******INCI ingredient labeling for products***** FDA web site link******

[Guest guest]

In response to:

" The proper way to label is with the Chemical name of ingredients in

decending order of predominance, and you can add the common name in

parenthesis after the chemical name.

This labeling info is stressed on ANY soap/toiletries list because

it the the legal way to sell a product. Selling without the

required labeling is Illegal. "

This is not quite true. As a Cosmetic Chemist and a doctor of

pharmacology I legally manufacture pharmaceuticals, Cosmetics and

toiletries. The FDA regulations on this are as follows:

" The ingredients must be declared in descending order of

predominance. Color additives and ingredients present at one percent

or less may be declared without regard for predominance. The

ingredients must be identified by the names established or adopted

by regulation; those accepted by the FDA as exempt from public

disclosure may be stated as " and other ingredients "

It is NOT a legal requirement to use " INCI - International

Nomenclature of Cosmetic Ingredients " names for ALL ingredients as

long as the ingredient in question has an acceptable or established

name, is unique and can not be confused with something similar. A

case where you WOULD USE the INCI name is for many botanical

ingredients because there are many sub species. An example of this

is Chamomile, you can't just list the word Chamomile in your

ingredient list because there are many varieties, German Chamomile

(Matricaria recutita), Roman Chamomile (Anthemis nobilis), Moroccan

Chamomile (Tanacetum annuum). A case where you can get away with NOT

using an INCI name is Aloe Vera because aloe barbadensis is used

99.9% of the time and it can not be confused with anything else. You

can CHOOSE to use all INCI names but you will not be fined or have

to fill out paperwork with the FDA if you choose not to use INCI

names on all ingredients.

She also writes:

If you find a commercial company without proper labeling it is

because no one has reported this company to the FDA yet, that's all.

But if they find out they will issue you a warning and then if it

happens again they will require you to cease and desist selling any

products and shut down your business, so why risk it???????

This is also not accurate. ALL large consumer products manufacturers

have lawyers on retainer to handle these issues and to make sure the

company is in compliance with ALL FDA requirements and regulations.

It is NOT a matter of no one reporting them so they get away with

it. They don't shut the business down, if there is a issue, the FDA

will fine the company and ask that they become compliant. This is

very rare as I said most companies have a staff of people to make

sure their products all comply with government regulations.

I hope this is clear to everyone.

Here is a link to the FDA web site for Cosmetic Labeling with

specific details on this and many other issues.

http://www.cfsan.fda.gov/~dms/cos-lab1.html

The main FDA web site for Cosmetic requirement information is:

http://www.cfsan.fda.gov/~dms/cos-ind.html

Dr. Lee C Brown, PhD, DPharm.

President

Fantastibath Naturals, Inc.

www.fantastibath.com (retail)

www.soapsrus.com (wholesale, private label manufacturing)

[Guest guest]

Dr. Brown,

Thanks for that detailed labeling information.

Can you tell us how you got started and became a cosmetic chemist?

I am in the process of getting my Masters from FDU in New Jersey.

Have you heard of their Cosmetic Science Program? I thought this was

a well rounded program that I could benefit from, instead of going for

a chemistry degree.

Trudie

>

> In response to:

> " The proper way to label is with the Chemical name of ingredients in

> decending order of predominance, and you can add the common name