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Misleading terms used to sell skin care products: natural, hypoallergenic, not tested on animals, organic, non-comedogenic, preservative-free, Vitamin E Oil.

Skin Care lies to the public that have been perpetuated for years by the large [and now the many small] cosmetics companies, to the point that most consumers assume these Marketing Terms are based on adherence to specific standards and/or backed by meeting scientific-based requirements - they are not - they are Marketing Terms. We are providing you with information, published, by the FDA, to inform you of the truth. The FDA is the regulatory agency that overseas the NAICS industry of Health & Beauty products, and as such determines which terms are, indeed, backed by science and testing, and those which are simply hype and puffery.

We believe it’s misleading and unethical to note these marketing terms to our customers. Our 70% repeat-customers already know much of this information –and we hope 10 years from now, all consumers will be educated about this and, thus, when they see the term, “natural” they will understand it is the same thing as screaming “will take 10 years off.”  We do, however, feel confident our unique products are the most free of unnecessary fillers you will find on the market: we do not add all the typical fillers, most products on the market contain, that are added, solely to “beautify” a products visual appeal.  Because of this, our products work fast and are effective. Additionally we use the highest-grade derivative for each ingredient we include in a product and forgo adding “sprigs of this-n-that” just to add to our label. Put another way, how many plants are white in nature: very few [ratio-wise]. If so, then why are all cosmetics normally white or turbid in color? Fillers! We’d much rather have a filler-free Bone-in, then eat SPAM every night.



The Marketing Terms, with no Official Standards, nor criteria to meet, per the FDA
http://www.cfsan.fda.gov/~dms/cos-safe.html [part of article pasted, below]

Non-comedogenic*
supposedly these products so labeled do not contain common pore-clogging ingredients that could lead to acne

Fragrance-free*
Products so labeled may still contain small amounts of fragrances to mask the fatty odor of soap or other unpleasant odors

Hypoallergenic*
Cosmetics that are less likely to cause allergic reactions



The Marketing Term, “Natural”—hype not science
http://www.cfsan.fda.gov/~dms/qa-ind7f.html [part of article pasted, below]
“The term "natural" has not been defined by the FDA . Certified Organic is defined for food-grade items, not cosmetics and skin care.



The Marketing Term, “Organic”—hype not science
http://www.ams.usda.gov/nop/Q&A.html#Definitions [part of article pasted, below] The Organic Foods Production Act and the National Organic Program (NOP) are intended to assure consumers that the organic foods they purchase are produced, processed, and certified to consistent national organic standards. The labeling requirements of the new program apply to raw, fresh products and processed foods that contain organic ingredients. Foods that are sold, labeled, or represented as organic will have to be produced and processed in accordance with the NOP standards.[Hod comment: Note: be clear the certification for organic is only applicable to FOOD grade items. Thus, if a product , like we do, has certified organic oils in it, that ingredient is can indeed be certified organic. But, if they even have a sprig of preservatives [which they would need to they want their product to have a shelf-life of more then 2-3 weeks [the time it takes oils to oxidize - a natural process] ] the final product they are selling is NOT organic, according the requirements that must be met in order to be a truly “organic product,” as NOP standards require. Additionally if there is any water in the product it cannot be labeled organic  [which as you already know is normally 90%+ of a typical OTC skin care product: read the label!]

http://www.ams.usda.gov/nop/Q&A.html
Water can not be certified as organic under the National Organic Program. Water is a chemical substance used in the production of agricultural products but is not itself an agricultural product. 



The Marketing Term, “Hypoallergenic”—hype not science
http://www.cfsan.fda.gov/~dms/cos-224.html
“Hypoallergenic cosmetics are products that manufacturers claim produce fewer allergic reactions than other cosmetic products. Consumers with hypersensitive skin, and even those with "normal" skin, may be led to believe that these products will be gentler to their skin than non-hypoallergenic cosmetics.” There are no Federal standards or definitions that govern the use of the term hypoallergenic." The term means whatever a particular company wants it to mean. Manufacturers of cosmetics labeled as hypoallergenic are not required to submit substantiation of their hypoallergenic claims to FDA....”The term "hypoallergenic" may have considerable market value in promoting cosmetic products to consumers on a retail basis, but dermatologists say it has very little meaning.”

http://www.cfsan.fda.gov/~dms/cos-safe.html
Anyone who has ever had poison ivy knows that "natural" and "hypoallergenic" are not necessarily interchangeable terms...”As a result of the decision, manufacturers may continue to label and advertise their cosmetics as "hypoallergenic" or make similar claims without any supporting evidence. Consumers will have no assurance that such claims are valid." . . . "Likewise, label claims that a product is "dermatologist-tested," "sensitivity tested," "allergy tested," or "nonirritating" carry no guarantee that it won't cause reactions.” "Hypoallergenic can mean almost anything to anybody," says Bailey. ..."Hypo" means "less than," and hypoallergenic means only that the manufacturer feels that the product is less likely than others to cause an allergic reaction. Although some manufacturers do clinical testing, others may simply omit perfumes or other common problem-causing ingredients. But there are no regulatory standards on what constitutes hypoallergenic. FDA tried to publish regulations [in 1975] defining hypoallergenic to mean a lower potential for causing an allergic reaction," says Bailey. "In addition, we were going to require that companies submit information to FDA establishing that in fact their products were hypoallergenic." However, two cosmetic manufacturers, Almay and Clinique, challenged the proposed regulations in court, claiming that consumers already understood that hypoallergenic products were no panacea against allergic reactions.


NANO TECHNOLOGY
Nano-Technology is the engineering of particle on an extremely tiny scale: between 50,000 and 100,000 times smaller then the width of a human hair. On paper the potential is captivating. Tiny particles can pass through the body without being digested and vitamins are more easily absorbed. However, this capability is also causing some concern from scientist questioning the new capabilities and unknown risks to human health. “The human body hasn’t ever encountered nanoparticles before,” says Ronnie Cummins, national director of the Organic Consumer Association (OCA). In the UK> organic certification is refused for any foods that contain engineered particles smaller then 125 nanometerics. Here in the USA, the OCA is petitioning the FDA to enforce similar restrictions. Still in the USA cosmetic companies are jumping on the band-wagon and the Environmental Working Group (EWG) has identified more then 9,500 personal care products that contain nano-particles: with zinc-oxide based sun screens leading the charge. Companies are no currently required to indicate nanoparticles on labels. If your sun screen is invisible on your skin, it probably contains nano-scale zinc or titanium.

“The biological effects of nanoparticles may be different than those of larger sized particles, therefore, it is crucial to develop appropriate toxicity testing approaches for the safety assessment of nanoparticles . . . ”
http://www.cfsan.fda.gov/~frf/forum05/J-58.htm

Also, “. . . ADVANCE \d 5when in nano-size particle form may affect immune functions . . . ”
http://www.cfsan.fda.gov/~frf/forum06/B-85.htm


DECODING THE COSMETIC LABEL
The Ingredient Label is the only thing a consumer should look at: this area is rigorously regulated by the FDA. But, as you will see by reading below, some labels are even confusing for the FDA to understand
http://www.cfsan.fda.gov/~dms/cos-labl.html
“Ingredients are listed in descending order of predominance, that is, with the ingredient present in the greatest amount listed at the beginning and those present in the smallest amounts listed at the end. I. How can you be sure your shampoo that claims to have all natural ingredients does not also contain some synthetic chemicals? Or that your hand lotion actually does contain the vitamin hit claims? The logical response should be, "Read the ingredient label on the back of the product." Logical, if you happen to be a chemist or a cosmetic scientist. Perplexing, if you are the average cosmetic consumer. John Bailey, Ph.D., director of the Food and Drug Administration's Office of Cosmetics and Colors, understands such consumer dilemmas. He and the scientists on his staff admit that most of us don't recognize the names of the ingredients listed. But there's no way to change that and still accurately identify the ingredients”



The Misleading notations of “Cruelty Free--Not Tested on Animals”
http://www.cfsan.fda.gov/~dms/cos-safe.html
Whether driven by altruism, liability, or the bottom line, most companies see the need for safety testing. But safety testing can rarely be mentioned without bringing up the controversy surrounding the use of animals for those tests. Many companies have begun to label their products with statements indicating that no animals have been used in testing. "As far as we know," says Neil Wilcox, D.V.M., director of FDA's Office of Animal Care and Use, "what these companies do is use, for the most part, old reliable ingredients that have been proven safe [based on past animal data and a history of safe use] and then tests the final product on people." "There's kind of a fine point here," says CTFA's McEwen. "These companies that say they don't test on animals are skirting the issue. Practically every ingredient that's used in cosmetics was at some point tested on animals. Probably a statement like 'no new animal testing' would be more accurate.”

http://www.cfsan.fda.gov/~dms/cos-226.html
“Some cosmetic companies promote their products with claims such as "CRUELTY-FREE" or "NOT TESTED ON ANIMALS" in their labeling or advertising. The unrestricted use of these phrases by cosmetic companies is possible because there are no legal definitions for these terms.  Some companies may apply such claims solely to their finished cosmetic products. However, these companies may rely on raw material suppliers or contract laboratories to perform any animal testing necessary to substantiate product or ingredient safety. Other cosmetic companies may rely on combinations of scientific literature, non-animal testing, raw material safety testing, or controlled human-use testing to substantiate their product safety. Many raw materials, used in cosmetics, were tested on animals years ago when they were first introduced. 

Preservatives: Your Best Protection
There is a common misconception that “natural” is good and preservatives are bad. In fact, the health risks of an unpreserved product are far greater than those of using a preservative at a low percentage. Preservatives prevent the growth of bacteria and mold and many natural skin friendly preservatives are now available. 



Vitamin E Oil information – IU’s Alone Mean Nothing
Pure Vitamin E Oil is exceptional for healing. Unfortunately most consumers do not get Vitamin E oil when they order it: 99% of the time they get filler oil [referred to as a "carrier oil”] and very little Vitamin E oil. Thus they may, erroneously, assume Vitamin E oil isn't as GREAT for healing as it actually is: because what they used wasn’t even close to real Vitamin E oil: they got filler-oil! In order to figure out if you are getting pure Vitamin E oil, the most important thing to do is to convert the IU’s to a gram measurement. IU’s, in regard to Vitamin E oil, is supposed to be measured in grams. Unfortunately, often companies, knowingly, list in ounces, liters, etc, so that it appears the product has a very high IU’s. Any ethical company will list in IU’s/gm, the scientific standard for measurement, without the need for the consumer to convert.

Here is how you can figure it out: We commonly see a 2oz * 30,000 IU’s product, sold as, “Vitamin E oil.” Our IG’s contain Vitamin E oil with 1,305 IU’s/gm. Here’s the math:

1oz = 28 gms, thus the company above with a 2oz has 56 gms [28gms*2]

If they have 30,000 IU’s in a 56 gm product, then they have 533 IU’s/gm [30k/56], meaning only 40% of the product is actual Vitamin E oil and 60% is a filler/carrier oil.

Now, on the other had, if we used this companies method of denoting IU’s in ounces, our Vitamin E oil, in a 2oz size, it would contain 73,080 IU’s [56gms[2oz]*1,305IUs].

When you contact the company to point this out, the common response will be that Vitamin E oil is too thick to pour and it needs “carrier” oil. It is true that is labor-intensive to pour, due to its thickness. But, but don’t you think if they are selling a product with only 40% Vitamin E oil, and the rest [60%] is a filler oil, ethically it should be called, “60% Filler oil w/ 40% Vitamin E oil.” Why do companies do this: the same reason they call their products, “hypoallergenic,” “natural,” etc – profits.. Who has the time to figure this all out on our own: when we buy a product called, “Vitamin E oil,” we trust the company is selling us Vitamin E oil. When we buy a product called, “organic,” we assume the product has meet some sort of standards. When we see “not tested on animals” we assume the company knows what it’s talking about. We could go on and on, but we don’t’ want to bore you anymore! If you desire more information a great read is the book, Cosmetics Unmasked, by Dr. Stephen & Gina Antcza.




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