Defending Free From … Again

‘Free From’ labelling is based on fear. So declared a cosmetics industry panel at a summit last year, as reported in Cosmetics Design Europe last month.

No, we countered in response. ‘Free from’ messaging is vital to those with allergies, or environmental, ethical, religious or other personal considerations. The problem is with the misuse of ‘free from’ – ‘free from toxins’, for example.

We were glad Cosmetics Design Europe picked up on it, and asked us for comments for a follow-up article, which appeared here.

It’s not the first time we’ve dealt with this issue, and some tweets from chemists in recent days about our FreeFrom Skincare Awards – which open on 1st February – gave us cause to revisit the subject.

“The words “free from” in your award create alarmism,” one told us. “It implies the ineligible items are harmful.”

Does it? Does the so-named “free from” aisle in the supermarket create alarmism, and does it imply that wheat, milk, eggs and peanuts, rarely to be found there, are harmful?

“… allowing known allergens detracts from the “Free From” claim,” said another. “Your award is misleading to thousands of people who have those specific allergies.”

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A free-from aisle – not free of allergens

This was a reference to fragrance allergens and food allergens permitted in our awards. Yet it’s impossible to exclude all potential allergens – few products would be eligible. Minimal use of allergens is just one quality we look for. Others – such as effectiveness, VFM, labelling, innovation, versatility – are listed here. This means that, yes, products with allergens do win awards – reflecting strong performance in other areas.

That may seem strange to outsiders, but it’s not strange to those who live ‘free from’ lives, who understand not all ‘free from’ products are suitable for them – but that they are more likely to meet their needs. To continue the analogy: the milk allergic individual must still check the labelling of a product at a ‘free from’ aisle, because it may only be free from gluten and not free from dairy too – yet knows that he is more likely to find a product suitable for him here than elsewhere in the supermarket.

‘“Free from” claims are truly unnecessary’
So says a short-sighted article we were directed to during our Twitter dialogues.

The argument here being that those avoiding certain ingredients need only read the ingredients list in order to determine whether they’re present.

Easy to say that, if you’re not someone who routinely has to do it whenever you go shopping …

Consumers are neither chemists nor fluent in Latin. Long lists of obscure ingredients are hard work. I suppose you could memorise that juglans regia/nigra is walnut, that prunus amygdalus dulcis is almond and all the other nuts – and ingredients – you may need to distinguish. But I find it difficult to process the lack of sympathy from one who’d begrudge a ‘free from nuts’ message to help an individual in this case.

“To proclaim any particular material as being absent implies that there is a reason for its exclusion – because it is not safe” reads the article, “and, therefore, by implication, any product that DOES contain that ingredient is also not safe.”

What surprises me here is that those who (rightly) invoke science, scientific method and research to add weight to their position on ingredient safety, appear less keen to do so to support claims that ‘free from’ is necessarily about scare tactics, or that consumers are being misled and alarmed. Constantly objecting that ‘free from implies the ingredient is unsafe’ fails to make it so. Sceptical chemists and critics seem oddly determined to will this statement towards truth via repetition and dogma.

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‘Fragrance Free’ – why is this a problem for some?

Those familiar with the concept of ‘free from’ don’t infer non-safety from it; if others do, then the solution is education, and we’re happy to be a part of it. ‘Vegetarian friendly’ – essentially a ‘free from meat / fish’ message – is understood, and not interpreted to mean flesh is dangerous. Why is this acceptable and others not? What would detractors prefer on already busy labels? ‘Friendly to those with fragrance allergies’ – or ‘fragrance free’? If the wordier former – why?

Safety is not all that matters
‘Science has determined safety so stop worrying about ingredients’: this is what critics and the mainstream beauty industry appear to be saying, a position which assumes safety is the only concern to all consumers, and by logical consequence that all permitted ingredients are somehow equal.

The processed food industry uses a similar tactic to market junk. They do it by indulging myths such as “there are no good nor bad foods” and reassuring us that all food ingredients are fit for consumption (I’m sure they are). Don’t know about you, but I hold that banana and a fillet of salmon are good foods, that a packet of sherbet dips or tub of margarine are not good foods, and do not wish to routinely consume trans fats, saccharin, or high-fructose glucose syrup, for instance – because I want to eat what I consider to be better. Likewise, some natural skincare afficionadas want to consume cosmetics they consider to be better too: and if that’s manifested in a preference for essential oils over artificially synthesised parfum compounds (which we also exclude) (and which to my nose often honk to high hell), then we understand.

If the mainstream subscribes to this notion of ‘equal’ ingredients, for me it begs a question: why don’t cosmetic brands list more of them on front of pack? And why don’t critical observers pull them up on this apparent reluctance?

Nivea namecheck argan oil on this product, and Pantene do likewise on this. Why don’t Nivea put methylisothiazolinone on the front instead – perhaps alongside an image of its pentagonal isothiazolinone ring, which of course consumers will understand because they’re expected to be chemists – and why don’t Pantene likewise declare silicones, alcohol and parfum – which come before argan oil in the list of ingredients, so just imagine how little of that prominently displayed botanical is actually present?

And it’s the ‘free from’ cosmetic community who are accused of misleading?

Free from: here to stay …
‘Free from’ folk buy products outside the ‘free from’ aisle as well; they buy cosmetics in Superdrug and Boots too. We’re not against the existence of mainstream cosmetics in much the same way that, I don’t know, the MOBO awards are not against the premise of One Direction, to pluck an alternative comparison. This is not ‘us versus them’. The typical high street skincare product is just not what we’re about.

But we work with other ‘free from’ awards, and know dozens of people with specific dietary and product needs. Something we hear time and again in their voices is tiredness at having to constantly justify choices, defend needs, and the right of easy access to information. ‘Oh you’re just going gluten-free to lose weight’ many a young coeliac woman is told. ‘Can’t you just open a window?’ – to the person with a fragrance allergy to air freshener. ‘We’re not sure which allergens are in your meal’ – to the sensitive diner.

Opening 1st February ...

Opening 1st February …

FreeFrom is small, but getting less small. The community is in the minority, but growing, and here to stay. We run niche awards. The EU, we keep being told, often with undisguised relish, is going to crack down on ‘free from’ claims – something we hear is already happening in a couple of European countries.

If this escalates, if the enforcers come after ‘free from’, while turning a blind eye to the larger cosmetic companies for their questionable marketing methods, it is, I fear, going to start to feel like bullying to some in the ‘free from’ community. We’ll protest it if we have the resources, adapt to it if we have to, and support folk where we can. But ultimately we’d rather industry found it in itself to accept at least some ‘free from’ labelling – and produce independent research on its supposed detrimental impact on public perception of cosmetics. Not too much to ask?

47 Comments

  1. Joanna White

    Well said! Free from is so important and useful for those who have allergies/sensitive skin. Thank you for standing up for the free from community and supporting those who value it.

    Reply
    1. Alex (Post author)

      Thanks, Joanna – appreciated.

      Reply
  2. John

    I don’t agree that ‘free from’ is relevant to cosmetics in exactly the same way it is to foods. There are clear dietary needs that justify ‘free from’ aisles (nut allergies, lactose intolerance etc.) in products we eat or drink, hence those aisles in stores. Many/most of those are not relevant to topical products.

    Comparing to cosmetics isn’t quite the same. It’s interesting that you exclude fragrances, given they are the source of the main allergens found in cosmetics (other than preservatives, but then again most ‘natural preservatives’ are based around fragrances). ‘Free from synthetic fragrances’ is a claim used all over the market for products often containing high levels of essential oils (which naturally contain allergens), sometimes at worrying levels.

    As a side note…. most people who think they have ‘sensitive skin’ actually don’t. It’s only a very small number (i.e. less than 5%) of the population that really do have sensitive skin. Fear marketing contributes to a lot more people believing they have.

    So putting ‘free from’ for relevant topical allergens aside, it leaves ‘ethical’ considerations. Again, no issue with this as a concept, but it can be so misleading. ‘PEG-free’ because petrochemicals may contain toxins for example? That’s a load of rubbish as cosmetic-grade petrochemical ingredients are incredibly pure (or wouldn’t be permitted). Or is it ‘PEG-free’ in favour of something deemed ethically better? If so, why? What is the actual message to the consumer, or is it left for the consumer to decide? It’s such a woolly area. Do products listing 5-6 different items they are ‘free from’ help the consumer with clear messages or simply infer they are better/safer as a result of what they don’t contain? That’s a debate that can never be concluded without evaluating every product in question, but is the basis of industry concerns.

    Lifestyle choices are of course also relevant, but as you say – ‘Vegetarian friendly’ doesn’t need a ‘free from’ descriptor.

    One genuine recommendation is that you put one or more Chemists / product formulators on the Judging panel. Why? Because they will evaluate the products on what they are, not on the ‘free from’ claim.

    Finally just a quick response to your comment about Nivea, that’s a fight against marketing in general. Now there’s something I would absolutely back…. awarding products based on quality and using meaningful levels of claimed ingredients, not on making claims just because certain ingredients are in there (or not in there in the case of your awards). Go for it, that’s a far better idea for a set of awards!

    Reply
    1. Alex (Post author)

      Hi John,

      Not sure I was claiming equivalent relevance between food and skincare, merely drawing a straightforward analogy. No, no relevance for lactose intolerance eg – but skincare has its own allergic considerations – fragrances, for example, which aren’t relevant to food.

      Not sure what you mean re: excluding fragrances. We don’t exclude them. We do give credit to products which minimise them. As I said, it would be impractical to exclude them – there’d be too few products eligible, and not everyone needs to worry about fragrance anyway.

      PEGs – we do permit them for preservation. You’d have to talk to those carrying PEG-free messaging, I guess, to understand why. We don’t often see it.

      We do have formulators and ingredient experts on the panels. During judging, what is in the product forms, I’d guess, around 80%+ of the conversation. I think you’re perhaps reading too much into the name of our Awards here – and perhaps this applies to how you’re viewing us, generally.

      Our Awards are based on quality – we use six testers for each product, testing for a month – which is unheard of in the industry. Some Awards award on the basis of voting for products voters may not even have seen, let alone tested. We think we’ll stick to what we’re doing!

      Thanks for your thoughts – Alex.

      Reply
  3. Sarah

    As you know Free From is both important to me for food as it is for skincare. A free from label on the front of a bottle can attract my attention, it will make me want to pick up the bottle and then I will take time to look at the full ingredients. I am actively avoiding ingredients for ethical and medical reasons, anything which can help me determine the best products to use is a good thing where I am concerned.

    Reply
    1. Alex (Post author)

      It’s that straightforward, isn’t it? It’s helpful for people like you – and it’s not relevant for other people who have no ethical or medical (or other) issues – it’s as simple as that. Thanks for commenting, Sarah.

      Reply
  4. Sue

    As a conscious consumer and a mother I think there needs to be far more free-from labelling – there are many things I tried to avoid during pregnancy, and still do and avoid in my kids products. Breast Cancer UK do a really handy guide (http://www.breastcanceruk.org.uk/reduce-your-risk/ ) and its one of the things that I use when considering purchases, but knowing up front whether a product has parabens, BPAs, Aluminium, Triclosan etc does/would really help making shopping so much easier. We also have to consider allergens and dietary preferences like non-diary or vegan and the more free from labelling the better for us. If I’m not comfortable a product is going to do us good, we do without and if its just not made clear in the packaging I won’t buy it.

    Reply
    1. Alex (Post author)

      Making shopping easier for those who have to avoid certain ingredients is the real value of ‘free from’ labelling. It’s their first consideration – before what is in the product, they need to know what’s not in it, before proceeding with considering the purchase. I think some people who don’t live ‘free from’ lives don’t appreciate this – simply because they’ve never had to actually ‘live’ it in practice.

      Reply
  5. Perry

    I’m confused about what you mean by “free from” or maybe I don’t understand what your audience thinks you mean.

    On the one hand you say that claiming ‘free from toxins’ is a misuse of the ‘free from’ label. You say free from claims educate people about allergens.

    But then you allow allergens. So allergens might be a factor in your decision about “free from”, it just isn’t the most important factor. What is? How many people does an allergen have to affect before it makes it to your banned list?

    Then when Sue says in the comments above that she avoids ingredients because she mistakenly believes that products which contain parabens or BPA’s or Aluminum will increase her breast cancer risk (they won’t), you do nothing to correct her. Instead, you encourage her chemophobia. You say you are making it easier for people to find products that reinforce there mistaken beliefs. That seems to be what the “free from” awards are really about.

    You need “proof” that ‘free from’ claims don’t imply safety? That’s some anecdotal evidence right there. Poll your own audience and ask them how many of them think “free from” products are more safe. What would be the outcome of such a poll?

    I respectfully disagree that “free from” claims have no connection to chemophobia. There are any number of ingredients that cosmetic marketers could say they are “free from” but they don’t.

    For example, “free from” marketers don’t make claims about unknown cosmetic ingredients like “free from glyceryl stearate” or “free from sucrose laurate.”

    Marketers choose to call out ingredients that resonate with consumers. And the reason ingredients resonate with consumers like Sue is because of chemophobia.

    Marketers say “paraben free” because they know some segment of consumers are afraid that parabens cause breast cancer. We both know that parabens don’t cause breast cancer.

    Marketers claim “sulfate free” because they know some segment of consumers are under the false impression that sodium lauryl sulfate causes cancer. It doesn’t.

    And all the other “dirty dozen” cosmetic compounds are called out as “free from” because marketers know some segment of consumers like Sue are afraid of these ingredients. It’s not allergens, it’s fear.

    If consumers had never heard scare stories about Triclosan or BPA or parabens or silicones or most of the other ingredients on your “free from” list marketers would not be calling out these ingredients in their marketing.

    Also, your analogy with eating bananas versus processed foods is flawed when applied to cosmetics. ALL cosmetics are processed. There are no skin lotion bushes or shampoo trees. There is no equivalent non-processed cosmetic. A more accurate comparison would be between a Coke versus a Diet Coke.

    Finally, I agree with you that the mainstream cosmetic marketers use misleading claims. In this way they are no different than the “free from” marketers who also use those types of claims. They are both misleading. But I do see a difference in “free from” claims versus feature ingredient claims.

    1. Feature ingredient claims say “buy my product because this ingredient makes my product special.”

    2. Free from claims say “buy my product because it doesn’t have a scary ingredient that my competitors who don’t care about your safety put in their product.”

    I agree with John, let’s celebrate formulas with superior performance. That seems a more appropriate option than celebrating products that pander to erroneous beliefs.

    Reply
    1. Alex (Post author)

      Hi Perry,

      ‘Free from’ toxins is a misuse of ‘free from’ because toxicity is dependent on dose, and no ingredients are permitted in cosmetics at levels that would ordinarily be toxic.

      As I have explained in the post, we allow allergens because so many ingredients can be allergens, so it would be unfeasible to disallow all. We disallow some – such as peanut and MI – which are of particular concern to many with severe allergies.

      I have also said in the post that there are many factors on which we judge – allergen issues are merely one.

      The ‘banned list’ was decided upon originally in 2011 when we met with various consultants and has been tweaked occasionally in the intervening years. The idea was never to give an exhaustive list or to have a ‘qualifying threshold’ of affected people above which we would ban. We couldn’t make it too long (possibly too difficult for entrants to easily determine whether their products would meet the criteria) nor too short (we felt we had to make the Awards meaningful in excluding quite a few of the ingredients people look to or need to avoid) and so we settled on what we settled on. As I said, it’s always subject to review and no doubt we will review it again.

      Sue left a number of comments – these included on our previous blog, and you’ll find a more direct response re: our position on parabens there.

      I have no idea why we should poll our audience in order to attempt to demonstrate critics’ claims. The burden of proof is not on us – it is on sceptics who are making the claim that we are misleading.

      No, SLS doesn’t cause cancer – but many people choose to avoid it as they find it an unpleasant ingredient to use.

      Some people prefer coke to diet coke ….. Shouldn’t they be told which is which? (eg via ‘free from sugar’).

      ‘Free from’ claims say different things to you than they say to people who need ‘free from’ – this should really be apparent from the post. I’m not sure I can explain it any better to help you understand, I’m afraid.

      Our Awards do celebrate formulas with superior performance. We submit products for month-long testing – no other Award we know of undertakes this level of testing.

      Thanks for such interesting comments!

      Alex.

      Reply
  6. Dene Godfrey

    As the author of the “short-sighted article” cited in your piece, I feel obliged to observe that you failed to address many of the points raised in that article:

    1) Sometimes the “free from” ingredient is not even a cosmetic ingredient.

    2) Cases where companies claim “free from” but the substance is actually present (especially in the case of “free from chemicals”!).

    3) “Paraben free” claims in products where parabens would never be used (nor any other preservative)

    Your criticism of the suggestion that consumers simply check the INCI list is unjustified in my view. The entire point of the INCI labelling system is for consumers to be able to identify ingredients with which they have a problem. Littering the pack with “free from x, y and z” is unnecessary additional information (and ironic when you consider that consumers often complain that there is TOO MUCH information on the packs). A product that is labelled “paraben free” may still contain something to which many consumers are allergic. This kind of labelling only satisfies the chemophobes to whom Perry referred earlier, and the vast majority of these people do not have the first understanding of chemistry or toxicology. “Free from” feeds on this ignorance and irrational fear and is pure negative marketing.

    An earlier commentator claimed that she only took the time to read the INCI list when the product already contained a “free from” message. I fail to see the point in this discrimination. So many products already do not contain any given “victim” of the “free from” campaign; the vast majority, in fact, so she may as well look at ANY product listing. For example, fewer than 25% of cosmetics now contain methylparaben, yet only a tiny proportion are labelled as “free from parabens”, so the majority of products on the market don’t contain parabens anyway.

    In my experience, many of the companies using “free from” are often wrong, especially in the case of “petrochemicals” and “chemicals” (surely one of the single most ridiculous claims possible). “Free from petrochemicals” is more often claimed falsely than not because those making the claim do not fully understand what they are talking about (or think that they can get away with the false claim).

    If you think that “free from” claims don’t give the majority of consumers the impression that the ingredient is unsafe, then you clearly haven’t seen the number of people who say “well, if parabens are safe, why do so many companies sell “paraben free” products!

    I see fragrance free as a different, and separate issue but, in general, “free from” claims are largely redundant and misleading and, far too often, downright lies.

    I am sure that you will disagree, but it is telling that Canada, France and South Africa all have industry codes of practise that prohibit such claims.

    Reply
    1. Alex (Post author)

      Hello Dene,

      Thanks for stopping by.

      Regarding 1), 2) and 3) – we have addressed 2), a number of times. When we encounter these in our Awards, it does count against entrants, although 1) and 3) are rare. We give feedback to entrants when we feel they misuse free from terminology or use alarmist terms – like free from toxins / chemicals – and in this way we aim to improve its standard of use in industry.

      If you have concerns about companies’ ‘free from’ labelling – then perhaps tell them about it? We do when we have some. We have constructive dialogues with many.

      Perhaps not, no, we haven’t been much exposed to those who say ‘well, if parabens are safe, why do so many companies sell paraben free’. But then, if you think ‘free from’ claims are redundant, then you perhaps haven’t had much to do with the many with allergies and others who want or need to avoid certain ingredients nor spoken to them about how useful they find such labelling. We have. We exhibit at the Allergy Show annually, meet dozens of such individuals, receive emails from our readers. But I guess we all move in different circles, and this shapes our viewpoint, doesn’t it.

      Perhaps it’s unintentional by all parties, but it’s a real pity there seems to be little regard for the ‘free from’ customer’s point of view from your side of this debate – exemplified this time by the questioning of allergic consumer Sarah’s approach to negotiating labelling in cosmetics – and it strikes me as ironic that you expect those “who do not have the first understanding of chemistry” to obtain what they need from the ingredients list.

      All the best,

      Alex.

      Reply
      1. Dene Godfrey

        Hi Alex,

        Thanks for taking the time to respond to my comments.

        Point 2 was not covered in your article, so I had no way of knowing that you address this issue!

        I challenge the view that allergy sufferers find “free from” labelling useful to any practical extent, despite the feedback you may have received from such people. The most frequently employed “free from” ingredients are the parabens. Parabens are among the least frequent causes of allergy within the group of cosmetic ingredients that have such a (tiny) potential issue. Only a miniscule proportion of the population are allergic to the parabens (less than 1% of dermatological patients, which represents a far smaller proportion of the general population; probably significantly less than 0.1%). Given that a significant percentage of claims are for “free from parabens”, this is a totally disproportionate response, and even more inappropriate when you consider that the “free from parabens”trend bears no relation to allergic responses, but to the scaremongering generated as a result of the publication of an extremely poor scientific paper that has (mistakenly) been used to claim a link between parabens and breast cancer.

        Making “paraben free” claims is of virtually no benefit to allergy sufferers. There are probably more than 50 reasonably common ingredients used in cosmetics that have a much greater potential than parabens to illicit an allergic response (but still only in a tiny percentage of the general population), so labelling “paraben free” does nothing for the majority of allergy sufferers and, (once more), given that “paraben free” constitutes the majority of “free from” labelling, then it follows that there is little true benefit to those who suffer. Allergic reactions are almost always specific to one compound (or closely related groups of compounds) so, to be genuinely of use to sufferers, EVERY potential allergen should be labelled as being absent in order to properly justify the use of such claims. That is completely impractical, of course.

        The recent explosion in skin reactions to methylisothiazolinone (MI, or MIT) has reached a response rate of more than 10% among dermatological patients, yet the “MIT free” claim is relatively rare (as far as I am aware, although that may have changed more recently).

        It is ironic that a major UK “health” chain massively promotes fear over parabens and SLS by having posters making “free from parabens and SLS” claims all over the store, yet the majority of their personal care products are preserved by a formaldehyde donor which, in the view of most chemophobes, is even more of an issue. (Personally, I do not subscribe to this view, but I would guess that the “anti-chemicals” lobby would view formaldehyde donors with great suspicion.) Incidentally, I once asked people to visit various stores within this particular chain and to ask them why they were promoting paraben free products. In three cases my “spy” was told, unequivocally, that parabens cause cancer. (I only had 4 responses – a worryingly high rate of scaremongering and disinformation!) THIS is the level of dishonesty and fear promoted by “free from” claims in some (admittedly, the worst) instances.

        //and it strikes me as ironic that you expect those “who do not have the first understanding of chemistry” to obtain what they need from the ingredients list.//

        There is no irony here whatsoever. My comments regarding the lack of understanding of chemistry refer to the people who read nonsense on the internet and believe it to be true, because they don’t have the required level of understanding to separate the wheat from the chemophobic chaff. No understanding of chemistry is required to obtain what they need from the ingredients list; only accurate information from their dermatologist and the ability to read! I will concede that some INCI nomenclature can be intimidating for the non-chemist, but if your dermatologist tells you to avoid methylisothiazolinone, it should be fairly easy to spot it in the ingredient listing, even if you can’t pronounce it! The INCI system may not be perfect, but “free from” is an extremely blunt instrument that largely misses the target, and has unintended (?) consequences.

        In summary, only a tiny minority of potential allergens are included in “free from” claims, and the only way to avoid an allergic response to something for which you have already been diagnosed as being allergic is to read the INCI list. The majority of “free from” claims mislead the majority of people into believing that they are better off avoiding those particular ingredients, when this is not the case.

        Cheers

        Dene

        Reply
        1. Alex (Post author)

          Hello Dene,

          I feel we’re rather going around in circles now. Free from claims aren’t only about allergens – but environmental, ethical, religious sensitibilities too – and indeed often just a matter of personal taste (I avoid SLS because it’s foamy – but personally have no safety concerns over any cosmetic ingredient whatsoever).

          The parabens issue is a problematic one, I know, and we share your view that there is insufficient evidence of their non-safety. I think we included them on the exclusions initially because they were on all contact dermatitis panels that we looked at, and we do have readers with parabens allergy, but it is something we will review.

          A message such as ‘free from petrochemical derivatives’ or ‘ … artificial fragrance’ can be useful to those who wish to avoid such and who are unfamiliar which ingredients are, or aren’t derived from such sources. This cannot be gleaned from the INCI. (We often have to ask for clarification / evidence ourselves.)

          Yes, MI allergics can look for methylisothiazolinone in the INCI, but similar sounding ingredients can confuse, especially the newly diagnosed. I remember a query from a reader worried that ‘methyl stearate’ (or something like that; I forget) was MI under a different guise. A food example of this, just to illuminate my point better: maltodextrin confuses those avoiding malt (barley / gluten); and hence ‘gluten free’ helps reassure and inform.

          The gluten analogy, I think, is a good one, actually. Diagnosed coeliacs in the UK, who have to avoid gluten? 0.25%. Percentage of people who fear gluten and think it’s ‘bad’? I imagine into the 20-30% range. Reason to ban ‘gluten free’ labelling on food? No. Reason for education, instead.

          That’s rather how we view skincare, but I can see we’re never going to agree.

          All the best,

          Alex.

          Reply
          1. Dene Godfrey

            Hi Alex,

            If the world were a simple place, then I would possibly agree with your comments regarding environmental and ethical considerations, but I don’t see much good evidence that these claims help with any accurate information. The “petrochemical free” claim is often accompanied by false claims about the dangers of petrochemicals; usually with further misleading claims about the safety of “natural” ingredients. I understand the desire of some people to be environmentally responsible, but I suspect that the carbon footprint of aloe vera transported all the way from Australia to the UK may be greater than a petrochemically-derived substance manufactured in Europe and used in Europe. It is by no means clear cut, and it not properly addressed with the catch-all “free from” tag. The association of this particular claim with the disinformation about the safety of petrochemicals doesn’t help either!

            What ethical considerations are addressed by using “free from” claims?

            I see no justification for any negative claims for religious reasons; the more positive “halal” or “kosher” label would be far more specific and accurate, surely?

            The use of negative claims works against the industry and causes confusion and misunderstanding in far too many instances.

          2. Alex (Post author)

            Hi Dene,

            But disinformation is a separate issue, to us. ‘Free from petrochems’ is a mere statement of fact. ‘Free from petrochems (which are dangerous)” is not. Again it seems to come back to the misuse of ‘free from’ terms, which I’ve commented on already.

            No, environmental issues may not be ‘properly addressed’ by ‘free from’ – but I struggle to see why it should be expected to be a panacea?

            Yes, Halal and Kosher can be great – as can Vegetarian and Vegan – but some manufacturers may not want to directly name particular such personal beliefs and sensibilities directly (for whatever reason) and prefer the option of ‘free from alcohol’ or ‘free from animal derivatives’ or whatever they like. We think that should be open to them, although we have no personal preference on this front.

            A.

  7. Sarah

    in reference to the comment made by Dene, I actually said that the labelling entices me to pick up a product compared to a competitor, I see no harm in that. Every product on a shelf has a “tag line” something which attracts your attention. For example, when you select shampoo you are looking for key words on the front of a bottle, is it suitable for my fine hair, will it protect my colour etc, I view “free from” labelling in the same light. I have to double check INCI on every product due to my allergies but that can be tiresome so if someone wants to make my life a little bit easy then I welcome the shorten list.

    Reply
    1. Dene Godfrey

      // I actually said that the labelling entices me to pick up a product compared to a competitor, I see no harm in that//

      EXACTLY! That is why they use this insidious type of labelling; it’s not to make the consumer more “safe”, it’s to try to gain an advantage over competitors, and you are falling for the trick!

      I am sorry to hear that you suffer from allergies, but it is unlikely that you are allergic to parabens, for example (please correct me if I am wrong). The vast majority of “free from” claims relate to parabens, so how does this claim help you? Even if you are allergic to three different cosmetic ingredients, if they are not the ones highlighted as being absent, you have to look at the ingredient list. Please also see my response to Alex, where I have addressed this in more detail.

      Reply
      1. Sarah

        Perhaps I fail to articulate myself but I most certainly don’t fall for marketing tricks and to imply otherwise feels like an insult. Free from claims go far beyond those of parabens. I don’t think you understand the convenience of a free from label perhaps because you don’t live with allergies?

        Reply
  8. Dene Godfrey

    There is no reason to feel as though you have been insulted – most people are fooled in some way by marketing strategies, and I certainly don’t exclude myself from this.

    I am aware that “free from” claims go beyond parabens, but they are an excellent example of the misuse of such claims.

    I don’t need to live with allergies to understand the point about “free from” claims, but you have not addressed my point about making a “free from” claim for one substance when it is not the substance to which you are allergic. How is that useful? In order to avoid the substance to which you are allergic, you either have to rely entirely on finding a pack proclaiming the absence of that specific ingredient, or you have to look at the ingredient lists. There are few other ingredients specified as “free from” on packs, aside from parabens and more general claims such as “petrochemicals”.

    Reply
  9. Chris Gummer

    First, let me set out my stall. I agree free-from claims have a place and can be invaluable to some consumers. I also agree that education is essential for all people at all levels of expertise. I am also a consumer and make some often odd and barely rational purchase decisions. And I’ve been around the cosmetics business for a long time.
    The Skin Matters Free From awards present an interesting concept and, by and large, I think it’s a good idea as long as the award doesn’t overtake the need to educate. And it is here I have a concern. Like any consumer I was interested to see who won and who got a mention. The results for runners up directed me to Pai products. A new company for me but a good looking web site. Someone has obviously taken the time to draw a good balance between marketing their products and being conservative about their claims. In short, I like what I see and want to learn more.
    In stark contrast is the Best Free From Skincare product of 2015. The product takes me to the website where the ingredient philosophy is “We don’t use harsh synthetics – many of these man made, and cheap ingredients have been linked to hormone disruption and are known carcinogens and skin irritants. You will NEVER find any such ingredients in our products and that includes Parabens, Phthaltates, Artificial colourings and Fragrances, SLS, DEA’s, PEG’s, Mineral oils & Petrochemicals.” and “We never test our products on animals – We use healthy & happy human volunteers for that!”
    It is the latter approach to free-from claims that does a disservice to both the consumer and the cosmetics industry as a whole, and we are all part of the same industry. The claims made are misleading, scaremongering, and do not comply with advertising codes. It is, therefore, a pity that the awards chose a product underpinned by such a misleading approach to consumer education.
    I would ask that when considering products for awards, Skin Matters takes a look at the company philosophy in order that we can all help educate, rather than scare, the consumer in to informed product choice.
    It is our right, as consumers, to choose what we want. But it is our responsibility as professionals to give consumers the correct information to make that choice.

    Reply
    1. Alex (Post author)

      Hi Chris,

      A very good point, and one I assure you we have considered.

      Our Awards are quite complex and labour intensive. They are judged on the basis of month-long testing of the products by cosmetic users, and round-table panel judging by experts (examining the products, scrutinising labelling, commenting on formulation etc).

      Were we to incorporate other factors – such as a consideration of a company’s marketing, ‘education’, website, philosophy etc – we would struggle, due to the number of companies who enter, and the work that would need to be done in deciding how to judge all these additional aspects, and in judging itself. It would mean increasing entry fee, which we don’t want to do, as we are desperate to be accessible to smaller companies. (In practice, the judges are sometimes aware of brand philosophies, so these issues can be brought up at judging sessions, but they don’t have a huge impact, normally.)

      I can assure you that we do penalise brands with alarmist expressions or terms on their labelling – or indeed on their entry forms.

      We do take on wider considerations, however, with regards to the brands shortlisted for our Best Brand award.

      We will review all this for 2017.

      Thanks very much,

      Alex.

      Reply
  10. Chris Gummer

    Alex,

    thank you for the reply.

    It would be a shame if products win your awards and advertise their success on their websites if, at the same time, they misinform or scare the consumer and fail to comply with advertising regulations. Let’s celebrate those who get it right and not those who choose to mislead.

    Let me offer a solution to your concerns of more work and increased fees. For any product that goes forward to your panel for assessment I will review the website and brand / ingredient philosophy gratis.

    Happy to help where I can.

    Chris

    Reply
    1. Alex (Post author)

      Thanks Chris – very generous offer. Will get in touch by email in due course. Forgive haste – presently dealing with enquiries and entries.

      A.

      Reply
  11. Pingback: Free From Claims On Cosmetics -Colin's Beauty Pages

  12. Bruno B.

    Dear Alex,

    I am so glad to see people fighting for consumers’ rights.
    Your awards are a great idea and definitely “Free from” shouldn’t be used as a scare tactic but for guaranteeing quality to people who care or have health concerns. This maybe why we do need a regulation on the topic, but we certainly do need to keep the “Free from” authorised.
    I simply disagree on the exclusive use of natural fragrances as part of your criteria. They contain allergens and are, as such, in clear contradiction with the rest of the efforts. IMHO an artificial fragrance free from any of the 26 listed allergens is undoubtedly a better choice for anyone with allergies
    But I’m happy to help anyway I can to support your efforts because we do need better products for people and Nature. Consumers need to know which brands are doing it right.

    For transparency purposes, I should mention that I am about to launch such a brand. And what prompted me to do so is the realisation that so many companies and brands have such little regards for consumers’ health or nature. I decided to do something about it, hoping to join a community of brands who respect their consumers and force others to adapt and follow to the benefit of consumers and nature. It will take time…but it’s worth the effort.

    Reply
    1. Alex (Post author)

      Thanks Bruno,

      We don’t think permitting fragrance allergens in the form of natural fragrances contradict our efforts, because – although our background is in allergy and we started the Award keen to make allergy considerations an important factor – we didn’t want it to be exclusively about allergy, but other considerations too. Not everyone has fragrance allergies, but many prefer natural fragrances (at least in our experiences, which are what informed the Award, when we set it up).

      That said, excluding allergen-free synthetic fragrances is a more debatable point. We permit synthetic preservatives, partly for pragmatic reasons, so synthetic fragrances free of the 26 is something we will consider for 2017. We meet annually to review the terms, criteria and so on, and this will definitely be on the agenda.

      I ought to point out that we do have a special ‘Free From Achievement’ category within the Awards, which is awarded to products that are particularly ‘allergy friendly’, including fragrance-free.

      Thanks for your comment and support.

      Alex.

      Reply
  13. Ric Williams

    With more than 45 year’s experience in formulating cosmetic products, I feel compelled to enter the debate, something I rarely do as I find that highlighting a problem only tends to extend its life span, but this is different. The use of Free from claims attacks my basic ethics and inner being. The perception is that they accuse me of having used something in a product that causes harm. Nothing can be further from the truth.
    Yes, I know that some Free from claims can be justified (eg. Alcohol in Halal (although apparently an incidental amounts can be justified); No animal testing (if you ignore the fact that most raw materials (if not all) have been tested on animals to gain the approval of regulatory authorities for use); Animal products (for vegans/vegetarians, even those that wear leather clothing items); Nut products (despite the fact that if we ignored the concerns and introduced these into children’s diets early enough, we may not have the problem or those that claim no Coconut are doing so just to say something)). But what I hate is using false or incorrect so-called “science”, such as NO Parabens or NO SLS, implying that these are dangerous (which they are not), just to get a marketing advantage over a competitor. Nowadays, using these may be “scientifically” safe but “commercially” suicide and that is wrong. What many detractors forget is that if we used something that was “dangerous” we would be sued by the regulatory authorities, so don’t imply we may have done the wrong thing.
    I have read the good arguments made by Dene Godfrey and Chris Gummer, finding them representative of what we are actually seeing out in the market place. To deny this is pretending not to see the truth for ulterior motives. Then I have read the responses by Alex, and see a desperate attempt to defend the indefensible. His argument/explanation justifying the award to Pai products borders on the absurd, and indicates that he cannot admit a mistake that he has made. How credible can his awards be after that?
    The facts are that while, in some cases, they ARE informing the consumer of genuine concerns (albeit the information CAN be found in the ingredient list and it is NOT hard to seek further on those materials), most Free from claims ARE demonising chemicals, ARE used to denigrate competitive products, and ARE trying to say that they are better than someone that does use these “offending” materials or better than they used to be before the “offending” materials were removed. How does the uninformed consumer (or more dangerously those that only get their information from non-scientific websites that proliferate these falsehoods, let alone know which websites are truthful) determine the difference between truth and lies? The inherent (major) problem is that bad news sells more (newspapers) than good news and that is what marketers are relying on.
    If this continues, as it has been going, then more governments will step in and regulate these claims, or ban them altogether, as has already been done in some countries.
    So let’s get the TRUTH out there and not proliferate incorrect information. OK let’s have claims about genuine concerns, but let’s be more concerned to tell the positive things about good products and to do this Free from claims (and awards) MUST be accompanied by education, that justifies the exclusion, so that we are all on the same playing field. The consumers deserve nothing less.

    Reply
    1. Alex (Post author)

      Thanks Ric, for your comments.
      I don’t think you’ve added any points not already made by other posters, or that I’ve not already addressed fully elsewhere in my own blogs or in my responses to those critics, so can only suggest you refer to them.
      All the best, Alex.

      Reply
  14. Ric Williams

    Firstly I find it disapointing that you always feel the need to defend your position particularly with you also not adding anything new. It shows insecurity.
    My blog was not to add new information but to add further weight to the argument against unnecessary Free From claims. Sorry you could not see that.

    Reply
    1. Alex (Post author)

      Hi Ric,
      I struggle to see how defending our position in the face of repeated criticism shows insecurity. I would have hoped it showed a willingness to engage with those who question what we do – as I’m continuing to do here.
      Thanks again for stopping by.
      All the best,
      Alex.

      Reply
  15. Ric Williams

    “repeated criticism” – doesn’t that tell you something?

    Reply
    1. Alex (Post author)

      Hi Ric,
      Sure, I guess it tells us that the cosmetic scientists / chemists who have been moved to comment detest free from labelling.
      The supportive comments – including many sent privately – tell us that many who use and need free from labelling value it and find it helpful.
      Best wishes,
      Alex.

      Reply
      1. Dene Godfrey

        //Sure, I guess it tells us that the cosmetic scientists / chemists who have been moved to comment detest free from labelling//

        Perhaps this is because “the cosmetic scientists / chemists” are much closer to the coalface and can see the problems these claims cause more clearly than most people?

        //The supportive comments – including many sent privately – tell us that many who use and need free from labelling value it and find it helpful.//

        I challenge this claim, despite an earlier post stating that they always looked for “free from” labels from which to choose. The degree of “helpfulness” is limited to the claim to be “free from” the specific allergen for the specific customer. Few people are allergic to parabens, but this is the most prevalent “free from” claim and, therefore, it is “helpful” in a very small proportion of cases. When measuring the degree of (misplaced) public mistrust of parabens due to this type of labelling against the numbers of people who are actually allergic to parabens, this is greatly skewed and, once more, such labelling is totally unnecessary, given that parabens are very easy to identify in the INCI list. Even the person who claimed it was helpful stated that they still have to read the INCI list, which renders the “free from” claim somewhat redundant.

        Moreover, the “free from” claims are more often used by companies who spread precisely the type of misinformation highlighted by Chris Gummer, and this scheme gives that type of company far more validation than they deserve.

        “Free from” claims add absolutely nothing to safety; that’s what the INCI list is for.

        Reply
        1. Alex (Post author)

          Hi Dene,
          Do you disagree with all free from labelling, across the board, or do you approve of / feel agnostic towards any particular examples?
          Best wishes,
          Alex

          Reply
          1. Dene Godfrey

            Hi Alex,

            I am not aware of every single “free from” claim that is being made, so I cannot comment on absolutely every single example, but I feel that “free from” specific ingredient X is a bad claim (e.g. parabens, SLS, etc) as well as being unnecessary (due to the INCI list) for the reasons I have previously stated.

            If people are interested in environmental issues, then it is better that they check out the manufacturers web site to assess their attitude. Labelling pack with “petrochemical free” is not necessary, and this is one of the most frequently misleading claims made. The vast majority of the companies that I have investigated who make this claim are not telling the truth as they often DO contain petrochemicals. Environmental issues are not as simple as “petrochemical free” would suggest anyway, so it can be misleading on more than one level.

            Ethics can be addressed on the manufacturers’ web site as well. “Cruelty free” is a nonsensical claim, mostly because it is, essentially, meaningless. The BUAV permit signatories to nominate their own “not tested since” date, and there is some wriggle room in terms of the amount of ingredient sold into other industries. “Free from” doesn’t even begin to address the complexity of ethics in cosmetics.

          2. Alex (Post author)

            Hi Dene,
            Can I ask whether you have a view on freefrom labelling on food? Gluten-free, dairy-free, free from artificial colourings / preservatives and so on?
            These appear to be remarkably uncontroversial in food industry – they’re widely welcomed by allergy charities, by consumers, including allergic consumers, and there is no objection to their existence among, for instance, food scientists, food service providers, dietitians, manufacturers / brands, medics or other relevant parties. Why do you think that is?
            Best wishes,
            Alex.

  16. Chris Gummer

    “Sure, I guess it tells us that the cosmetic scientists / chemists who have been moved to comment detest free from labelling.”
    Let’s not let this descend in to an online spat. Alex, we have had several communications on this matter and I hope you would agree that I would like to see accurate information that allows the consumer to make an informed choice. As a cosmetic scientist I have never adopted the position of detesting “free from” labelling / claims and have said publicly that it has a place. Let’s all work together to make sure the consumer gets the facts and appropriate guidance to choose the products that best suit them and their needs. And together, where we see the abuse of “free from” claims call out that company to justify their position and not perpetuate simple commercial gain or “because the others do it!”

    Reply
    1. Alex (Post author)

      I do agree. It was in response to the previous poster’s question about what the ‘repeated criticism’ told me – I hadn’t intended the comment to refer to you. Apologies.

      Reply
  17. Dene Godfrey

    Alex,

    Any view I might have on the food industry is irrelevant to this discussion. We are talking about the cosmetics industry, not the food industry. They are very different industries with different consumer perceptions and performance requirements. As far as I am aware, there is no part of the food industry that is trying to convince its customers that the rest of the industry is trying to kill them as is the case with a section of the cosmetics industry, a section that includes the most prolific users of “free from” claims.

    You are attempting to employ a false equivalence. Let’s stick to discussing the cosmetics industry, shall we?

    Reply
    1. Alex (Post author)

      Hi Dene,

      Not an equivalence – an analogy – and I think it’s relevant.

      Curiously, there are sections of the food industry – a few producers of vegan and so-called paleo products – who do market on a ‘gluten is harming you’ / ‘milk is poisoning you’ basis (neither a position I agree with) – and some bigger brands too, such as Genius. But does that mean they should not carry ‘gluten free’ or ‘dairy free’ labelling? No. Does that mean all GF and DF labelling is bad and should be banned? No. You could argue such terms are ‘unnecessary’, because the GF or DF consumer can just read ingredients – but the point is these terms are helpful to consumers – even though, no doubt, some who do not need / want to avoid dairy or gluten infer from ‘free from’ messages that the referred-to ingredients are somehow ‘bad’.

      This is how we view cosmetics. We know our readers do so too.

      I’m not sure what else to say that I’ve not already said. As I told Chris off-list, we review our judging criteria annually and will do so later in the year and see how we can improve. I’ll bring many of the points made in all the discussions I’ve been involved with to the table.

      I’m going to have to leave it there.

      All the best,
      Alex.

      Reply
      1. Dene Godfrey

        Alex, with respect, an analogy is an equivalence (by definition). The main reason I claim false equivalence for the food industry is because neither “gluten” nor “dairy” are labelled as ingredients; i.e. the ingredients that contain gluten or are of dairy origin do not appear on the label as “gluten” or “dairy”, whereas parabens are parabens and are clearly indicated in the INCI list, as are most other individual ingredients that your “free from” campaign seeks, in effect, to taint.

        Reply
        1. Alex (Post author)

          Hi Dene,
          An equivalence is an equality; an analogy is a partial similarity.
          But you’re right – it would be ‘wheat’ and ‘milk’ – although ‘wheat free’ and ‘milk free’ are less commonly seen, hence why I used GF and DF. The point still stands.
          It’s not a campaign. It’s an Award. And we seek to taint nothing.
          All the best once again,
          Alex

          Reply
  18. Ric Williams

    Following;
    //Hi Dene,
    Do you disagree with all free from labelling, across the board, or do you approve of / feel agnostic towards any particular examples?
    Best wishes,
    Alex//

    Alex
    Do you agree with ALL free from labelling, across the board, or do you disapprove of / feel agnostic towards any particular examples?
    What Dene, Chris and myself are trying to say (but you cannot seem to acknowledge) is that not all free from claims are bad, but lests NOT promote those that are unnecessary or based on false science.
    Ric

    Reply
    1. Alex (Post author)

      Hi again Ric,
      I disapprove of nonsensical or alarmist or opinionated free from claims – eg free from nasties, free from chemicals, free from toxins.
      I generally approve of factual / free from [ingredient] claims.
      I’m not sure Dene is saying that not all free from claims are bad, unlike you and Chris, but I’m certain he will correct me if my perception is wrong.

      Which claims are unnecessary or based on false science? Is there a consensus agreement on this among chemists and cosmetic scientists? I’m not sure there is, but I’m all ears. The decision would have to be made on each individual claim / ingredient.

      The argument could be made that all free from claims are ‘unnecessary’ – just “read the INCI”. Yet we know that free from labelling helps as a shortcut, or for people intimidated by the INCI.

      The argument could be (and is) made that ‘free from parabens’ is based on false science. Yet some have parabens allergy. A tiny minority, I know, and for the record, I agree with the science on parabens safety. What about ‘free from MI’? False science or not? How do you decide? On whether there is public concern / wide false perception about MI – or based on numbers of sufferers of MI allergy? Which criteria and data do you use to draw the line between acceptability and not?

      Because in order to incorporate this into our Awards and our judging, we would need to determine what we would permit / not permit and why, and also pre-decide to what degree a brand’s product should be penalised for making a claim deemed not acceptable.

      There is also the added layer of complexity concerning free from labelling and types of products in which they have no ordinary business being present. I suspect you might agree, for instance, that ‘free from SLS’ on a body lotion is more unacceptable than the same on a shower gel. This too would need to be decided on to maintain fairness in judging – although I should say that judges have highlighted such issues in the past, and they have been taken into account.

      Something else that has been raised previously has been the prominence of free from labelling. Ideally, discreet free from labelling, given the same prominence as the INCI, for people who need to seek it out, is generally what we feel is most appropriate. Great big ‘parabens free’ messaging in CAPS on the front, appealing to that fear that no doubt exists – no, I am not keen on that either. Again, this has been taken into account on products during judging in the past.

      I suspect all this is fiendishly complex to itemise and determine, but as I’ve said elsewhere, I will bring the subject to our annual post-Awards meeting. Again, I’m happy to hear suggestions in the meantime.

      All the best,
      Alex

      Reply
  19. Ric Williams

    Firstly your perception is wrong. Did I not say “What Dene, Chris and myself are trying to say (but you cannot seem to acknowledge) is that not all free from claims are bad, but what I have said is lets NOT promote those that are unnecessary or based on false science”. Did you not read that?
    I agree that, as you said, “all this is fiendishly complex”.
    Lets take a few examples you have used recently.
    Firstly Sodium Lauryl Sulfate (SLS) has been claimed to do all sorts of things, and I don’t believe that any of them are justified. I have seen claims “Sodium” content can cause heart problems similar to salt intake in diet, but topically, in a wash off product – give me a break. I have seen claims that it causes cancer, but I have seen absolutely no evidence to that effect. If it did then a similar material – Sodium Lauroyl Sarcosinate (for example) while milder, is still in the same chemical family (anionic surfactants) however does not have the same hype as SLS. I have even seen a customer of mine reject Sodium Lauroyl Sarcosinate because it has the same initials (SLS). There are claims for “Sulfate free” and this is even more insidious because sulfate can be a common generic molecule that has no resemblance to anything bad (eg Epsom Salts is Magnesium Sulfate). This form of generic free from is worse than attacking specific chemicals.
    The original claim against SLS was that it was an eye irritant in hair care. At this point, I must correct you in that SLS is hardly used in shampoos nowadays, mainly being restricted to powder types only. It is more used in creams (as an emulsifier) – see Aqueous Cream BP, a common therapeutic cream base.
    Next, the company that first made this claim (and I am sure it was trying to denigrate an opponent as the claim was that anybody that used it caused eye irritation) actually used something that was more irritant – but how does the consumer know this (without proper education)? Its “known irritancy” came from the fact it was used as a standard in the Eye Irritation test, why, because it could be obtained as a 100% pure material and always gave the same answer – 3 out of 10 – hardly a dangerous chemical with that level of irritation, but just enough for the user to know that it had something in their eye and to wash it out. Milder shampoos don’t have this inherent “defense mechanism”.
    Parabens, you say, can cause allergies, although you admit that this is a “tiny minority”. Yes some claim to be allergic to parabens but what of all those that aren’t. The “Free from parabens” claim may cause the nervous consumer to avoid products that contain parabens, even though that consumer may not be allergic to parabens. A case of causing concern where there is no necessity. If someone is allergic to parabens then surely they can see the INCI name in the ingredient list – as Dene said it is not hard to see.
    The question is how much is enough before you feel compelled to warn the consumer. One in 1,000, one in 10,000, one in 100,000 – if we did that then there would be no room on the label as all would be taken up with free from claims or we would have no materials that would make a consumer acceptable cosmetic product. Please rely on the fact that a formulating chemist, is the expert, and takes this into account by using materials at safe levels and 1 in 10,000 may be an acceptable risk, yet if it appears as a Free from claim then consumers will not realise it may be safe to them. Yes some people have allergies, that are unknown or unusual, hence a commercial product can never cater to absolutely 100% of the population, and one person in a large population may not be the single determining factor in the development of the commercially acceptable product (effectiveness vs price).
    The last issue with Free from claims is how the ingredient is used. Just to say the product contains a material of concern is totally insufficient to alarm the consumers.
    Example 1 – Caustic Soda is a dangerous chemical but is used to adjust pH and if the product is formulated to approximate the pH of skin (ie acidic) then there will be no residual Caustic Soda (alkaline) remaining. In this case a claim of Free from Caustic Soda may be correct or incorrect, depending on your approach and Free from Dangerous Chemicals may be superfluous, even though a dangerous chemical was added.
    Example 2 – By saying free from … it does not take into account other materials used that make negate the effect of the material of concern. Adding anti-irritants will reduce potential irritation, so how do you take that into account? How does the consumer know that the formulation is designed this way ? Remember “Hypoallergenic” is not an approved claim or does the consumer only read “Free from …” and not see “Low irritant”.
    Example 3 – a change in pH can have a dramatic effect. Alpha Hydroxy Acids, at low pH, can cause skin burning, but if the pH is raised the irritation is minimised. With parabens in a low pH product you may get hydrolysis to PABA, a known allergen, but at the normal pH of skin this is insignificant.
    Example 4 – what would you do about the most common chemical used in cosmetics, that kills more people per year than any other chemical known – DiHydrogen Oxide? Remember, an excess of anything is dangerous. If the laws/rules that exist now were around 100 years ago we would not have alcohol, coffee, aspirin and the list goes on.
    Air pollution is dangerous but I don’t see you giving awards to clean energy providers.

    With most of these cases above, just by saying that a cosmetic contains that material, is no way the definitive answer as there are often mitigating circumstances.
    Yes it is “fiendishly complex” so trust the experts, please, and don’t award those that demonise us, without offering explanations as to why – just make sure you get it right.
    Ric

    Reply
  20. Cara

    I’ve run into so much trouble with buying skin care items I think I’m safe with only to find out I’m not! I started using Yu-Be Skin Care’s Moisturizing Skin Cream and have used it every day since. It has just a few simple but effective ingredients and lists every one of them on its site.

    Reply

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