines.
(See Worden blog:
Is there really an organic
mattress – Part 1 – the National
Organic Program Certification.)
Retailers or
consumers can look for GOTS
certified mattress manufacturers
using this
link and by typing in the
word “mattress.” At the time of
this writing, two U.S. based
companies are the only North
American companies to achieve
GOTS certification: Naturepedic
and Organic Mattresses, Inc.
(OMI). Readers are encouraged to
check the
GOTS website periodically as
more manufacturers are working
to comply with the
Specialty Sleep Association’s
(SSA) Environmental & Safety
Program , which encourages
truth in advertising through
proper use of terminology and
certifications such as GOTS.
With the SSA program online,
awareness of organic
certifications is growing.
Gaming
the System
(definitely more-ganic)
As I was writing
this blog, I received an email
from someone concerned that a
particular company was making
claims of certification (of one
or more of the certifications
detailed in this series) without
actually having achieved said
certification. I will note that
each of these certification
bodies is as vigilant as
possible in maintaining the
integrity of their brands by
pursuing and preventing false
certification claims.
“Greenwashing” as it’s called
(i.e., making false or generic
claims) comes in many forms.
Consumers should be equally
vigilant as they do their
homework before a purchase. The
websites provided within this
blog allow the opportunity to
verify if certification has been
achieved.
Organic
Watch-dogs: OE 100 and OE
Blended Certifications
As I
investigated more about false
certification claims, I learned
about two more certifications
that are highly relevant. They
were created by the Organic
Exchange (OE for short, and now
OE has been renamed the
Textile Exchange). This is a
membership organization
sponsored by some of the biggest
companies throughout the supply
chain including, Nike,
Nordstrom, Walmart, as well as
mills, input suppliers, and
others from around the world.
OE created two
standards that help assure
consumers that the organic fiber
in a finished product truly came
from an organic farm:
OE 100 and OE Blended.
OE 100 is for
products that want to claim the
volume of cotton fiber in a
product is at least 95% organic.
OE Blended was created to
encourage use of some organic
product even when a majority of
the product is non-organic
cotton fiber or traditional
fiber. OE Blended certifies the
percentage of organic cotton
fiber in a product. For OE
Blended, the finished product
must have at least 5% of organic
cotton to be certified.
These standards
address chain of custody and
organizations that are certified
to either OE 100 or OE Blended
standards open their facilities
to inspectors who will pull a
mattress from a product line,
for instance, and request all
documentation demonstrating
where the organic cotton in that
product originated as well as
proof that it was certified
organic (to NOP standards in the
U.S., right? Right!). The OE
standard requires in-depth
documentation so that inspectors
can “do the math” and ascertain
whether the volume of organic
product purchased is likely to
be reflected in the products
being manufactured.
The extra step
to achieve OE certification is
one more proof point
manufacturers may pursue to
demonstrate that they are
committed to providing organic
and responsibly manufactured
products.
Conclusion
I encourage
readers to think of the building
of an organic mattress as
similar to the building of a
really great sandwich. You
first need the tasty ingredients
(certified to the NOP and OE
standards), components that are
layered in an appropriate way
(certified to the NOP and/or
GOTS, and finally a product
sealed together with a
lip-smacking, final
certification by GOTS.
Stay tuned in
for “Is there really an organic
mattress? – Part 3 – Correctly
applying “organic” to your
products.”
Worden Associates, Inc.
welcomes your questions,
inquiries and perspective on the
content of this blog entry.
We at the SSA look forward to
hearing your
comments.
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Is there
really an organic mattress? –
Part 1 – the NOP Certification
Posted on
April 28, 2011
By: Vicki
Worden, President,
Worden Associates, Inc.
and Consultant to the
Specialty Sleep Association
It’s amazing the amount of
confusion that exists around the
application of the term
“organic.” Perhaps it should be
renamed “more-ganic.” Every
time one thinks they might
understand the term, or the
organic certifications, there
seems to be yet “more” to learn.
Since I have been trying to nail
down how the word organic should
and shouldn’t be applied to
certain products, I thought it
would be beneficial to share my
findings. This blog has been
titled with a Part 1 because I
can already envision Part 2, 3,
and potentially many more
installments before I feel I’ve
completely covered this topic.
Based on my client roster, this
series will be evaluating how
organic is applied to textiles
and finished products, like
mattresses.
First of all, what is
the definition of organic?
In the United States, we need to
consult the U.S. Department of
Agriculture’s (USDA) National
Organic Program (NOP). The NOP
regulates the term organic as it
applies to agricultural products
through its NOP regulation, 7
CFR Part 205.
The NOP regulation does not have
a one-stop shop definition, but
instead provides requirements
for meeting organic farming
standards and crop/livestock
production standards.
-
What is organic?
(from
http://www.ams.usda.gov/AMSv1.0/nop)
-
Organic production is a
system that is managed in
accordance with the Organic
Foods Production Act (OFPA)
of 1990 (PDF) and
regulations in Title 7, Part
205 of the Code of Federal
Regulations to respond to
site-specific conditions by
integrating cultural,
biological, and mechanical
practices that foster
cycling of resources,
promote ecological balance,
and conserve biodiversity.
The National Organic Program
(NOP) develops, implements,
and administers national
production, handling, and
labeling standards.
It goes on to specify in
guidance documents that raw
natural fibers, such as cotton,
wool, flax, etc., are
agricultural products and
covered. However, to earn NOP
certification of a finished
textile product, the textile
must fully meet the
crop/livestock production
standard, which is considered
challenging for many textiles
because these standards were
written for crops and, for
example, certain dyes and other
treatments are not addressed in
the regulation and therefore not
allowed.
If a product cannot meet the
full NOP production standards,
it still may be identified as
having “organic fibers certified
to the NOP crop/livestock
standards.” The marketer may
also state the percentage of
organic fibers contained in the
final product, and the
Specialty Sleep Association
(SSA) encourages manufacturers
to do this to help bring clarity
to consumers and substantiate
their claims.
Manufacturers may not, however,
use the USDA Organic seal or
imply that the final finished
product is certified organic.
One retailer that mistakenly
advertised a mattress containing
organic cotton fiber as a “USDA
organic” mattress in its store
catalog and its advertising was
unfortunately the subject of a
complaint and NOP investigation
(Complaint Case NOPC-107-10,
resolved 4-4-11). The
investigation resulted in the
store having to remove all such
claims and further, having to
prove that the crop components
that comprise the mattress had
indeed been certified as organic
by NOP. Once proof was
provided, the mattress store was
warned that future violations of
the NOP regulations could result
in civil penalties of up to
$11,000 per violation.
(SSA has learned from 4/14/11
meeting with NOP staff that a
Policy Memo will shortly be
issued to provide further
clarification for textile
manufacturers and hopefully help
them to avoid fines. Once
issued, the Worden blog will
provide additional examples of
proper and improper labeling and
advertising for mattresses.)
The threat of an $11,000 fine is
enough to make any manufacturer
or retailer sit up and pay
attention. It also begs the
question: If the NOP program
doesn’t apply to finished
mattresses, how do I
assure consumers that my
mattress is organic? Or for
consumers, isn’t there some way
to ensure that the mattress I’m
buying is as organic as
possible?
Enter the Global Organic Textile
Standards or GOTS, and
Part 2
of the Worden blog “Is there
really an organic mattress?”
Worden Associates, Inc.
welcomes your questions,
inquiries and perspective on the
content of this blog entry.
We at the SSA look forward to
hearing your
comments.
***************************************************************
FTC’s Proposed
Changes to Green Guides
Posted on October
10, 2010
By: Vicki Worden, President,
Worden Associates, Inc. and
Consultant to the Specialty
Sleep Association
On October 6, the Federal Trade
Commission (FTC) announced that
its long-awaited proposed
changes to the Green Guides have
been released. FTC seeks public
comment on the changes, which
include new guidance on
marketers’ use of product
certifications and seals of
approval, “renewable energy”
claims, “renewable materials”
claims, and “carbon offset”
claims. The FTC is seeking
public comments on the proposed
changes until December 10, 2010,
after which it will decide which
changes to make final. Our blog
today provides background on the
Green Guides and a brief
analysis of the proposed
changes.
Background
FTC introduced its “Green
Guides” in 1992 (updated in 1998
and this version likely to be
finalized in 2011), which
specifically address the
application of Section 5 of the
FTC Act. Section 5 of the FTC
Act protects against unfair
methods of competition or
deceptive acts affecting
commerce. The Green Guides, more
formally known as the FTC’s
Guides for the Use of
Environmental Marketing Claims,
provide significant direction to
advertisers in areas relevant to
most green product claims. The
guides provide the basis for
voluntary compliance with truth
in advertising laws. A short
list of relevant marketing Dos &
Don’ts from the Green Guides can
be paraphrased as:
Do:
-
Tell the truth
-
Substantiate environmental
claims with competent and
reliable evidence
-
Be specific by using clear
and prominent qualifications
Don’t:
-
Unintentionally mislead, for
example, a) by highlighting one
environmental attribute while
completely ignoring other
potentially more serious
environmental issues or b) by
highlighting the environmental
attributes of the package but
allowing the consumer to presume
the claim applies to the product
within
-
Don’t overstate product claims
-
Don’t use generic words that
provide no specific benefit to
the consumer, for example,
eco-friendly and eco-safe do not
allow consumers to compare one
product against another based on
these claims.
The FTC also makes clear that
the emphasis in its enforcement
is based on the consumer’s
perception of what a claim
is saying.
Oct. 6 Proposed Changes
FTC Chairman Jon Leibowitz says,
“The proposed updates to the
Green Guides will help
businesses better align their
product claims with consumer
expectations.” Here’s a rundown
of some of the more interesting
changes.
Use of “sustainable,”
“natural,” “organic” –
Proposed changes don’t address
use of the terms “sustainable,”
“natural,” and “organic.” Just
for the record, the word
sustainable might as well fall
into the FTC’s “general
environmental benefit” category.
It is too general, and therefore
difficult to substantiate.
Natural, is most often used in
environmental marketing to
describe the use of biobased
content in the construction of
the product. However, no federal
agency currently defines natural
as it applies to most products
(other than food, where USDA
does step in). Worden
Associates, Inc. has recommended
that industries consider moving
toward the use of “natural/biobased”
to promote greater understanding
of what is meant when using this
word in marketing. The USDA does
define biobased material and
there is an ASTM test that can
be used to substantiate claims
of biobased content in a
product. Organic is defined by
USDA as it is applied to
crops…and the yield from those
crops can be certified under the
National Organic Program.
However, once those crops are
turned into a finished products,
for instance, cotton into a
t-shirt or blanket, the USDA
certification does not apply.
Our understanding is that the
Global Organic Textile Standard
(GOTS) is the leading
international certification for
finished products. Many believe
the USDA will be broadening its
reach in this area. We welcome
and encourage knowledgeable
commenters to let us know what
you know in this area.
Certifications and Seals of
Approval - This is a new
section in the Guides. It notes
that these certs/seals are
covered by the FTC’s Endorsement
Guides. It provides more
examples and makes clear to
marketers that they should
substantiate use of the Seals by
clearly and prominently
qualifying the attribute(s) that
are addressed by the Seals. It
also makes clear that
third-party certification does
not remove the marketer’s
obligation to substantiate
claims.
Degradable – is clarified
as must completely degrade
within one year. It also
specifies that marketers cannot
make degradable claims if the
product is destined for
landfills, incinerators, or
recycling facilities because the
product won’t degrade within one
year. It will be interesting to
see how marketers respond to
this change.
Recyclable – the proposed
changes would force marketers to
determine if their product falls
into one of three categories and
make appropriate qualifications
(i.e., “may not be recyclable in
your area” or “is only
recyclable in a few
communities”). On the latter, if
less than a “significant
percentage” of consumers have
access to recycling programs,
you are supposed to note this.
This is a very specific change
and may nullify any benefit
marketers previously had when
using this term.
Made with Renewable Materials
– the FTC wants marketers now to
be specific about what is
renewable, how it is sourced,
why it is renewable. They should
also note what specifically is
renewable and not apply the term
generally when there are also
non-renewables in the product.
One example of substantiation
provided by FTC is: “Our
packaging is made from 50%
plantbased renewable materials.
Because we turn fast-growing
plants into bio-plastics, only
half of our product is made from
petroleum-based materials.”
Made with Renewable Energy
– must now be specific about the
kind of renewable energy used.
Also, marketers cannot make this
general claim if any part of the
product is made with fossil
fuels. It must be “virtually
all” made with renewable energy
or conventional energy offsets
using RECs.
All in all, the changes were not
sweeping. I can’t quite say that
it’s “much ado about nothing.”
There are important messages
made clear by the FTC’s proposed
changes and all marketers should
review the proposed changes as
you plan your upcoming marketing
campaigns. To review a detailed
summary, visit the FTC’s website
at
www.ftc.gov/opa/2010/10/greenguide.shtm.
We at the SSA look forward to
hearing your
comments. |
