The FDA does not regulate the manufacturing of personal care products or require testing products for safety.  Nor do they review or approve products before they are sold.  Only certain cosmetics or other personal care products that contain color additives or contain active ingredients that are classified as drugs are reviewed before they can be sold to the public.  In Europe, more than 1,000 ingredients typically found in cosmetics and other personal care products in the United States have been banned.  The personal care and cosmetic industry in the United States, on the other hand, is allowed to police themselves through their Cosmetics Ingredient Review panel.  In 30 years, the panel has only identified 11 ingredients that are not safe, and even then, their recommendations are not binding on manufacturers.  By contrast, Whole Foods Market, a retailer, has taken it upon themselves to study the effects of ingredients found in personal care products, and have banned the use of 400 harmful ingredients in their private label, premium body care products. 

The FDA does regulate the labeling of personal care products.  The information panel of a personal care product must contain the name and address of the manufacturer or distributor, facts about the intended use of the product, a warning or caution statement, and the list of ingredients.  The ingredients must appear in descending order of predominance, and if the product is also an over-the-counter (OTC) drug, its label must comply with the FDA regulations for both OTC drug and cosmetic ingredient labels.   That said, even the industry acknowledges that "cosmetic ingredients are often complex chemical substances; [therefore] the list may be incomprehensible to the product's average user." (http://www.cosmeticsinfo.org/label)

Researchers have identified over 82,000 ingredients used in cosmetics and personal care products, over 10,000 of which have been identified as carcinogens, pesticides, plasticizers, reproductive toxins, endocrine disruptors, degreasers, and surfactants.  People are exposed to these ingredients by breathing in sprays and powders, swallowing chemicals from the lips or hands, or absorbing them through the skin.  Many – such as phthalate plasticizers, paraben preservatives, the pesticide triclosan, synthetic musks, and some sunscreen ingredients – are common pollutants in the bodies of men, women, and children.   To maximize penetration, cosmetics frequently contain enhancers that accelerate absorption deeper into the skin.  Not only are all of these ingredients absorbed into the skin, but they are also washed off into the water and into the environment.

Why this matters:

Sales of natural and organic personal care products reached $10.5 billion in 2013 and could reach 20% of the entire health and beauty care market by 2017.  According to Natural Foods Merchandiser the main driver of this trend is that consumers are looking for safer products in every facet of their lives.  Changes in product formulations have been driven by consumer education and demand, not by government intervention.  

Quality Standards & Certifications

Even the natural product industry is not immune to the use of synthetic ingredients and greenwashed products that appeal to consumer demand for cleaner, safer body care products.   As a result, the Natural Product Association (NPA) created standards for products that could be authentically labeled “natural” along with the national certification program that rewards manufacturer compliance with certification seals easily recognized by consumers. 

The NPA Standards for Personal Care Certification is:

Natural Ingredients: A product labeled "natural" should be made up of only, or at least almost only, natural ingredients and be manufactured with appropriate processes to maintain ingredient purity.

Safety: A product labeled "natural" should avoid any ingredient with a suspected human health risk.

Responsibility: A product labeled "natural" should use no animal testing in its development.

Sustainability: A product labeled "natural" should use biodegradable ingredients and the most environmentally sensitive packaging.

Ingredients may only come from renewable resources found in natural (flora, fauna, mineral) with no petroleum compounds.  The standard goes further to define required manufacturing processing procedures and the chemical makeup of the ingredients.  The NPA provides a list of approved personal care ingredients and certified products from companies such as Field Day, Pura Botanica, J.R. Watkins, Desert Essence, Burt's Bees, Badger, and Aubrey Organics, among others.

Additional certification requirements include:

  • All ingredients must be generally recognized as safe (GRAS) by the FDA
  • Companies must fully disclose ingredients accurately and truthfully
  • Formal International Nomenclature of Cosmetic Ingredients (INCI) nomenclature must be used to describe all cosmetic ingredients
  • A majority of recyclable and post-consumer recycled content must be used in product packaging
  • Manufacturers must avoid animal testing of ingredients or products except where required by law

The movement toward safer body care products is global with organizations such as the Campaign for Safe Cosmetics, the Environmental Working Group's Skin Deep(R) program, the Organic Consumers Association Coming Clean Campaign, and the Organic Trade Association's Personal Care Task Force, among others, working toward the elimination of toxic ingredients and honest labeling on body care products.

In addition to the Skin Deep(R) database, Environmental Working Group (EWG) has launched EWG Verified(TM) in November 2015, a label designed to help consumers identify healthier and safer personal care products. The new eco-label will require products to meet stringent ingredient and transparency standards. To qualify for the EWG Verified seal, products must not include any ingredients listed in the Skin Deep database as restricted or unacceptable. Furthermore, companies must disclose all ingredients on the label and ensure that their products are preserved without the use of toxic chemicals. Catch-all terms such as “fragrance” often used on personal care products will not be acceptable and a full ingredient listing will need to be submitted to qualify for the seal. There has been a growing demand for stricter cosmetics regulations in recent years, but little progress has been made in an industry lacking government oversight. EWG hopes the focus on safety and ingredient transparency will help consumers and be embraced by manufacturers and retailers. “The purpose of verification is not only to educate consumers but to empower them to make better choices while pushing for market change,” - Nneka Leiba, EWG’s Deputy Director of Research.

Organic Body Care Products

The USDA allows cosmetics and personal care products to be certified organic if the product contains or is made up of agricultural ingredients and can meet the NOP organic production, handling, processing, and labeling standards.  But since the USDA doesn't require certification to be labeled as "organic", products can put marketing terms natural or organic on the label even if the ingredients are not organic. Store staff and consumers alike should not assume a body care product is truly organic unless it carries the USDA Organic seal.

In 2010, the pressure for certified organic personal care products profoundly increased when Whole Foods Market required brands making organic claims to qualify and carry the USDA Organic or the NSF/ANSI 305 certifications.  The American National Standards Institute, a private, non-profit organization, the NSF/ANSI 305 standards are administered via QAI (Quality Assurance International) and specifically define labeling and marketing requirements for personal care products that contain organic ingredients.  The NSF standard is designed only for “contains organic ingredients” claims and does allow for limited chemical processes that are typical for personal care products but would not be allowed for food products. NSF/ANSI 305 also requires companies to state the exact percentage of organic content based on the requirements of the standard.

A third organic standard was born in 2010 from a program created by a personal care Trade Association of 30 cosmetic suppliers, manufacturers, and distributors.  The Organic and Sustainable Industry Standards (OASIS) were created out of a concern that the USDA organic standards applied to food and the personal care industry required different standards that encompassed the entire ingredient’s supply stream, including "green chemistry" principals.

Why this matters:

The proliferation of organic certification seals causes confusion among store staff and consumers alike.  Consumers frequently look for seals to let them know if the product is certified or not.  But they may not know the source or the standards associated with the specific seals.  Many products in the body care department are imported from Europe.  So store staff who work in the body care department should have a working knowledge of the different certification seals and their meaning.  The best way to do this is to look for any new certification seals on all new products that are brought into the store.  If a new one comes in, ask the Department Manager or Store Manager.  Other sources of information will be the sales rep and the internet.  

International Organic Body Care

There are a number of other organic certification organizations operating in countries outside the United States.  These seals may also be found on personal care products and should give reassurance to consumers and staff about the quality of the ingredients and transparency of the product labels.

EcoCert (France)

Ecocert is a private organization that has established standards for natural and organic cosmetics and the practice of the respect of the environment throughout the production process.

BDIH (Germany)

The Association of German Industrial & Trade Firms developed comprehensive guidelines for certified natural cosmetics in 1996. The "Certified Natural Cosmetics" seal confirms the use of natural raw material such as plant oils, fats and waxes, herbal extracts and essential oils, and aromatic materials. They must be obtained from controlled biological cultivation or controlled biological wild collection.

Soil Association (UK)

In the UK, standards for organic beauty products are based on food standards. If an ingredient is available organically, it must be used. The remaining ingredients must meet strict criteria to ensure that they are not damaging to the health or the environment. The Soil Association approves product formulas and labels and inspects the manufacturing facility annually.

Certech (Canada)

In Canada, natural and organic certification uses the IOS Cosmetics Standard established by Certech, a privately owned company. A minimum of 95% of the ingredients must be of natural origin. Products that obtain certification as organic must also use certified organic ingredients. Packaging must be recyclable and the products and their individual ingredients must not have been tested on animals, must be virtually free of synthetic ingredients, and must not contain pesticides, harmful preservatives, artificial colors, and fragrances.

Australian Organic (Australia)

As one of the strictest standards in Australia, the Australian Certified Organic Standard brings together the requirements of national and internationally relevant standards that are administered by the Australian Certified Organic program.

Animal Testing

One of the most common ways manufacturers of conventional personal care products tests the safety of their products has been to use animals.  Rabbits, guinea pigs, hamsters, mice, and rats are subjected to new cosmetic ingredients before the ingredients are used in finished products and, also to the finished products themselves.   Neither the FDA nor the U.S. Consumer Product Safety Commission requires animal testing for cosmetics or household products and there are already more than 5,000 established safe ingredients that have never been tested on animals.  Instead, they were tested in labs on artificial human tissue or test-tube analysis for toxicity.

But demand for humane manufacturing practices has forced companies to change their practices.  In the United States, 73% of the general public is in favor of eliminating animal testing altogether.  Now more than 500 personal care companies around the world operate their manufacturing processes "cruelty-free." Typically these companies:

  • Don’t conduct or commission new animal testing
  • Only use new ingredients when human safety can be established without animal testing
  • Don’t sell cosmetic products in countries requiring animal testing

Why this matters:

Customers frequently want to know which personal care products can be trusted to be cruelty-free.  Only when a product has been certified can staff and customers be certain that the product meets these criteria. Staff and customers alike should look for the Leaping Bunny seal to be sure.  

Environmental Impact

What goes on the skin goes down the drain and into our water system.  The ingredients in body care products frequently contain bioactive chemicals that are environmental pollutants, harmful to both humans and animals.  Since they are constantly introduced to the water environment, they have the potential to harm continuous life-cycle, multigenerational species.   Often these impacts are undetectable or go unnoticed and accumulate slowly until the changes have accumulated so much, the negative effects are irreversible.  For example, researchers have found that antimicrobial ingredients used a half a century ago still persist today in the estuarine sediments of New York City and Baltimore.

Many manufacturers in the natural and organic industry have signed the Compact for Safe Cosmetics pledging not to use chemicals that are linked to cancer, mutation, or birth defects, and have also agreed to implement substitution plans that replace hazardous materials with safer alternatives in every market they serve.  The Campaign for Safe Cosmetics is a broad coalition of environmental and public health groups led by the Environmental Working Group, whose website Skin Deep offers a database of more than 69,000 products that have been tested and rated for hazardous ingredients.     

 

Words to Remember

FAUNA

Another word for animals.

 

FLORA

Another word for plants.

 

GREENWASHED

Greenwashing was added to the Oxford English dictionary in 1999, where it is defined as "disinformation disseminated by an organization so as to present an environmentally responsible public image." Typically it is used when an organization spends more time and money on marketing that they are green than actually putting environmentally practices into effect within their company.

 

INCI

This acronym stands for the International Nomenclature of Cosmetic Ingredients. it is a system of names for waxes, oils, pigments, chemicals, and all types of ingredients for body care products based on scientific names, Latin and English words. This single, worldwide naming convention is helpful to consumers when learning about ingredients listed on packages.

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