NCS standard

The goal of the standard is to replace petrochemical-based, genetically modified, and environmentally harmful products with less environmentally harmful alternatives. Dies setzte voraus, dass Verbraucher solche Produkte erkennen.

Another aim 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 greatest 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 the raw materials specified in the NCS standard and their manufacturing processes are used to produce NCS-certified products. The appendix contains an open list of compliant INCI names (Appendix 1) and a positive list of nature-identical substances (Appendix 2). Appendix 1 is intended to serve as a guide for product design. Er wird laufend durch neu zugelassene INCI erweitert.

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.

³ The substances are not produced from, by, or with the aid of genetically modified organisms. Proof consists of a declaration of non-GMO status from the manufacturer and, in case of doubt, a PCR analysis (the threshold for accidental, technically unavoidable contamination 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 that are separately identified in Annex 1 are granted a tolerance period until the end of 2023. A query for the declaration of freedom is provided by the standard setter.

Natural [1]: In accordance with ISO 16128, “natural” refers to ingredients and processes used in this product that
– are not of fossil origin (e.g., not derived from petroleum or coal),
– are derived from plant, animal, microbial, or mineral raw materials,
– and which have only been processed physically, enzymatically, or microbiologically without significantly altering their natural identity.

Substances that have been synthesized through fundamental chemical modification, as well as those whose origin or structure can no longer be clearly traced back to a natural source, are not considered natural. Please note the classification of raw materials into substance groups in this standard.

Derived natural: In this standard, “derived natural” refers to substances that originate from natural sources and whose chemical structure and composition have been altered exclusively by processes that also occur in nature without human intervention.

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 to sort 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: Other material composition 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: In this standard, “synthetic” refers to substances that are not of natural origin and are produced using chemical processes, which would not occur in nature without human intervention, and/or are 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.

[1] Hinweis zur Verwendung des Begriffs „natürlich“:
In diesem Standard beschreibt „natürlich“ die Herkunft eines Stoffes, nicht seine Wirkung. Natürlich vorkommende Stoffe können umwelt- oder gesundheitsschädlich sein. Die Bewertung ihrer Unbedenklichkeit erfolgt daher nicht allein aufgrund ihrer Natürlichkeit, sondern im Rahmen gesonderter Kriterien.

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

• Natural substances: natural raw materials, chemically unmodified raw materials of plant, inorganic mineral, or animal origin, as well as mixtures and reaction products thereof

• 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 these preservatives are used, the label must include the statement: “preserved with … [name of preservative]”.

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

4.4 Auxiliary and extraction agents

The following are approved as extraction agents for natural substances: water, vegetable alcohol, carbon dioxide, vegetable fats and oils, glycerin of vegetable origin. Furthermore, enzymatic and microbiological processes that also occur in nature may be used. Nicht richtlinienkonforme Extraktionsmittel sind nur dann erlaubt, wenn ein alternativer Extrakt nicht zur Verfügung steht und das Extraktionsmittel anschließend bis zu den Nachweisgrenzen der in § 5e KVO aufgeführten Analysemethoden reduziert wurde.

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 Regulation are not permitted in NCS-certified products. This does not apply to substances that are encapsulated. This does not apply to substances that are encapsulated.

This applies to all formulations and products submitted for certification after August 1, 2020. For products registered before August 1, 2020, a transition period applies until December 31, 2023, to adapt the formulation to coated or non-nano raw materials.

Based on the current state of scientific knowledge, it is not possible to draw any clear conclusions regarding the risks or safety 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 the end products with ionizing radiation is not permitted.

Natural products and environmentally harmful packaging don’t go together. This is especially true when the packaging gives the impression of being eco-friendly, even though it hinders the recycling process or isn’t recyclable at all. The standard sets criteria to counter such greenwashing packaging.

The current GfaW packaging criteria apply to NCS-certified products. These criteria, including a list of approved packaging materials, are available in a separate document on the GfaW website ( https://gfaw.eu/downloads) available.

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).

Der Impact ist immer über die gesamte Wertschöpfungskette hinweg zu ermitteln (Rohstoffherstellung, Verarbeitung, Logistik, Nutzung, End of life, Aufbereitung und neuer Rohstoffeinsatz).

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 weight proportion, 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

• The weight of concentrates 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 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

To ensure the quality of the GfaW standards, the certification body prepares an annual report on nonconformities. This report is confidential and serves as a basis for the GfaW to identify topics for working group meetings, determine advisory needs, and evaluate the scope of impact.

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