What's The Real Agenda And Who Benefits From It? Pt 2
OR Who are the Keyser Sözes of The Safe Cosmetics Act of 2010?
"...The EFFECT of this legistlation is not to put you out of business. The PURPOSE of this legislation is to put you out of business."
I was floored by this. I was just stunned. I had not seen it that way. And it made me jam on my brakes to a screeching, treadmarks of burned rubber halt. And I thought about what my BFF said. And I thought some more. I've been thinking about what they said and this frak'd up from the floor, wrong on so many levels piece of potential legislation for about 2 weeks now. It made me ask myself "Okay, who will benefit from this? Who are the usual suspects?" That thought then flashed in my mind one of my favorite movies: The Usual Suspects . If you've seen the movie, you know what I'm talking about. If you haven't seen it or have forgotten it's plot (it came out in 1995), it's about a criminal getting revenge while playing a game of cat and mouse and hiding in plain sight. And the scene that literally flashed in my mind was when Kevin Spacey's character Verbal Kint talks about his boss, Keyser Söze.
"...Nobody ever believed he was real. Nobody ever knew him or saw him or anybody who ever worked directly for him. But to hear Kobayashi tell it, anybody could have worked for Söze. You never knew. That was his power. The greatest trick the Devil ever pulled was convincing the world he didn't exist".
To truly understand where I'm coming from, you really should see that whole scene. And then the ending scene of the movie. (I've linked, not embedded, because the scenes goes into some NC17 violence and might make some uncomfortable. You've been warned). The first scene describes how Keyser Söze came to be who he is. And the second, how he disappears, with most none the wiser. While the story's characters are gangsters, thugs, bad cops and murderers, the idea is the same. These scenes are telling and perfectly describe what I think is going on with this potential legislation. Watching them again and thinking about what my BFF said made me realize there is DEFINITELY something else going on behind the scenes of this proposed legislation. I think it's a plan to go out, reek havoc, decimate and destroy the competition. Like Keyser Söze. Create shields and walls and blinds around you and always have them wondering if you actually do exist. Make them think it someone or something else. Never deny, never admit, stay off the main grid, don't protest too much, but cower enough to make them think you're scared too. Get others -others who may not even know you or your agenda exist- to do your dirty work.
So who are the usual suspects? I started to think about all the previously mentioned infighting, bi#ching, moaning and lawsuits that has been going on back and forth over the last 10 years between the USDA Certified Organic Cosmetics players, the Natural Cosmetics and Natural Based Cosmetics players (there's a difference) and also the fakers who put the word natural or organic on every label they possibly can with almost nothing "natural" in it. Then I added in a few of the small, medium and larger sized Natural/Natural Based players who have been bought out or by the Big Time Multi-national players and said same players who are now starting to formulate more natural based products on their own. Then I factored in who in each group is really buddy buddy and are big supporters and contributors to The Environmental Working Group (EVG) and The Campaign for Safe Cosmetics (CFSC) (web links purposely not included for these thugs). That was a hard one as the EWG money trail is slim pickings. I've been saying for 5 years "follow the money".
Then I factored in the EU companies who fit into all my listed categories as SCA 2010, in it's current draft legally also affects them with the same requirements. Then I added the importers from the rest of the world, ditto the same requirements. These last players, sadly also include the countries who have histories of having confiscated products, knock off/counterfeited products and deadly tainted products that run the gamut from prescription drugs, OTC drugs, cosmetics, food and even drywall. It gave me a huge headache. Thankfully, mainstream media reports on many of these things. And the Cosmetics Industry trade papers are a wonderful source of all cosmetic information, good, bad and ugly. Both the North American and EU versions also have sections which are devoted to developing markets in what's called BRIC (Brazil, Russia, India And China). The FTC and FDA notifications are also quite a read some days. Yes, the internet is my friend.
Next I started thinking about just who all would benefit from the extreme diminishment of the Handcrafted Cosmetics Industry. Actually, who all would benefit the most from it's almost complete demise? First, let's list who WON'T benefit from SCA 2010:
Besides the US Handcrafters, not my Canadian or other foreign Handcrafter Brethren who have US sales. They're not selling hundreds or thousand of bars or jars at a pop to US importers/distributors. (And if they have hundreds of stores world wide, they're not handcrafters, I don't care what they say. You know who I'm talking about, rhymes with slush. And while they'd have to follow the law too, they can afford to hire lots of bodies to keep up with this proposed idiocy). The average foreign Handcrafters are more or less in the same leaky and listing boat as US Handcrafters right now.
So just who would benefit from SCA 2010?
Let's start with foreign cosmetic manufacturers that already are or will be selling hundreds or thousands of bars or jars at a pop to US importers and distributors. Then there's that coming tidal wave of cheap, badly formulated, made with illegal ingredients crap that will come pouring in even more from Mexico, Asia, Africa and the middle east. THOSE will be the ones we have to worry about. The FDA will not be able to keep up with the SCA 2010 paper and computer generated work to accurately keep track of the importers and their ingredients declarations. How will they be able to keep track of all the foreign importers? Will they create a monthly or quarterly "Allowed" list? And if they do, who will enforce this list and more importantly where and how will it be enforced? Yep, another blog post for another day. So who enforces SCA 2010 on the import side? The FDA is stretched extremely thin and needs to step up it's game and keep track of, keep ahead of and catch the tainted food and drugs, both domestic and imported. And with regard to the imports, by it's own admission the FDA cannot and will never have enough people to inspect every shipment at every port of entry, land, air or sea. From their lips to God's ear. So I'm hazarding a guess the FDA will probably give the importers more leeway than they'll give the US cosmetic companies. That also includes Handcrafters. I also think the FDA will just "trust" the importers to properly, promptly and accurately fill out the required forms and declarations on ingredients. Yeah, okay, riiiiight.
Can we say heparin, wheat gluten and toothpaste? Oh my! 3 products that go INTO your body. And that's just 3 bad imports that we know about. Or were told about. And on the US side don't get me started on the uber scary, mind boggling peanut products recall . The FDA can't keep up and no matter how much money is tossed at it, the world is now a fast moving, gotta get it now importing and exporting global economy and there aren't enough and never will be enough Inspectors, Agents or lab techs to check the imported and domestic food and drugs quickly. Operative word there is quickly. Now there are those who want to add cosmetics to an already over loaded ship? The Cosmetic Industry is not making products to harm their customers! Oh, and we all know any "fees" collected from cosmetic companies will be spread out amongst the whole agency, not just on the cosmetics arm.
So who on the US side would benefit from SCA 2010, our demise and taking away the customer's right of product choice?
Now before I continue, I must disclose that while I applaud many of the goals set by the below listed NGOs (non governmental organizations) regarding "Naturals" and "Organic" Certification, I am also suspect of these same organizations. Why? Sigh. It's just a feeling I have:
1. Most of the certification standards were set by a compilation of well known cosmetic companies that got together to make the standards and it's in essence having your competition "okay" you.
2. The cost of certifying is very high per sku (stock keeping unit). A company has to, no needs to have a certain level of income in order to afford them. So if you don't qualify on the money end, you aren't big or selling enough yet and won't be able to join/get certified if you are not able to afford their fees. You usually have to be seriously cranking out lots of product and selling them or have investors or some type of financing sitting in the bank to afford the cost of the certifications. So once again, as for the certification, most indies, micros and small cosmetics companies don't even think about putting their horse in that race. But looking at most of the founding members of these certification orgs. and even their current members companies, I think this list may be a very telling feature.
3. I truly believe who your parent company is (if there is one) should be factored in before getting a Natural or Certified Organic certification.
So, in order of vocalization and media attention regarding cosmetic "Natural" or "Organic" standards, whom all we haven't heard from regarding the SCA 2010?
Leadership from these Certifying Agencies:
The Natural Products Association
While I did read in a trade news article a quote from one of their members on how they thought SCA 2010 was throwing the baby out with the bathwater, as of this posting I have not found any official statement anywhere on the NPA's official site where they say either yea or nay on the proposed SCA 2010.
The Oasis Standard
As of this post I have not found any official statement anywhere on their website as to a yea or nea on SCA 2010.
NSF International , The Public Health and Safety Company
While they are truly a neutral certification organization, since they have set standards for certification, the should state their position. As of this post I have not found any official statement anywhere on their website as to a yea or nea on SCA 2010.
And many of their members and the certified companies. Most of whom started out just like me. As Handcrafted Soap and Cosmetics Makers. Many of these certified companies will go bye-bye if SCA 2010 passes. They will have even heavier mountains of regulations, requirements and information gathering and submitting to carry than the load they already are.
Now if I am wrong about any of them, someone please politely (and if it's not polite it won't be published and the addy will be banned- I don't tolerate trolls!) correct me and point me to the links were they have publicly posted their official views. I would like to be wrong. I really, really would.
So who else would benefit from our demise and the taking away the customer's right of buying choice?
Oh yes, last but not least, some private companies who have the USDA "Certified Organic" seal (who shall remain nameless as they have deeper pockets than me and who ironically get a bit pissy when they get criticized). Some whom I would call bullies. While I applaud them on reaching for and attaining what some consider the holy grail of goals, they really do need to stop being such mean, nasty, arrogant bullies in the Cosmetic Industry. Thinking of one in particular, I think their daddy would roll in his grave if he knew how his heirs were behaving. He built his company with a quality product and by love of mankind, not by bullying. To them and others I say yes, some companies are not to your standards or even mine, and others do greenwash and "natural" the hell out of their products without it being in any significant quantities or any at all. But ultimately, the consumer will decide their fates. The petty mean spirited actions, holier-than-thou attitudes, the constant bully pulpits and continual lawsuits do not endear any of you to the industry as a whole and it might actually be causing you to lose current and potential customers. I know, because they are buying from Handcrafters.
For every bar of soap, jar of body scrub, tube of foot balm or bottle of lotion I'm selling, that means someone IS NOT BUYING YOURS . Multiply that the thousands of micro and small Handcrafted Soap and Cosmetic Makers and companies in the US. See us at the Farmers Markets, the local Fairs and Festivals. Their own retail stores, their ability to get into Natural Food stores large and small in their region. Look us up on esty, artfire , indiepublic and all the other handcrafted marketplaces on the web. Look us up on our industry networks. The Handcrafted SoapMakers Guild has 4631 as of this post. The IndieBeauty Network has 6000+ members. We created our niche. We've created our jobs . We make what the public wants to buy, and we make it honestly and ethically. Are we cutting into your profits? Maybe. Are we sorry if we are? NO. There are thousands of Handcrafted Cosmetic Manufacturers, hundreds of their Suppliers and millions of a buying public. 308 million in the USA -and rising. 7 billion people on the planet -and rising. No few entities can sell to them all, no matter how hard they try. Though I guess a few of you can give it a really good try if you get rid of most of the small, localvore and internet competition.
Well, I've listed all the players and I can't pierce the veil. It's really thick and I think the answer is in this list of suspects. It's in there, somewhere. But I haven't found it...yet. But perhaps with combined efforts my fellow Handcrafters, our suppliers and industry advocates can, armed with the knowledge that our potential demise is not an incidental or accidental casualty of war. It is a deliberate attack on our segment of the industry.
"...The EFFECT of this legistlation is not to put you out of business. The PURPOSE of this legislation is to put you out of business."
So all this really just boils down to just one question:
Who all is the Keyser Söze of The Safe Cosmetics Act 2010?
Categories: Regulatory, I'm Just Saying...
Tags: legislation organic/natural certifications removing competition NGOs cosmetics idiocy run amuck bully business handcrafters markets
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