Thursday, October 11, 2007


When you see ingredient names such as "iodopropynyl butylcarbamate" or "DMDM hydantoin" on the label -- what questions run through your mind? How do I pronounce this? What does it mean? And why would I want to use a multi-syllabic ingredient on my body or in my simple, basic formula? Is it even safe to use? Good questions!

Typically, when big international industries such as cosmetics and body care are involved, one of two things will occur to regulate their actions: a) a governmental agency is set up, such as the US Food and Drug Administration (USFDA) and/or b) a non-governmental agency is set up (NGO), such as the Cosmetics, Toiletries and Fragrance Association (CTFA). In the USA, both the FDA and the CTFA take active roles in assuring the public that the ingredients and finished goods they purchase are safe for consumption.

CTFA is an international body, an NGO with broad powers. In the USA, the USFDA relies upon CTFA to screen new products applicants and once approved, to assign “INCI names” 0r nomenclature (a fancy word for "name").

The INCI name should be used in labeling. It is provided to end any confusion the consumer, whether they live in the USA or anywhere else, may have regarding exactly what is in their product. The INCI name is the "real name" for a good. For instance, I might have a new moisturizer that I want to market, that no other company or person has ever produced. I'd submit my paperwork to the CTFA along with my fee, and they will research the material, and if appropriate, grant an INCI name to that product. I would then print that INCI name on the ingredients panel of my label. This process aids the consumer in deciphering exactly what is in the product they are considering. For instance, instead of reading "Glydant Plus", which is meaningless, they will read "iodopropynyl butylcarbamate" or "DMDM hydantoin" -- names that can be researched.

Sounds like a pretty good deal, right? The consumer is protected, the government is happy and the fee for approval is paid by the individual petitioner. What more could you ask for?

Just as with all things in life, your individual happiness with this system may vary.

One vendor, who shall remain nameless, is obviously unhappy with this system. This person had published a statement regarding the use of parabens, which are mold, yeast and fungi inhibitors (classed as preservatives) in a description of a product they and we and I am sure, numerous other entities sell. This product is supplied as a 1% solution. Their claim was that they do not use parabens in their product, however, any other company or person that sells this product is lying to you if they say there are no parabens in their product. Not only that, the writer continued, but the rest of us are either stupid or liars – or maybe we are stupid liars? – because we are not disclosing the entire ingredients list. After all, there is 99% water in the product, and that does not show up anywhere on the ingredients list. They say they are being “ethical” and they are “uncomfortable” with the INCI naming process. The unwritten message is that the rest of us are unethical and comfortable with “lies”.

Hello? My first reaction was, “how does this person know what I am selling? Or where I purchase it from?” My second reaction was that the writer obviously did not do any research before issuing this claim nor do they exhibit an even rudimentary understanding of chemistry.

The truth is, the writer of this preposterous statement has no clue where any of us purchase anything. All they truly know about, we hope, is what they do, or what they seem to be doing. While I respect the writer’s position regarding their feelings about CTFA and INCI, and fully endorse their right to say it, I note that my recent visit to their webpage shows a less emotional statement than they originally had published, though still wholly unacceptable and inaccurate.

In fact, CTFA dictates what the ingredients label will read, and not the individual petitioner or vendor of the product. I did not wake up one morning and decide what INCI name I would give this product, nor did my manufacturer. I am informed of INCI names by the manufacturer, who receives them from CTFA. If I manufactured this product from the dry powder form, which I could easily do, and which this other vendor claims they do, then I could simply to go to the CTFA ingredients list and see if the materials I am using are named there. If they are, I simply list the named ingredients according to FDA rules regarding product labeling. I do not have to apply to CTFA for a new INCI name. I can just use the materials and list them according to INCI nomenclature. Typically, with small manufacturers, no tests are performed to see if the product works as advertised.

In addition, certain things are “givens” in the wonderful world of INCI. Things like water, for example, are considered obvious and not listed in a product that is referred to as a “you-name-the-percentage” solution, such as Sodium Lactate 60% solution. It is a given that the sodium lactate represents 60% and water or aqua represents the remaining portion. Water is the norm. I am not hiding anything here. Water is the only solvent that does not require labeling, according to CTFA.

Then again, CTFA does not list incidental ingredients – such as preservatives added to the product at the time of processing – in the INCI nomenclature, either. These types of materials are considered processing aids – in other words, you could not reliably make the product without the use of these materials and the remaining amounts in the finished product are so infinitesimal that they do not warrant being listed.

Dendritic salt is a wonderful example of this INCI process at work: the INCI name for dendritic salt is sodium chloride, the same as table salt or pool salt or kosher salt or pretzel salt. It’s all got the same name because it’s all made up of sodium chloride. Most salt is mined from the ocean and either kiln or solar dried. To make dendritic salt, the sodium chloride undergoes an additional process. It is crystallized under special conditions. A trace (less than 3 ppm) of yellow prussiate of soda is added to modify the way the salt crystals grow. The crystals grow at the corners rather than the faces, which produces star-shaped crystals. Only sodium chloride will fit into this crystal matrix, leaving incredibly pure salt crystals with micropores in them. The yellow prussiate of soda is removed before the crystals are dried.

Additionally, dendritic salt is treated with sodium aluminum silicate, to assist in flow.

Neither of these ingredients are listed under the name "dendritic salt". CTFA calls dendritic salt “sodium chloride”. So do we and so does everyone else in the free world. Does that make us unethical or liars or stupid? I sure hope not. We are, after all, abiding by the law. Funny thing is, the writer in question also sells dendritic salt. And they list the INCI name as “sodium chloride”. Period. What about that yellow prussiate of soda and the sodium aluminum silicate? Where are their ethics now? I mean, if you are going to issue an incendiary statement about how the rest of the world is lying and not disclosing or is ignorant about what they are selling, then perhaps you should be more careful of what is growing in your own backyard?

There are plenty of reasonable and effective methods to challenge CTFA and INCI nomenclature without slamming the rest of the industry. Contacting the CTFA comes to mind immediately. If that doesn’t appeal to you, or you think you may be rebuffed (doubtful), then look to other organizations for help. On the internet, the Environmental Working Group offers a free, searchable database of ingredients used in the manufacture of cosmetics and body and hair care. Called “Skin Deep”, it “pairs ingredients in nearly 25,000 products against 50 definitive toxicity and regulatory databases, making it the largest integrated data resource of its kind.” Don’t expect miracles, though. I ran several searches for ingredients well-known for use in preservatives, and got zilch in return. These things take time, and they are working on it. Click here to read more about how the EWG system operates.

Still unhappy? Take action at the EWG website! They offer a challenge to the INCI process in the petition form which is easy to complete and send along to your Member of Congress.

Laws and rules are created to protect us. They are not put into place to lend credence to unethical behaviors or measure the reliability of a certain product or vendor. Using an ordained process as an excuse to indict everyone who observes that process as a liar is unconscionable and inappropriate. The way to change the law is to get to the root of the issue, not to slander others.

What do YOU think?

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