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Why consumers and private-label owners are unable to rely upon a product label to determine contents.

Local grocery store patrons can see skin-care products lining the aisle advertising that they are organic, wrinkle-reducing, hypoallergenic, etc. However, after use, consumers are finding that the products not only do not provide the aforementioned results, they occasionally cause adverse reactions.


Cosmetic companies have the ability to permit advertising claims, and omit quantitative lists of inactive ingredients, regardless of contents. This renders a person unable to determine efficacy or potential allergens at face value. In addition, many private label cosmetic owners are not having the product independently tested to ensure that what the customer sees on the label is indeed true. This is why individuals and private-label business owners alike contact chemical testing laboratories like Avomeen, who perform reverse-engineering to identify a product's quantitative levels of ingredients.

In the United States, when a cosmetic is distributed for retail sale, the FDA requires the company to quantitatively list any biologically active substances over 1%. Inactive ingredients must simply be declared in descending order of concentration. Most inactive ingredients have little to no effect on the consumer, so the vague declaration is not an issue. The problem arises when there is an ingredient which may be declared inactive, but could actually have an active effect at certain levels. There is often discrepancy between which organizations consider ingredients active versus inactive. In examining the inactive substance lists between Canadian and US regulatory agencies, the discrepancy is quite clear.

A example of one inconsistency is urea, an ingredient commonly included in creams as a skin moisturizer and reparative. According to the FDA, urea is an inactive ingredient at all levels. However, according to Health Canada, urea must be declared at concentrations equal to or above 10%. The regulators of Health Canada must acknowledge effects that the United States does not. Suppose urea does indeed cause irritation at certain levels; the consumer from the United States will be unable to depend on the label to predict a reaction to the product.


Skin irritation aside, some products simply do not work to solve the cosmetic issues the labels promise. The FTC requires that when a claim is expressed, such as, "this moisturizer firms skin," the company must be able prove a test existed. Considering that a company may find ease in guiding research into desired results, are these requirements sufficient? Furthermore, some claims require absolutely no substantiation. For example, the term hypoallergenic does not necessarily mean that the specific product causes fewer allergies. The FDA website declares, "The term [hypoallergenic] means whatever a particular company wants it to mean."

When considering a product based upon the label, it is always worth regarding bold promises with skepticism. One can never be sure which companies are able to substantiate their claims, or if the claim even requires proof. Additionally, products must always be tested by label owners to ensure that included ingredients match the label, active and inactive ingredients are listed appropriately, and that ingredients are tested for potential irritation or negative effects.

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Dr. Shri Thanedar, Ph.D, is the CEO and Chief Chemist at Avomeen Analytical Services. He has over 20 years of experience serving as chief scientist or expert witness on over 20 litigation support projects involving chemical analysis, product failure analysis, reverse engineering, and polymer and rubber analysis.

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