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Ingredient label rules- what we are not told about beauty products

Reviewed by Marta October 14, 2011 15 Comments

Truth In Aging has made me a label nerd – for the simple reason that one of the ways of figuring out whether a cosmetic product might deliver on its promises is to take a good look at what’s in it. I’m not completely naïve and have never assumed that the list of ingredients on our potions and lotions tell the full story, but I was still taken aback to discover recently that cosmetics manufacturers are not obliged to list all the ingredients that they use. I’d always assumed that they were, and so I realized that it was time to go back to basics and give myself a cosmetics ingredients regulation 101.

After noodling around on the FDA’s website, I pulled together the key points so that you don’t have to. If you are interested in the details, here’s the link to the FDA. If you just want the highlights read on. Warning – this post may make you disappointed, possibly angry, or perhaps just drowsy.

Fun fact: the requirement for cosmetic ingredient labeling became fully effective in early 1977. Or it would be fun if those requirements had become more rigorous since then. But by and large they have not.

The one thing that most of us in the Truth In Aging community take for granted is that cosmetic ingredients must be listed in descending order of predominance. You would be forgiven for thinking that this means that the first ingredient listed is in the greatest quantity and the last is the least. Well, I’m afraid this may not be the case.

The most frustrating exemption from this descending order rule is that it only pertains to ingredients in a concentration of more than 1%. Ingredients present at a concentration of less than 1% may be listed in any order.

The problem with this is that we don’t know by looking at the label where the ingredients at less than 1% concentrations start.  And, therefore, we don’t really know the quantities of any ingredients and the significance of their contribution to the formulation.

So, in my opinion, a great consumer-oriented innovation would be for the FDA to require cosmetic labels to state, at the very least, which of the ingredients are at less than one per cent. I have a feeling that we’d be a little shocked by how many of them there would be.

I was also surprised to see that in some instances cosmetics companies don’t have to tell us what the ingredients are at all: flavor, fragrance, and trade secret ingredients are exempt. In retrospect, flavor and fragrance are not surprising as we very often – and annoyingly - see them listed as just that. But “trade secrets” sounds a lovely loophole for cosmetics companies to keep all sorts of things off labels. So I was somewhat, but not entirely, reassured to see that the FDA requires “full statement of the factual and legal grounds for the request” to be considered a trade secret. If the company wins though, they are able to simply say "and other ingredients" at the end of the ingredient declaration.

Next time you are at a salon or spa, be aware that you may never know what’s in the products being used since all this ingredient declaration stuff only applies to cosmetics customarily sold at retail or for use at home. They do not apply, for example, to products used at “professional establishments or samples distributed free of charge”.  Why the heck not, I’d like to know!

There are a few other situations that worryingly merit off-label status. For example, a “masking agent” (this means an ingredient used to cover up a nasty smell) need not be declared at all if it is “in a product at an insignificant level”. Personally, I find the term “insignificant level” to be vague and meaningless. For cosmetic companies, it means that the ingredient may be considered an “incidental ingredient “ and “in which case it need not be declared on the label”.

Another example of an “incidental” ingredient bothers me. In the FDA’s words: A substance that is added during manufacture of a cosmetic, is converted to an ingredient declared on the label, and does not significantly increase the concentration of the declared ingredient. Example: Sodium hydroxide added to a sodium stearate and stearic acid-containing cosmetic.”

It’s kind of ironic that the example given is sodium hydroxide, a rather nasty and harsh ingredient that is used as a pH balancer. It seems it could be in my beauty products without me even knowing.

Also off-label could be a “substance…. having no technical or functional effect in the finished cosmetic. Example: Preservative of a raw material added to a cosmetic as an ingredient at a concentration which reduces the preservative to a level at which it is no longer effective.”

The FDA ingredients labeling regulations are out of date. We consumers in 2011 are educated and armed. I believe what we need is really very simple: we need to know exactly what we are buying and that means knowing everything that is in our cosmetic products and how much of them. No exceptions, exemptions, incidentals or cosy trade secrets.

  • August 26, 2014

    by Marta

    Hi Rebecca - thank you for pointing out my error. Sodium hydroxide is indeed used as a pH balancer. I have amended the article accordingly. The hyperlink goes to the sodium hydroxide entry in our ingredients directory, where the usage was and is correctly described. It also correctly notes that this ingredient is caustic acid, otherwise known as lye. This is not something I want in my skincare.

  • August 26, 2014

    by Rebecca

    How can you write such an uneducated, unreserached bile of rubbish? I am a cosmetic scientist and formulator. Did you do anything other than do your research on anything other than Google?? Did you actually SPEAK to a cosmetic scientist like myself? Apparently not! For one thing Sodium Hydroxide is NECESSARY in ALL cosmetics! It is NOT a preservative!!!! It is an alkaline salt that is used to balance pH. For example...the natural pH level of your skin is 5.5, and if I needed to formulate a pH balanced cream to match the pH of the skin, I would then test the pH of that cream and if I found it to be acidic...I would have to add a small amount of Sodium Hydroxide or another like kind to bring the pH to 5.5 to match the skin so it'll be gentle. You article is FILLED with errors and things that just are NOT correct!!! Contact me and I will give you an exact breakdown of everything. Next time you think of writing an article like this...ask an expert rather than a Google search!

  • August 7, 2013

    by Mckayla

    What is an off- label ingedient?

  • October 24, 2011

    by Jeanne

    Olivier - to be totally honest, don't be surprised if they didn't answer you - but hopefully the delay is in their taking the time to research the answer. The truth is, many skincare companies don't do their own formulating in house. Some larger ones do, but most companies outsource that to a lab. The lab prepares a formula for them and the skincare company rejects it or says "yes, I love this formula, let's manufacture!." They're then supplied with an ingredient listing like what you see on the back of the bottle, but they don't know percentages or incidental ingredients involved. Thus the fault doesn't come down on the skincare company, but the laboratory making and manufacturing the formula. It's a whole system that needs to be reworked - not just the company! The truth is, they probably just don't know.

  • October 20, 2011

    by Perry

    You mostly got it right. The one thing I would point out is that Fragrance isn't listed as Fragrance primarily because it's a trade secret. The reason it's listed that way is because fragrances are made up of 70 - 150 separate ingredients. If all the ingredients in the fragrances were listed they wouldn't fit on the back panel.

    The other thing I would point out is that companies wouldn't want to tell you where the 1% line is. That way, you might realize that all those featured ingredients on the front of the label aren't in there at significant levels. People would just rather believe that Aloe is their moisturizer rather than Petrolatum which is really having the effect.

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