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Full Disclosure :: Zuii Organic Cosmetics USDA Organic Certification Criteria & Status

As we hope you know by now, we like to keep it real around here.  So what happens when something we have touted as truth is not exactly?  Well, we're going to tell you about it because it's the right thing to do and ethical behavior means open and honest communication, things we're big fans of. 

I first learned of Zuii Organic in June 2010.  It was the very first USDA Certified Organic makeup line that I had ever heard of.  And I know that is not an easy feat - create a cosmetic that is USDA Certified Organic because the great majority of makeup is made up of mineral pigments that are not approved for use in USDA Certified Organic products.  But Zuii Organic had a unique angle and it was that they were "the only 100% Certified Organic cosmetic range produced from flowers" according to their website.  I was hesitant when I read that statement because honestly it seemed to good to be true, but I withheld judgement because if it was true then it was quite impressive that they had done something that no other brand had done before.  There was some suspicion lingering in the back of my mind, mostly due to some of the language on their website about the floral content versus the actual floral content I saw in the ingredients decks. As I normally do when I have questions for a brand, I emailed them - almost one year ago now. I didn't hear back from Zuii so I didn't pursue them further.

It wasn't until a few month later, last Fall when Bella Floria contacted me, raved about the products and wanted to send Zuii's products for me to try out, that I decided to because I could find nothing in the ingredients that were reason for concern.  And I trust Emelyn, the owner of Bella Floria, and I believe she acts with integrity, is one smart cookie and knows her stuff; she is afterall a practicing attorney and I have always found her to be honest and ethical in my dealings with her.  When I received the products I thought it was a little odd the USDA Certified Organic seal wasn't on the product boxes or containers or that the copy of their USDA Organic Certification by the Organic Food Chain looked to me like it was for their facility, not necessarily for the individual products - because those are two different things.  Not entirely knowing how the Australian organic certification body (the 3rd party USDA organic certifier) did things, I pushed those nagging questions aside and thought I was perhaps being too much of a conspiracy theorist.  Upon putting the products to the test, I was an immediate fan of their performance and wrote about the blush and eye shadows in a rave review {that can be found here} and they were even named in our Natural Beauty Awards in the Best Blush and Eyeshadow categories.

Fast forward to a couple days after Valentines Day this year when I read a blog post by an owner of a USDA Certified Organic skin+body care company that called out other brands for misusing the word "organic" and/or using the USDA Certified Organic seal in error and/or without merit.  Though Zuii Organic was not specifically mentioned anywhere in the post and I really don't think most people would have known it referred to them, I instantly recognized the image from their website because I had just scoured their site months earlier.  The article asserted that Zuii Organic makeup couldn't be USDA Certified Organic because not all the ingredients they use in their products are approved for use in USDA Certified Organic personal care products according to the USDA National Approved Ingredient List {which can be found be clicking here}. 

In that moment I knew I shouldn't have dismissed my doubts months earlier.  And so began my personal investigation.  I wrote to Zuii's PR person, I contacted the author of the blog post, I reached out to Emelyn at Bella Floria and began to read pages and pages of the USDA Certified Organic Personal Care products requirements, process and allowed and not allowed ingredient lists.  I emailed the owner of another organic personal care brand who I respect and who has been through the USDA Organic Certification process many times and knows the rules and process inside and out.  She graciously contacted their third party certifier for me, QAI, and asked them to confirm if certain ingredients I was questioning were or were not allowed in a USDA Certified Organic personal care product or not.  I did not inform QAI of the brand in question, nor did the brand I asked for help.  I contacted Australia's Organic Food Chain to ask questions about their certification standards because it was still unclear to me if all USDA third party organic certifiers are required to abide by the exact same rules and regulations.  I received two bizarre email replies from Organic Food Chain that answered questions I didn't ask before they ceased communication with me. I didn't find out until afterward that the USDA National Organic Program Compliance & Enforcement Division already had an active complaint for Zuii, so I'm sure that's why the emails ceased.  After that, a couple people told me that they saw Zuii's booth at Expo West at the beginning of March and were also suspicion of the USDA Certified Organic claims after looking at their ingredients but didn't feel the trade show was the appropriate time or place to question them about it. 

At this point, I was leaning towards the assumption that one of two things had happened:

1). The USDA Organic Certification seal was being used without having earned or qualified for it. 


2). Organic Food Chain had certified them in error.

The first option was more believable to me than the second since I had seen that happen several times before, even as recently as a few months ago when a hair care brand was using the USDA organic seal on their bottles without actually being certified and when I asked them about it they told me they didn't understand the USDA's labeling requirements so they would be re-printing all their labels without the seal.  Needless to say, I wanted to get to the bottom of things and know the truth for my own peace of mind.  It was clear Zuii Organic products contained at least eight ingredients that weren't on the National Approved List for USDA Certified Organic products: mica, titanium dioxide, iron oxide, stearic acid, cetearyl alcohol, sorbitan olivate, panthenol D and manganese violet. 

I contacted Emelyn at Bella Floria and told her I needed help sorting through my questions, doubts and needed to know more about all of it to either put my mind at ease or retract the potentially false statements in my Zuii Organic review, since my post touted not only the claim that Zuii Organic was USDA Certified Organic, but the very first cosmetic brand to achieve USDA Organic certification.  Emelyn has kept an open and honest line of communication with me throughout this entire process and initially received confirmation from the USDA that Zuii was indeed legitimitely certified organic, but after their investigation concluded recently she was sent a 365+ page report from the USDA a few weeks ago with the findings of their investigation of this issue.  The very short version is that the USDA's investigation unveiled that Zuii Organic products were indeed USDA Certified Organic by Organic Food Chain, but done so in error as they don't meet the qualifications to be USDA certified organic.  Per the USDA report:

“the products produced by Zuii Organic were erroneously certified as ‘organic’ by TOFC (The Organic Food Chain) because the products contain prohibited ingredients and do not contain enough organic ingredients to qualify for the ‘organic’ designation, which requires the products to contain 95% or more organic ingredients by weight.”

Zuii Organic has since removed all instances of the USDA Organic Certification seal and USDA organic certification claims from their U.S. website (it is still all over their Korean website as of today) and removed the link to their USDA Organic certificate which used to reside on their About page, though it can still be found here as of today. Bella Floria has also removed all claims and verbiage of USDA Certified Organic from their Zuii Organic products pages and wrote a statement about the ordeal on their blog last week

This raises a lot of questions and doubt for me such as:  If certification agencies are allowing the USDA Certified Organic logo to be placed on products that don't meet the USDA Certified Organic criteria, how can I trust this logo?  What other ingredients are being allowed that we don't think are?  What else is slipping through the cracks? How can a third party certifier, whose job it is to ensure standards are upheld through very specific processes and paperwork, not catch this before they allow the USDA Certified Organic seal to be put on a product, when any person can find this information out?  How could Zuii Organic not know what was or was not allowed to be in a USDA Certified Organic product if they applied for the certification?  Does the USDA National Organic Program not have processes in place to check the work of 3rd party certifiers before they allow their USDA Certified Organic seal to be placed on products and claimed?  So many questions... 

As I wrote before, my personal opinion is that a product doesn't need to have the {USDA} seal to be the real {organic} deal; but when it does have the seal it should absolutely mean the ingredient criteria and all qualification standards have been checked, double-checked and triple-checked by not only the brand making the product but by the 3rd party certifier, and by the USDA National Organic Program itself.  While I'm not sure how or why, the rules fell through the cracks in this instance, and while this probably {hopefully} isn't the norm, it sure is worrisome for consumers because we believe that seal adheres to a high standard and a rigorous qualification process, and in this situation, it does not appear as if that occured.

Again, let it be very clear that I am not questioning the safety of the ingredients of Zuii's products - I don't have issue with them and I liked two out of four products that I have used of theirs.  What I have issue with is: a certification seal is a visual assurance that a specific standard has been upheld and when a product with the seal doesn't meet the standards the public thinks it does, that greatly compromises the intregrity of the seal and compromises consumer trust.

One of the most disappointing things in this situation is the manner in which I was communicated with by Zuii Organic.  The first time I ever heard from Zuii Organic was on February 17, 2011, ten hours after I emailed Bella Floria expressing my concern and suspicions regarding their USDA Certification due to the ingredient discrepancy.  I understand mistakes happen and not everyone or organization is perfect, but had they reacted to this ordeal differently, I might have a different perception than I do now.  The email I received from Zuii's CEO, (Per Stuart's email to me on 8/18/11, he is no longer the CEO of Zuii Organic) Stuart Harris, who also works for TFM {Masquerade} Cosmetics in Australia, indicated that they have taken 6 years in research and development to have the full range certified by the USDA and by questioning their certification is to suggest the USDA lacks credibility.  Instead of explaining how they meet the standards despite using ingredients that aren't allowed, he seemed annnoyed I was asking questions, stated he wouldn't be addressing the ingredient discrepancy question and accused me for not doing my research.  He closed by copying and pasting a quote from our (Fig+Sage) About Us page:

"Finally, I note this on your website:  “We do our research.  We make every attempt, to the best of our ability, to find as much out about a product as possible, including, but not limited to tracking down ingredient lists, studying each ingredient in a product to ensure it meets our stringent standards, contacting certification agencies to verify claims, asking hard questions of manufacturers, asking for proof of their claims..” What I would advise is that you spend a little more time reading the USDA standards for certification, or address your concerns with us directly." 


A). At the time I emailed Bella Floria with questions and suspicion, I had already been researching for months and poured over the USDA's standards for certification for hours and hours, reading carefully through pages and pages of complicated and confusing documents and sought advice from others to ensure I was intrepretting it correctly.  When I read that last sentence, I began to wonder if Stuart had ever read the Allowed List of Ingredients as it pertains to the USDA standards for certification. 

B). It was apparent he didn't know I wasn't communicating with them directly because they failed to reply to any of my emails.  Their retailer was my only direct line of communication to them as my previous attempts to contact them were never answered. 

Many months later, questions remain: Why did Organic Food Chain certify Zuii Organic products as USDA Certified Organic if they contained ingredients not allowed in USDA Certified Organic products?  Did they just not know how to intrepret the Allowed Ingredient List or was something else going on?  Even if the USDA is placing most the blame on The Organic Food Chain, how could Zuii not know their products didn't meet the criteria?  I'm not sure I'll ever have these answers.  The important thing is that you know the truth and can make decisions for yourself based on facts. 

I personally don't believe the 8 ingredients not allowed by the USDA National Organic Program for use in a USDA Certified Organic product, that Zuii Organic are using in their products, are "bad" or cause for concern, but what is concerning to me in this instance, is that the USDA Certified Organic seal does not mean what it does on other USDA Certified Organic personal care products and the products don't adhere to the defined USDA certified organic standards or meet the criteria, which leads me to wonder what other personal care products (or food products for that matter) out there are stamped with the USDA Certified Organic seal but don't meet the criteria?  For me, this situation comprises trust and causes me to question a seal that should give me confidence in my purchasing decisions.  The unfortunate part of this all is that it affects other USDA Certified Organic brands that go through the long, tedious and expensive process of becoming USDA Certified Organic because instead of seeing that seal and having total confidence and assurance, I see it and have doubts as to if it's truly legit and know I must still ask questions regarding it's validity.

Click here to read Bella Floria's post about Zuii Organic's USDA Organic Certification status

Update: 8/18/11 7:06 a.m. CST

We received this email from Stuart Harris the day after this post was published, the tone of which is a stark contrast from his previous emails:

"Hello Fig and Sage,

I read your Zuii article with considerable interest.

Would you be kind enough to state in your article that Stuart Harris is no longer the CEO at Zuii?

By the way, I was never annoyed at you. Further, the areas you touch upon in your article were not something I had anything to do with.

Good site by the way. Keep up the good work.

Kind regards,


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