By Dale Read, SSA President
On October 20th 2016 three people informally representing the Specialty Sleep Association (SSA) attended a five hour Roundtable sponsored by the USDA-National Organic Program (NOP) and the Federal Trade Commission (FTC) to Examine Consumer Perceptions of “Organic” claims for Non-Argicultural or Non-Food Products. Angela Owen, Chairman of the SSA and Owner of Suite Sleep, Dale “Sebastian” Luckwitz from SSA and OTA member company Naturepedic and Dale Read, President of the SSA attended the roundtable report on research conducted by the government agencies; and also, a research presentation on consumer perceptions and attitudes conducted by the Organic Trade Association (OTA). The SSA is a member of the Organic Trade Association ( OTA) and attended the “consumer perception” research report session with other members and people associated with the OTA’s “Misleading Organic Claims Task Force” including people representing the Global Organic Textile Standard ( GOTS), Textile Exchange ( OCS-100), Control Union, Oregon Tilth, organic textile clothing manufacturers and several mattress and bedding manufacturers, as well as a number of key OTA staff members who have been advocating for a clear non-food “organic” claims definition at the federal level.
The Organic Trade Association (OTA) participated in the roundtable along with experts from The Environmental Working Group, Consumer Reports, The University of Maryland, Texas State University, the FTC and USDA-NOP. A variety of government researchers, outside academic researchers and consumer advocates weighed-in on research findings and industry information concerning consumer perceptions and expectations regarding non-food products that make “organic” marketing claims. Noting that historically the USDA-NOP regulated “agricultural” crops at the farm or plantation level and processing and marketing of foods, but not non-food categories, the group discussed examples of blatant misuse of what might be expected to be an “organic” product, as well as existing non-government third-party standards for textile retail products such as mattresses and bedding. The meeting also explored “Consumer Misperceptions and Organic Claims in the Marketplace…” as well as “Approaches to Improving Organic Claims…”
The Issue is Far from Resolved but there are Several Observations we can make:
• The SSA is a strong advocate for transparency in marketing claims. The SSA’s BEDFAX® program is not a “green” program, but instead a contents label program advocating a 100% transparency for consumers regarding marketing claims. As a result, we are very interested in consumer education regarding mattress contents, and we are seeking to do away with “green washing” or any possible misleading or erroneous claims regarding mattresses and bedding. As a result of our vision and mission, our commitment embracing transparency and advocating consumer education, having unregulated and unclear non-food “organic” claims in the marketplace is a key concern for the SSA.
• Mattresses and other “fiber or textile” based mattress, bedding and textile products are not the same as personal care products ( shampoos, deodorants, cosmetics, creams, lotions) or dry cleaning services. There is a very clear and well-established third-party international standard for both textile components and finished products in the form of the Global Organic Textile Standard (GOTS). More on this in a second. Because there already exists a widely recognized credible international standard for mattresses and bedding, we would strongly suggest that non-food organic rules and regulations for mattresses and bedding not be lumped in with personal care products, dry cleaning or other products not covered by such legitimate standards as GOTS and the Global Organic Latex Standard ( GOLS). Due to the unique situation that already exists, mattresses and bedding should be treated separately from personal care products and other non-textile related products.
• While not the only standard dealing for “organic” textiles and textile related products such as mattresses and bedding , (there is also Textile Exchange’s (TE) OCS-100 for textile components tracking) and the Global OrganicLatex Standard (GOLS) for latex mattresses and pillows; the Global Organic Standard ( GOTS) is indeed the most widely recognized and, long standing international standard for finished “organic” mattresses and bedding. GOTS certifications for finished organic mattresses and bedding are achieved only after a rigorous inspection by credible professional national and international certifying agencies such as Control Union and Oregon Tilth. GOTS also allows companies to market “ Made with Organic” claims based on a 70%-plus organic content, and it allows for certified components, which can be marketed correctly.
• Environmentally and socially responsible and conscious manufacturers can also make a variety of “sustainable” or healthier and safer claims with such certifications as Rain Forest Alliance, GreenGuard, Oeko-Tex 100 if they choose a transparent marketing claims program that does not entail an “organic” claim. However some consumers DO specifically look for “organic” mattresses, pillows, sheets, toppers; and for those consumers, the GOTS program is a well-established, third-party certified program recognized worldwide. It does entail specific set-asides and 70% or 95% bio-based, naturally organic materials requirements. These specifications and standards have been studied for years and resolved on a worldwide basis. While not a “pure” organic standard from some consumers’ perceived viewpoints, it is clearly a widely accepted and worldwide standard that allows for healthier, safer products that are harmful chemical and GMO-free product for the consumer.
This issue is far from resolved at this point with the USDA-NOP and the FTC. The industry has until December 1st. to submit comments on the topic of correctly marketing claims for “organic mattresses and bedding.” Not all SSA members who are concerned about this issue see this in the exact same light. We share a common belief in “transparency and consumer education” regardless of which “organic standard” you embrace. We welcome your comments and thoughts on this issue.
SSA Representatives Angela Owen, Dale Read and Sebastian Luckwitz (2nd, 4th and 6th from left respectively)