ISO 16128 is not a certification. It is a calculation method — a way to work out what proportion of a formula is naturally derived, using agreed definitions for what counts. No body audits you against it, and nobody issues a mark.
That distinction has become the central practical problem for anyone selling a natural mascara, because the government certification system for natural cosmetics in Korea has been removed, and ISO 16128 is what brands reached for to fill the gap. A standard designed to measure something is now being asked to authorise it.
What the number does and does not tell you
A natural origin index of 91 percent, or 95, describes ingredient provenance. It says nothing about whether the remaining share is a preservative system, a synthetic film former, or a pigment dispersant that does most of the visible work.
M·A·C and Estee Lauder have both launched formulations quoting 91 percent or more naturally derived content, and those numbers are calculated honestly. They are also compatible with a formula that contains synthetic preservatives, because the standard was never written to exclude them. A product can score high and still sit uncomfortably beside a shopper’s mental model of what the word natural means.
The 95 percent threshold that circulates as a benchmark for natural cosmetic products has the same property. It is a content figure, not a verdict on the formula, and treating it as a pass mark imports a certainty the method does not carry.
Filling the gap left by certification
With the state mark gone, brands are assembling their own evidence packages, and the composition of those packages is now a genuine point of difference between manufacturers.
- Third-party verification schemes such as EWG Verified are being used alongside a natural origin calculation, because a mark someone else administers carries weight that a self-declared percentage does not.
- Independent testing of the natural origin index itself, with the supplier documentation behind each raw material retained rather than summarised.
- Clinical or instrumental testing on the finished product for the performance claims — lash lift, wear time, irritation — since ingredient provenance and product performance are separate questions that consumers hear as one.
The last of these is where the real cost sits, and where brands underestimate lead time most often. A natural origin calculation can be produced in days from existing supplier data. A wear-time or ocular-irritation study cannot.
The formulation squeeze
Eye products are the hardest place to apply a naturalness constraint, and mascara is the hardest eye product. It has to survive humidity, resist smudging against skin that moves constantly, hold pigment in suspension, and remain safe in contact with the eye across the whole life of an opened tube.
Preservation is the pinch point. The synthetic systems with the longest safety record are the ones a naturalness percentage penalises, and naturally derived alternatives generally need higher inclusion levels, tighter pH control, or packaging that limits contamination. Each of those has a cost, and the cost lands on a category where retail price points are unforgiving.
Fibre technology has taken some of the pressure off the chemistry. Microfibre systems build length and volume through physical structure — fibres wrapping the lash — rather than through heavier polymer loading, which makes a lighter formula viable without giving up the visible result the category sells on. Brands positioning around lash length and primer routines have leaned on this, and it holds up because the mechanism is straightforward to demonstrate.
Where it does not solve the problem is claim language. Volume gains quoted in brand-reported figures vary by formula, by applicator and by how the person applies it, and a number lifted from one internal panel does not transfer to a campaign in a market that asks how it was measured.
How to brief this now
Ask the manufacturer for the natural origin index and the method used to reach it, not just the headline percentage. Two suppliers can quote the same figure from different assumptions about what counts as derived, and the difference surfaces later when a retailer’s compliance team asks.
Decide early whether the naturalness figure or the performance claim leads the marketing, because they pull the formula in opposite directions. A product built to hit a specific content threshold and a product built to hit a specific wear time are not the same brief, and trying to write both after the fact produces a formula that satisfies neither.
Keep the raw material documentation. When the state certification disappeared, the burden of proof moved to the brand, and it moved permanently. The same pressure to substantiate claims with submitted data is showing up in other cosmetic format rules and in adjacent categories where a vegan or additive-free position carries a similar evidentiary weight.
A natural mascara that can show its working is now a stronger commercial proposition than one carrying a badge, which is not where this category expected to end up.
“The end of blanket organic certification has actually made our conversations with buyers more concrete, not less. Instead of asking us to simply put a ‘natural’ badge on a formula, brands sourcing mascara and other natural-positioned products are now asking what documentation stands behind that claim before they build a campaign around it. From a marketing standpoint, that’s a healthy shift — it pushes the story toward what a formula can actually demonstrate rather than a certification mark alone, and buyers who get ahead of that tend to launch with messaging that holds up under scrutiny.” — Hyejin Cho, Digital Marketing Specialist, Marketing and Communication Team at SPSCOS