Monday, March 7, 2016

Is #Cruelty-Free a Marketing Hype?

These days it takes me longer to shop. Gone are the days where I hop to the store, run down the aisles of my favorite shopping items and plop 'em in the cart. If I don't do my research before hand, I spend precious amounts of time perusing labels and Googling terms, ingredients and companies.

With eight children, a household - business to run, and a website to maintain, I don't have the time to validate what businesses are saying about their product. Third-party certifications are a MUST.

Green-washing is a vast, prevalent and profitable venture, and too many consumers are placing their trust and beliefs in for-profit enterprises. It is your right to demand and request proof to claims. Because more product producers are realizing this, we've now entered into a confusing world of certifications.

Adding to the confusion of green-washing are certifying bodies, or rather...those claiming to be certifying bodies.

So let's break it down...

Starting with the basics... What is certification?
Formal procedure by which an accredited or authorized person or agency assesses and verifies (and attests in writing by issuing a certificate) the attributes, characteristics, quality, qualification, or status of individuals or organizations, goods or services, procedures or processes, or events or situations, in accordance with established requirements or standards.(1)
What is an Accredited Body or agency?
An accredited body is a notified body. A third party that is entitled by an Accreditation Body. That Accreditation Body supplies definition and standards and may allow the Notified Body to provide certifications and standards. (3) For example, the USDA provides definitions and standards of what organic means and the notified, third-party, body such as Oregon Tilth, provides certification by verification processes set forth by the USDA.

What is third-party certification?
First, let's talk about what isn't a third-party certification. In a first-party certification, an organization offering goods and services supply assurances that it meets certain claims. In a second-party certification, the association that the organization is a member of, supplies the assurance. Finally, a third party certification is an Accredited Body entitled by an Accreditation Body (like the USDA) supplies this certification after verifying processes and procedures. (3) In other words, unlike the first and second party certification - a third party certification is independent and stands to gain nothing by supplying their assurances, but in respect, stands to lose their reputation and accredited status.

Is the Bunny Leaping?

With these guidelines in mind let's take a closer look at the Leaping Bunny. The Leaping Bunny is an internationally known animal-cruelty free program comprised of eight national animal protection groups banding together in response to companies' first party certifications to cruelty-free claims.
"In response, eight national animal protection groups banded together to form the Coalition for Consumer Information on Cosmetics (CCIC). The CCIC promotes a single comprehensive standard and an internationally recognized Leaping Bunny Logo. We work with companies to help make shopping for animal-friendly products easier and more trustworthy" (2)
To be very clear, Leaping Bunny makes no official statement, that I can find online, that states they are an Accredited body, i.e. third party independent. And making such a statement would be erroneous IF it was made, because there are no laws banning animal-testing, thus, there would be no Accreditation Body with standards.

What we do have, are laws that regulate animal testing as well as "Accreditation from the Association for Assessment and Accreditation of Laboratory Animal Care International, a non-governmental, nonprofit association, is regarded by the industry as the "gold standard" of accreditation." (4)

That said, third party certification is definitely implied.When explaining why the Leaping Bunny logo is important to prospective companies they say...

"...More than 65% of people surveyed indicated they are more trusting of independent third-party seals of approval and logos when it comes to finding accurate cruelty-free claims. Verifiable claims are becoming increasingly necessary as more and more companies self-declare that they are "not tested on animals" and have "cruelty-free" status without the assurances offered by certification with CCIC."
Can an organization be third-party independent and not accredited? To that I say sure...if they can show they don't stand to gain from assurances and verify processes and procedures in a satisfactory manner. For example, Non-GMO Project Verified requires companies that register with them to go through GMO testing by free-standing labs.  While, I wouldn't purchase any probiotic products certified by NGPV, I'm happy to purchase any other products with their label. You can read why here. 

So WHAT assurances does Leaping Bunny supply and where in the line of claim commands do they stand?

The "standard" that they apply to certify companies is, in short, a pledge(5) from the company and their suppliers and the requirement that they be audited upon request.

No up-front auditing.

I don't know about you, but what I would expect for a company to be "cruelty-free", or to use Leaping Bunny's words "free of new animal-testing" is a requirement for auditing prior to being certified. That's just commonsense. I strongly suspect if that requirement was enacted, they would have a very SMALL program.

The truth is if you're not using products with food-grade, organic, agricultural ingredients, the likelihood is HIGH that animal-testing is involved. As a matter of fact, Leaping Bunny states on their Standards page that "Companies are not required to obtain Declarations of Raw Material Compliance from suppliers of Natural Agricultural Ingredients."(5)

First, Second or Third?
Leaping Bunny is certainly not a first-party certification. They aren't selling goods and services and making claims about that. In order to be third-party certification, they have to be, at the very least...independent. From what I've read on their site, they are far from independent. On their "Marketing Opportunities" (6) page, they partner with some Leaping Bunny certified companies who donate a proceed of sales to Leaping Bunny. (7)

That would make them a Second-Party Certification. One with a vested interest in offering assurances, or should I say offering us pledges. When a company and it's suppliers makes their pledges, they pay a "nominal" licensing fee for the logo and have access to a list of marketing opportunities such as:(8)
  • Compassionate Shopping Guide List
  • Smart Phone App
  • Social Media Promotion
  • E-Newsletter Promotion
  • Website Promotion
  • Product Reviews
  • Sampling
  • Partnership (with Leaping Bunny)
  • Online Retailers
Considering this is Internationally known, Leaping Bunny, offers a huge marketing opportunity.

In my opinion, a second-party certification is just as good as a first-party claim. Which isn't saying much.

Finally, it is very important to understand that there are no legal definitions to the terms "Cruelty-free" or "Not tested on animals". It very well could mean that certain chemicals were tested on animals at some point in the past, but is "currently" not tested. In other words, the company/supplier already have their results on whether a chemical is "safe" for human use.(10)

Why Miessence Refused the Hype

"The simple answer is because we believe it is misleading.
Certified organic means that only ingredients allowed in organic foods are allowed in the product. These are the only ingredients we use in our products, and they most certainly do not require, nor are subjected to, animal testing. The ingredients in our products are, literally, good enough to eat.

Remember, most of our ingredients are food-based ingredients, so animal testing is not something we need to do or ever will do. We have chosen not to carry this symbol as we do not use any cosmetic ingredients that have been tested on animals in the past or will ever be tested on animals in the future." (9)
Can You Avoid Products Tested on Animals? 
You can!

  • Avoid using products with chemicals, that would be a good first step. Its not good for humans either! 
  • Avoid synthetic ingredients such as artificial flavors, scents, fragrance etc. 
  • Look for cosmetics with food-grade ingredients like Miessence. I'm happy to consult on our 75 plus products with independent organic certifications range from food to cosmetic standards
  • Use cosmetics with ingredients that employ a green chemistry process. If you want to learn more about green chemistry - contact me - this article getting too long!
  • Avoid GMOs! They have certainly been tested on animals.
  • Look for a Certified Organic seal. Certified organic foods and cosmetics cannot use pesticides or herbicides - both chemicals. 

Disclaimer and Disclosure Policy


 Sources:

1 - http://www.businessdictionary.com/definition/certification.html#ixzz41m5TOzQO
2 - http://www.leapingbunny.org/about/us
3 - https://en.wikipedia.org/wiki/Certification
4 - https://en.wikipedia.org/wiki/Animal_testing_regulations
5 - http://www.leapingbunny.org/about/the-standard
6 - http://www.leapingbunny.org/content/marketing-opportunities
7 - http://leapingbunny.org/shop/partners
8 - http://www.leapingbunny.org/about/faq#answer-8
9 - http://news.miessence.com/201603/education.html
10 - http://www.fda.gov/Cosmetics/Labeling/Claims/ucm2005202.htm




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