In a follow up to her previous article addressing the FTC accusing bamboo textile manufacturers of making false green claims, Coral Rose digs deeper into the issue of bamboo based fibers and their organic certification through the USDA National Organic Program.

The FTC recently charged four textile companies with making false unsubstantiated "green" claims. According to the FTC these companies were deceptively labeling and advertising textile related items as made of 'bamboo' fiber, when they are actually made of rayon, and must legally be labeled "Rayon made from bamboo."

With concern about the 'glamorization' of bamboo in the textile world, the question has been raised again.

"Can bamboo textiles, (which technically are man-made fibers) labeled as "Rayon made from bamboo" be certified organic to the USDA National Organic Program (NOP)?"

Given the lack of clarity amongst industry professionals and the ongoing controversy that is still running wild in the textile market, I decided to again reach out to the USDA for clarification.

According to Joan Shaffer at the USDA-AMS Office of Public Affairs "Bamboo" as a raw material for textiles is approved for Organic Certification, in accordance with the National Organic Program (NOP) Standards.

While this may sound a bit absurd and about as clean as coal, rayon or viscose, a man-made chemically produced fiber, can indeed be certified as an organic textile. Note that it is the bamboo itself as the CROP (raw material) that is allowed to be certified as organic to the USDA NOP Standard, and that the processing of the fiber and or garment is NOT considered in the process of certification to the USDA NOP Standard.

The USDA AMS Office of Public Affairs states:

"The organic standards cover agricultural products from livestock and crop. Bamboo is a crop." Please see the explanations for textiles in this (Labeling of Textiles Under National Organic Program (NOP) Regulations) fact sheet." ( *note this fact sheet was posted on my blog 8/08.)

"Below is an excerpt from the "Preamble" on "nonedible fibers products" in the organic standards."

"(6) Nonedible Fibers Products in the NOP. Some commenter's asked the NOP to clarify the certification status of fibers such as cotton and flax. The final rule allows for certification of organically produced fibers such as cotton and flax. However, the processing of these fibers is not covered by the final rule. Therefore, goods that utilize organic fibers in their manufacture may only be labeled as a "made with..." product; e.g., a cotton shirt labeled "made with organic cotton."

Proper labeling in accordance with the FTC would be:"Rayon(or Viscose) made with (or) from organic bamboo"

Respectfully, the decision to include bamboo for organic certification, in accordance with the USDA-NOP, can be summed up into four words "Bamboo is a crop."

All of this still calls into question a fiber, one that is man-made in a manufacturing process using toxic chemicals that results in the emission of hazardous air pollutants, being allowed to bear the organic label? What makes this seem like just another version of clean coal is that technically according to any textile textbook or textile academic, rayon (regardless of the raw material source) is classified as a 'man-made-regenerated' fiber versus a 'natural' fiber of vegetable or animal origin such as cotton, flax, wool etc.

According to ATTRA, the National Sustainable Agriculture Information Service, managed by (NCAT) and funded under the United States Department of Agriculture's Rural Business-Cooperative Service, "Bamboo" is a multipurpose "Agroforestry" crop and has three principal uses:

• Domestic use around the farm (e.g., vegetable stakes, trellis poles, shade laths)
• Commercial production for use in construction, food, and the arts (e.g., concrete reinforcement, fishing poles, furniture, crafts, edible bamboo shoots, musical instruments)
• Ornamental, landscape, and conservation uses (e.g., specimen plants, screens, hedges, riparian buffer zone)

While they do not indicate fiber as a principle use, they actually list bamboo as a fiber crop in a secondary value-add "Agroforestry" product category. Evidently based on two specialty food items- bamboo shoots used in Asian stir fry and a pickled condiment, qualify and support bamboo as a food crop.

There are many plant based raw material sources for rayon. Bamboo is just another one of those raw material sources. The marketing of Bamboo is that of a more glamorous commodity, than let's say Eucalyptus, Beechwood, Spruce or Pine.

Textile scientist and consumer advocate Dr. Gwendolyn Hustvedt states in her FTC testimony that "No mention is made of the process by which the rayon is produced and the consumer is left to believe that the fiber is "new" and "superior" based solely on the source of the material. No one would dream of labeling a product as "spruce" or "pine", but because it seems vaguely credible that bamboo plants could be made into fiber with minimal processing, the process is never discussed. This failure to discuss the process would not be so noxious if the suggestion was not also being made that the fiber is environmentally superior."

While all rayon is man-made and go through a similar manufacturing process, there is only one company that offers complete supply chain transparency for producing 'rayon' from plant based sources, in a closed loop process. The company is Lenzing. They produce TENCEL ® and Lenzing MODAL ® fibers derived from eucalyptus and beechwood respectively. I am not aware of any company that manufactures 'Rayon made from bamboo' in a closed loop production system, where the chemicals used are completely recycled and recovered at a rate of 99.5%, such as that of Lenzing fibers. Eucalyptus and Beechwood are also grown sustainably and without chemicals. In addition, Lenzing products carry Oeko-Tex100 and FSC certifications.

And while the NOP regulations are now crystal clear and bamboo as a raw material source can be certified organic as "rayon made from organic bamboo." You will have to make an informed choice, regardless of your role, as a sustainability professional or a consumer and consider that the only true cradle to cradle man-made fiber product from a plant source that can truly call itself a sustainable fiber continues to be TENCEL ® or Lenzing MODAL ® both of which will continue to be my garments of choice.

Coral Rose has more than two decades of experience in the apparel and retail industry as a merchandise buyer and in product development. Coral is founder of Eco-Innovations, a consulting firm focused on supporting businesses with the integration of "sustainable value" into their core strategies, product design, and development. Read her blog here.