NCS standard

The aim of the standard is to replace petrochemical-based, genetically modified and environmentally harmful products with less environmentally harmful products. This requires consumers to recognize such products.

Another goal is to promote recyclable packaging in order to contribute to the circular economy.

In order to achieve these goals, NCS offers a means of differentiation at the point of sale with its catalog of criteria for ingredients and packaging as well as the NCS seal of approval for products.

Every product that is NCS certified contributes to realizing the transformation to a petrochemical-free and circular economy.

In detail, this means

The lowest possible environmental impact:

• Strict criteria for petrochemicals
• Only chemical processes permitted that also occur in metabolic processes in nature

As few products from genetic engineering processes as possible:

• Strict criteria for ingredients involving genetic engineering

Promotion of organic farming:

• Recommendation to use as many organically grown raw materials as possible

• Obligation for organic quality for defined oils

The closest possible proximity to nature:

• If raw materials are obtained by means of chemical processes, these must correspond to the metabolic processes in plants/nature. They are listed in the standard.

Circular economy:

• Criteria for the design of packaging in order of priority
• Criteria for the permitted materials in accordance with the requirement to achieve the highest possible recyclability.

The NCS refers to all cosmetic products intended for humans and animals. Cosmetic products are defined in this context as substances or mixtures that come into contact with parts of the human or animal body, teeth or mucous membranes of the oral cavity for the sole purpose of cleaning, perfuming, changing their appearance, protecting them, keeping them in good condition or influencing body odor.

If, in addition to a natural cosmetics range, other cosmetic products that do not comply with the Directive are also sold, the natural cosmetics range must be clearly distinguished from the non-Directive-compliant ranges by appropriate presentation or designation. Products from the natural cosmetics range can only be registered if at least 60% of the products in the natural cosmetics range comply with the directive. This means that the necessary test documents must be provided for the natural cosmetics range, regardless of the number of products registered from the natural cosmetics range.

If several standards are used within a brand, at least 60% of the products must be registered for the NCS and bear the NCS label.

Only only the raw materials named in the NCS standard and their manufacturing processes are used to produce NCS-certified products. The appendix contains an open list of compliant INCIs (Appendix 1) and a positive list of nature-identical substances (Appendix 2). Annex 1 serves as a guide for product design. It is constantly being expanded with newly approved INCIs.

The required properties of the approved raw materials are described in this standard.

Surfactants must be more than 60% biodegradable within 28 days according to OECD Test 310 (EN ISO 14593) and 311 (EN ISO 11734).

Animal testing is not permitted in connection with the production and distribution of NCS-certified products. With regard to GMO freedom, the requirements of the EC Organic Regulation (Regulation (EC) No. 2018/848) apply to the end product and the raw materials used. This requirement also applies to ingredients that would not be covered by the Eco-Regulation, such as substances from the non-food sector and non-organically certified materials.

The substances are not produced from, by or with the aid of genetically modified organisms. Proof is a GMO-free declaration from the manufacturer and, in case of doubt, a PCR analysis (the threshold value for an adventitious, technically unavoidable admixture is 0.9. Selected raw materials that cannot be produced without enzymes from genetically modified organisms according to the current state of the art and which are marked separately in Annex 1 are given a tolerance period until the end of 2023. A query on the declaration of freedom is provided by the standard setter.

NIR: Near infrared. NIR (near-infrared) refers to a spectrum in a range between 760 and 2,500 nm that is not visible to humans. In this wavelength range, typical material patterns based on molecular vibrations can be detected after excitation with light. This technology is used for sorting packaging.

Recyclability: Recyclability is the individual gradual suitability of packaging or a product to actually replace material-identical virgin material in the post-use phase; “actually” here means that collection and recycling structures on an industrial scale are a prerequisite.

Recycling share: Proportion of recycled raw materials in relation to all raw materials.

Foreign materials: Material composition other than the basic packaging – e.g. for sleeves or labels

Impurities: Substances that disrupt or prevent the recycling process according to the current state of the art.

Synthetic: This standard defines “synthetic” as anything resulting from a chemical process that would not occur in nature and/or is of petrochemical origin.

Composite packagingPackaging consisting of different types of material that cannot be separated manually, none of which exceeds 95% by mass of the total packaging.

The ingredients of cosmetics according to the NCS are divided into the following substance groups:

• Natural substanceschemically unmodified raw materials of plant, inorganic-mineral or animal origin as well as their mixtures and reaction products with each other.

• semi-natural raw materialsRaw materials obtained from a natural substance as defined above by authorized chemical reactions.

• nature-identical inorganic pigments and mineralsSubstances whose chemical composition is identical to naturally occurring pigments and minerals. (See appendix 2)

• nature-identical preservativesSubstances whose chemical composition is identical to naturally occurring substances and are used as preservatives. (see appendix 2)

• Auxiliary and extraction agents

• Aerosols: Propellant gases

The following raw materials and processes may be used to manufacture NCS-certified products:

4.1 Natural substances

Only physical processes using the extraction and auxiliary agents listed under point 3.4 may be used for the extraction of natural substances.

Where available, all natural materials are preferably sourced from certified organic raw materials.

In addition, enzymatic and microbiological processes are permitted, provided that only naturally occurring enzymes or microorganisms are used.

Animal and vegetable raw materials must not be on the IUNC list of endangered species, unless they come only from live animals from species-appropriate husbandry or from species-appropriate organic farming.

The standard setter recommends a supplier query of relevant points, also with regard to sustainability and the origin of the raw materials.

4.1.1 Natural plant substances

The following plant-based raw materials come from certified organic sources:

Sunflower oil, olive oil, soybean oil, coconut oil, jojoba oil.

Shea butter comes either from organic raw materials or from wild collection.

The following natural substances originate at least from RSPO cultivation:

Palm oil and palm kernel oil

Raw materials whose cultivation is critical in terms of sustainability, such as palm oil, are only tolerated with a verifiable weighing up of priorities.

The use of all chemically unmodified natural plant substances (essential oils, fatty oils, extracts, etc.) is generally permitted, provided they have been obtained in accordance with the principles of the standard (see also point 3.4 Extraction and auxiliary agents). The KVO must be observed, in particular the protection of health, so that it is the responsibility of each manufacturer to use only harmless raw materials.

Raw materials obtained by fermentation or biotechnological processes that occur exclusively in nature are not listed in the annexes. If the raw material corresponds to an agricultural product, it is included in the organic calculation.

4.1.2 Animal natural products

Natural substances derived from living animals, such as milk or honey, may be used in NCS-certified products. In contrast, natural substances from dead vertebrates are not permitted (e.g. collagen, fresh cells, etc.).

4.1.3 Natural mineral substances

Natural mineral substances are generally permitted, provided they are obtained by physical methods and have not been chemically modified. Mineral salts such as magnesium sulphate or sodium chloride may be used in NCS-certified products. Exceptions to this are regulated under point 5 “Non-permitted substances”.

4.1.4 Fragrances

Fragrances that comply with ISO standard 9235 are approved for use in NCS-certified products. Biotechnologically derived fragrances can also be used.

Fragrances are not listed in the annexes and do not have to be registered. The manufacturer’s confirmation of ISO 9235 conformity is sufficient.

4.1.5 Water

Water is only classified as a natural substance if it comes directly from plant sources. In this case, it can be labeled as such if the organic quality of the source material is proven.

4.2 Near-natural raw materials

Natural raw materials may be obtained from natural substances according to the above definition by the following chemical reactions: Hydrolysis (including saponification), neutralization, condensation with elimination of water, esterification, transesterification, hydrogenation, hydrogenolysis, dehydrogenation, glycosylation, phosphorylation, sulphation, acylation, amidation, dimerization, oxidation (with oxygen, ozone or peroxides) and pyrolysis.

The use of organohalogen compounds for the extraction of near-natural raw materials is not permitted.

4.3 Nature-identical raw materials

In NCS-certified products, the nature-identical pigments, minerals, preservatives and vitamins listed in the positive list (Annex 2) may also be used.

4.3.1 Nature-identical preservatives

For the purpose of product safety, the following nature-identical preservatives may be used in NCS-certified products where necessary:

• Benzoic acid, and its salts and ethyl ester
• Salicylic acid and its salts
• Sorbic acid and its salts
• Benzyl alcohol
• Formic acid and its sodium salt
• Dehydroacetic acid and its salts*
• Propionic acid and its salts*

When using these preservatives, the addition: “preserved with … [Name des Konservierungsstoffes]” on the label is required.

* As far as authorized by Directive 76/768/EEC, except ethanolamine salts

4.4 Auxiliary and extraction agents

The following are permitted as extraction agents for natural substances: Water, vegetable alcohol, carbonic acid, vegetable fats and oils, glycerine of vegetable origin. Furthermore, enzymatic and microbiological processes that also occur in nature may be used. Extraction agents that do not conform to the guidelines are only permitted if an alternative extract is not available and the extraction agent has subsequently been reduced to the detection limits of the analytical methods listed in Section 5e KVO.

Pre-preservation and technical additives must comply with the Directive insofar as they remain in the end product (see point 3.3 Nature-identical preservatives). The only exceptions are those additives that are used and removed as far as possible in accordance with the state of the art.

All raw materials and additives contained in the product, in particular pre-preservatives and solvents, must be reported with INCI names regardless of whether they legally constitute “ingredients” according to Section 1 KVO. Sentence 2 §1 KVO does not apply to the notification of the formulation composition.

4.5 Aerosols

The propellant gases are components of the cosmetic product. The following propellant gases are permitted in NCS-certified products: CO 2, nitrogen, compressed air.

Substances from the following substance groups may not be used for NCS-certified products:

• EDTA complexing agent,
• Glutaraldehyde,
• Formaldehyde,
• Formaldehyde splitter,
• Organohalogen compounds,
• Synthetic fats, oils, waxes or silicones,
• Aromatic amines, ethanolamines and derivatives,
• Synthetic fragrances,
• ethoxylated auxiliary and raw materials,
• Musk compounds,
• Phthalates,
• PEG and PEG derivatives,
• Solid, insoluble polymers, especially if they are smaller than 5 mm.

Ingredients that must be labeled as “nanomaterials” according to the Cosmetics Ordinance are not permitted in NCS-certified products. Excluded from this are substances that are coated. The coating material must comply with this standard.

This applies to all formulations and products registered for certification after 01.08.2020. For products registered before 01.08.2020, there is a transitional period until 31.12.2023 to adapt the formulation to coated or non-nano raw materials.

The current state of scientific knowledge does not allow any clear conclusions to be drawn about the risk or harmlessness of nanomaterials. (see https://www.umweltbundesamt.de/publikationen/nanomaterialien-in-der-umwelt) Studies have so far only been carried out with non-coated particles. The coating prevents oxidation of the particles and thus increases the chance of better tolerability. Until further findings are available, the standard setter considers this criterion to be a compromise.

The treatment of plant and animal raw materials and end products with ionizing radiation is not permitted.

Valid for all from 01.01.2024 to be purchased packaging:

Natural products in environmentally harmful packaging do not go together. Especially not if the packaging gives a green impression, even though it interferes with the recycling process or is even non-recyclable. The standard sets its criteria against such greenwashing packaging:

These packaging criteria apply to products that are marketed under the company’s own brand or produced in-house for end consumers. Packaging for B2B transport or sales is not covered here.

In principle, care should be taken when using packaging materials and packaging materials to ensure that the packaging task can be fulfilled with the lowest possible overall impact (economic, social, ecological).

The impact must always be determined across the entire value chain (raw material production, processing, logistics, use, end of life, reprocessing and new raw material use).

Packaging is used in the following order of priority:

1. Priority Avoid: As little as possible. The key question is: Is packaging indispensable?
2. Priority DecreaseThe packaging that is required should use as little material as possible. The key question is: Can the packaging material be reduced, e.g. through refill options?
3. Reuse priorityPrefer reusable to disposable packaging. This means that before designing disposable packaging made from recyclate, it is necessary to clarify whether a reusable system, regardless of its form, would be possible. The key question is: Is there a reusable system for the planned packaging?
4. Priority recyclabilityRecyclability of packaging and packaging materials, which is required by the EU and in Germany. This is not about the theoretical recyclability of materials, but about the recyclability of a complete packaging material (including closure and labels) in the existing recyclable material streams. The key question is: Is the packaging actually recyclable at present? Can the consumer simply allocate it to the appropriate recycling streams? (I.e. the packaging / packaging materials should be marked in such a way that the consumer can assign them to the correct material flow. It must also be possible to automatically identify and sort packaging and packaging materials (NIR technology for sorting recyclable materials). In addition, they must be recyclable in the existing material streams and be able to be converted back into raw materials / packaging materials to an economic degree).
5. Emptying priorityResidual emptying of the packaging. In order not to disrupt the sorting and recycling process, the packaging must be easy to empty. The key question is: can the packaging be completely emptied?

The materials listed in the appendix, which are green may be used.

All materials marked in orange and red are contaminants for the recycling process.

The orangen marked materials are tolerated, but are currently not recommended by the standard setter.

The red marked materials must not be used.

As the technical possibilities of the recycling industry are subject to immense change, the criteria and the list of materials are reviewed by the standard setter every two years to ensure that they are up to date and adjusted if necessary.

In addition, the following minimum requirements apply to the materials:

Ban on PFAS.

The packaging used is free of perfluoroalkyl and polyfluoroalkyl substances. If PFAS are found in the current packaging, the company will present an action plan to replace the packaging with PFAS-free packaging by 2027.

Paper packaging:
Fully recycled paper materials are preferable to virgin paper.

The recycled content of paper packaging is at least 50%. (Exceptions are granted in the food sector for specific legal requirements for packaging).

Raw paper materials come from either FSC or PEFC sources.

The paper must not be bleached with chlorine or chlorine derivatives. Only TCF is permitted.

In particular, wet strength agents, grease sealants and PFC-based finishes are not permitted. Coatings and laminations should should not be used on paper materials.

Wood-based packaging:

The wood comes from FSC or PEFC sources. The packaging must be designed in such a way that different materials can be separated.

Plastic packaging:

No multilayer structures, except PE/PP-EVOH. If multilayer structures made of PE-EVOH and/or PP-EVOH are used, the company must submit a plan of action for adapting the packaging to recyclable material by 2027. This does not apply to food products.

Requirements for the proportion of recyclate in plastic packaging in relation to the product type:

*The possibility of using PE and/or PP with recycled content for foodstuffs will be adapted to market conditions by the standard setter. Currently (as of the end of 2023), no food conformity can be achieved with rPE and rPP.

** Unless an in-house recycling plant has been set up and the return rate is not 90% and the material to be purchased is contaminated with synthetic fragrances or genotoxic substances. . In this case, the company submits an action plan on how it can gradually reduce the use of petrochemical-based virgin material by 2027.

*** Does not apply to parts of the packaging that come into contact with the product if food conformity is required. Intelligent packaging solutions, e.g. with several layers that can be separated by consumers, are expressly desired.

No different plastics on the front and back. Recyclable printing inks (minimum standard EuPIA-compliant printing inks). When using labels or sleeves made of foreign material, they are smaller than 50% of the packaging surface (see minimum standard for impurities NIR).

No PETG sleeves or components for PET bottles.

No cellulose-based labels permanently attached to polyolefin packaging except for overlaminating standard labels or to save repackaging.

No silicone components.

Adhesives:
Only REACH compliant adhesives may be used.

Glass packaging:

No permanently adhesive (not water-soluble/hydrophobic) large-surface plastic labels.

Explanation of the criteria and recommendations for action

Section 21 of the Packaging Act* provides for the implementation of financial incentives for the use of recyclable packaging. No recyclability will result in a payment by the distributor, but the use of at least 90% recyclable packaging will result in a refund.

The standard setter therefore recommends not only adhering to the minimum requirements in this standard, but also following the recommendations, both from a financial and environmental perspective.

Fiber materials in particular are often assumed to be recyclable as a matter of course. However, this can be undermined by the wrong or too thick coating, by hot melts in folding boxes or by coatings and finishes. The PTS-RH 021 97 standard provides information on the recyclability of fibrous materials. The origin of fibrous materials should also be checked, as around half of cellulose comes from Latin America and from eucalyptus monocultures. To avoid supporting this trend, it is important not only to see the certificate number of the producing company in the FSC supply chain tracking, but also to list the numbers of the raw materials used.

The recyclability of composite material, plastic, glass and metal packaging is confirmed by companies such as HTP-cylcos, Interseroh and Clover. The EU is working on establishing a circular economy, so it makes sense to use as much recyclate, used material or cullet as possible in packaging. The use of recyclate, for example in the fiber sector, also ensures that the raw materials come from domestic collections rather than sources from other continents.

*Ӥ Section 21 Ecological design of the participation fees

(1) Schemes are obliged to create incentives within the framework of the assessment of participation fees in order to

the production of packaging subject to system participation

1. to promote the use of materials and combinations of materials that take into account the

practice of sorting and recovery can be recycled to the highest possible percentage, and

2. promote the use of recyclates and renewable raw materials. …” (Packaging Act of 05.07.2017)

The company that manufactures and/or markets NCS-certified products has set up a quality management system (QM system) for traceability and quality controls in accordance with HACCP and cosmetics GMP (ISO 22716). The QM system must be expanded to include environmental protection and sustainability measures in the course of continuous improvement. Orientation towards the Certified Sustainable Economics (CSE) standard is helpful here.

The products may be labeled as “certified natural cosmetics” and bear the NCS seal.

The following further awards are possible:

1. An NCS-certified product may be labeled as “organic cosmetics” if at least 95% of the ingredients of agricultural origin are of organic quality. Organic cosmetics may carry the label with the addition “organic-quality”.
2. An NCS-certified product may be labeled as vegan natural cosmetics if it consists only of ingredients that are not made from, by or with the help of animal substances. Any animal additives such as gelatine filters or animal carriers are not permitted.

The ingredients of all NCS-certified products are shown on the packaging in the INCI list.

In the case of the presence of ingredients with organic quality in the certified products of the “natural cosmetics” level, the following conditions must be complied with:

• Claims relating to the organic quality of the ingredients used are only permitted if they are labeled in such a way that they can be clearly and precisely assigned in the mandatory index of ingredients. The statement “organic quality” refers to the organic source material in accordance with the standard. For example, the reference to organic quality with “*” can be used as a precise indication. The regulation applies both to the wording “organic” and to all synonymously used expressions such as “eco”, “organic” or “controlled organic cultivation”. The language chosen for the claim is irrelevant.
• The proportion of organic ingredients must be stated as a percentage of the proportion of all ingredients in the end product. The percentages are given in whole numbers, fractions are rounded up. A permissible indication of the percentage share is, for example:

“70% organic ingredients in the product, 100% of which are organic”

For reasons of space, this information can be given on the website instead of on the packaging.

• The following should be noted when calculating the percentages: Undiluted ingredients in organic quality are recorded in their full proportion by weight, e.g. plant parts, pressed oils, pressed juices, microorganisms in their solutions and essential oils.
• Ingredients in organic quality are recorded in their full proportion by weight, e.g. plant parts, pressed oils, pressed juices and essential oils.
• Plant extracts in organic quality can be recorded in their full weight proportion if the extraction agent is no longer contained in the end product (e.g. CO2 extraction) or the remaining extraction agent is of organic quality.

The following formula is used:

• X= P/(P+E) x 100

X = organic content in the extract; P = mass of plant material used; E = mass of extraction agent used

• In the case of concentrates, the weight is not determined before concentration. The water that is added back to the concentrate is also not taken into account.

In order to obtain a clear identification of the raw material, every change must be reported to the certification body. This concerns the supplier, the composition of the raw material and, if applicable, its manufacturing process.

The standard setter also recommends a supplier inquiry with regard to sustainability and human rights. The standard setter will provide templates for this on request.

The certification and inspection bodies approved by the GfaW standards work in accordance with ISO 17065 and have many years of experience in certifying natural products. GfaW concludes contracts with the certification bodies for the performance of certifications in accordance with the GfaW standards. These contracts regulate the inspection and certification procedure, the qualifications of the assessors and auditors, the frequency and intensity of the assessment, sampling protocols for the assessment, sources for the evidence to be assessed, minimum content of assessment reports and deadlines for the submission of completed reports following the assessments. GfaW is responsible for monitoring compliance with the contractual agreements.

Certification process

There is a two-stage process for certifying the products:

1. StageTesting of the products including proof of quality requirements according to the standard
2. Stage: Implementation of initial audit GMP basic requirements, packaging and labels
3. Stage: Annual monitoring audits

The certificate issued entitles the holder to use the respective mark, which is awarded by the GfaW Gesellschaft für angewandte Wirtschaftsethik.

Further monitoring of conformity takes place through on-site audits depending on the risk classification.

Deviations and sanctions

If a product in the level 1 and 2 does not meet the standard, it will not receive a certificate. The Level 3 does not take place until all ingredients are compliant. The applicant then has time to change his formulation or replace the non-compliant raw materials.

Are used in level 3 If deviations from the standard are detected, reactions and sanctions take effect, including withdrawal of the certificate and prohibition of use of the label.

Application procedure

To register the products, the company receives a registration file from the certification body or access to digital registration software. Companies registering products for the first time enter company data that is relevant for certification.

Listing of components for product registration

Among other things, a list of all the ingredients contained in the product with the INCI contained is required in the product declaration. This is not(!) only the INCI declaration of the product. All the raw materials contained (if mixtures such as pre-preserved plant extracts are used, extraction agents and pre-preservation must also be listed).

The type and materials of the packaging must also be specified.

The certification body shall be informed immediately and without being asked of any changes relating to conformity with the GfaW standards.

Exchange with the certification body

For quality assurance of the GfaW standards, the certification body prepares a report on non-conformities once a year. This report is subject to confidentiality and serves the GfaW as a basis for topics in working group meetings, determining the need for consultation and evaluating the impact framework.

Certified products are published on the standard setter’s website with the following information:

• Brand
• Product name
• Certification level (NCP or NCP-vegan)
• Certification date and expiry date
• Links to online or stationary shopping opportunities
• Optional: Information on the application
• Optional: Information on sustainability