Although I didn’t realize it while writing it, my post a couple of days ago, ‘Watch out for green washing’ appears to have been the first in a series on ingredients, labeling, and advertising, so today I’m going to talk about what is supposed to be on a cosmetic label. Since I’m based in Canada, I will focus on that, but much of it applies to the EU and the U.S. as well. I will try to point out where they differ as I go.
Also, I am going to speak specifically about products that have only one label, such as a bottle of shampoo, or a bar of soap. If you are looking at a bottle of facial cleanser, for instance, that is sold inside a box, all of the requirements listed below are still in effect, but their are some differences between what is required to be on the outside (box) label and the inner (bottle) label. I won’t go into all of these, because this post would turn into an epic. If you’re looking for this information, visit Health Canada, and read the Guidelines for the Labeling of Cosmetics
The first requirement is the product identity. In Canada, this must be listed in English and in French.
Next, the ingredients. Simply put, if it’s in it, it has to be on it.
Ok, right off the bat, I’m going to point out an exception. In the United States, if a bar of soap is simply labeled as soap, without any claims such as moisturizing, deodorizing, antibacterial etc, then no ingredients are required to be listed.
Back to Canada, where all ingredients must be listed on the package, in descending order of their predominance in the product, regardless of whether it is soap, lotion or lip balm. So far, so good.
The next requirement is that the ingredients used be listed using the International Nomenclature of Cosmetic Ingredients, commonly known as INCI. INCI was developed with the intent of making it easier for consumers to identify what was in the products by standardizing descriptions around the world, so that coconut oil, for instance, would be listed the same way in Germany as it is in Canada. In theory, this is a great idea, but in practice it falls a little short of its’ intention to provide clarity to consumers. The problem is that the average consumer reading the package does not know that sodium cocoate is the INCI for saponified coconut oil, which means coconut oil that has been mixed with lye to form soap, or that butyrospermum parkii is Shea butter. At BumbleBee Lane SoapWorks we have added a Glossary of Ingredients to our website to help customers figure it out. If you are unsure of an ingredient in a product that you have purchased, contact the manufacturer for clarification.
Next, the product must show the net weight of the contents. Pretty simple, right? However, have you ever seen this character in front of the weight on a label?
This little guy is called an ‘estimated sign’ or ‘e-mark’, and it signifies that the weight of the product is not less than the stated amount. Who knew?
The name and address of the manufacturer must appear. This is to ensure that the consumer can contact the manufacturer if they have any questions or concerns about the product.
Finally, the product must list any Avoidable Hazards and Cautions. This is where you will find indications that the product is flammable, or ‘may leave an oily residue on the bathtub’, etc.
So this is the list of what must appear on the label. How about what is not allowed to appear on the label? This is a much longer list!
Health Canada states: “According to the definitions of the terms “cosmetic” and “drug”, the key consideration for the classification of a product is its proposed use. The claims made in package inserts, in advertisements, and especially in product labels, indicate the intended use of the product.”
Products such as soap, body lotion, aftershave lotion…all of the products offered by the handmade bath and body industry are classified as cosmetics, and as such, are not allowed to make any claims that the product is in any way therapeutic, which is defined in the dictionary as “of or relating to the treatment of disease or disorders by remedial agents or methods.” What does this mean? It means that any claim that a product treats or relieves a condition, from eczema and psoriasis, to aging skin is not allowed.
So which of the following statements are allowed?:
“A must for treating Eczema and many other skin conditions.”
” It has been used in traditional medicine for the treatment of tetanus, eczema, scrofula and erysipelas.”
” I have used your Tea Tree Oil soap everyday and have not had one occurrence of fungal infection.”
The answer is, none.
Any claim as to the healing properties of a cosmetic, whether it is a statement made by the manufacturer, a testimonial by an existing customer, or a reference to the traditional or historical uses of an ingredient within the product, are illegal. If the manufacturer makes any such claims, they must declare the product as a drug, submit it to Health Canada for testing, and will receive a DIN, or Drug Identification Number which must be displayed on the product.
So what claims can be made?
A manufacturer can say that their soap is soothing or moisturizing. They can also say that it changes the appearance of the skin. For example, a soap that contains oils that are good for aging skin cannot be said to reduce lines and wrinkles, but it can say that it reduces the appearance of fine lines and wrinkles. A soap cannot claim to eliminate eczema or psoriasis, but it may be said that it helps soothe and moisturize dry, itchy skin, which is associated with eczema or psoriasis.
We are allowed to say that a product is an antibacterial or antimicrobial cleanser, but cannot say that it kills bacteria, germs, pathogens, etc. We can say that it kills odour causing bacteria, but cannot say that it kills bacteria.
Most of the name brand soaps, cleansers and skin treatments adhere to these rules of labelling. Unfortunately, where you will find the majority of the offenders is in the handcrafted bath & body and cosmetic industry. Do a quick Google or Etsy search, and easily 8 out of 10 products listed will make either a completely outlandish and insupportable claim, or will state healing qualities for their product that are completely contrary to the Health Canada regulations.
Imagine, you have eczema, and are shopping at a farmers’ market looking for a new soap. Two vendors, each with an all natural calendula soap.
The first soap advertises that it will “heal, moisturize and soothe all your skin problems”, and lists the benefits of calendula as “Calendula officinalis, also known as pot marigold or garden marigold, has been used for centuries to heal wounds and skin irritations. Calendula has anti-inflammatory, antimicrobial, astringent, antifungal, antiviral, and immunostimulant properties making it useful for disinfecting and treating minor wounds, conjunctivitis, cuts, scrapes, chapped or chafed skin, bruises, burns, athlete’s foot, acne, yeast infections, bee stings, diaper rashes, and other minor irritations and infections of the skin. Plus, it stimulates the production of collagen at wound sites to help minimize scarring.”
The second soap states simply that it is “Soothing.Gentle. Moisturizing.”, and speaks only of the quality of the ingredients.
Which soap are you more likely to purchase? This is an illustration of the power of marketing, and the very reason that Health Canada mandates what can be said on labels. Swept away by the miraculous qualities of the first soap, you may be disappointed when you get home and find that it does not live up to its marketing.
This leaves the percentage of us who work hard to comply with all legal and government requirements in a bit of a tough spot. Do we make the claims that our competitors are making and clinch the sale? Or do we do what’s right, and watch the customer purchase from the other guy?
So the next time you find yourself choosing between two handcrafted soaps, lotions, or balms, look past the claims, and ask questions. If you are buying from the person who made it, ask her/him about the ingredients. A good Soapmaker or formulator should be able to tell you why they chose all of the different oils and butters in the product, not just the sexy ones.
Don’t expect them to tell you about the healing powers of the essential oils and herbal extracts…they are not allowed to. Do your own research before you leave home. There are some excellent sites which discuss the properties of the various ingredients, and do not rely on information found on websites that are trying to sell you something. Always look for independent sources of information.
Choose some that you think would be beneficial in your particular situation, and go look for them. Will they be effective? Some will, and some won’t. Like all products, not everyone’s results will be the same. Try different products until you find one that works for you, and keep in mind that the amount of essential oils and herbal extracts in soap, lotions etc. is minimal. Do not expect the same therapeutic effect from a lotion or wash off product that you would get from treatment by a certified aromatherapist, but respect the ingredients….use the products as directed, and take note of any contraindications listed.
In closing, also keep in mind that a soapmaker who has taken the time to research the advertising and labeling regulations, and chosen to comply with them, is also more likely to be complying with other things such as good manufacturing practices, and maximum safe usage levels for ingredients, ensuring that you are purchasing a safe, quality product.