active ingredients cosmetic
Article by: Perry Romanowski

Last week I gave a presentation of my Beginning Cosmetic Chemistry course to a full house at the National SCC meeting in New York. I was pleased that there were nearly 50 students! Doing that course is always fun. Incidentally, if you couldn’t make the live course you can get the information and more in our online formulating courseactive ingredients cosmetic

During the course I was talking about “claims ingredients” and the fact that many of the things that are touted as active ingredients are really just added for the marketing claims. I further stated that if you are adding a compound in your formula that is having a drug effect that would make the product an illegal drug. This met with some disagreement and another participant and I had a nice exchange about it. In reality, we didn’t disagree on the facts, but we did disagree on the way these facts should be considered.

Here is my opinion about cosmetics, active ingredients and their effectiveness.

1. If an ingredient is added to a cosmetic and it is going to somehow interact with your skin cells and change the body metabolism, then the ingredient (and product) is a drug.

2. If your product is not a drug then it will not have any significant impact on the skin cell metabolism…ergo it won’t work like a drug.

So the short answer is No, active ingredients in anti-aging cosmetics do not work. If they do, they are drugs.

For these reasons when you see anti-aging products that claim to “boost collagen” or stimulate elastin production, they either don’t work or they are illegal drugs.

This statement is what met with disagreement. There are people in the cosmetic industry who hold the opinion that you can use ingredients that are known to have an effect on skin, as long as you don’t claim that they do what you know they do. They believe that you can add ingredients known to boost collagen as long as you don’t claim that your product does that. It’s an understandable position but not one that sits right with me.

I should add that they make the point that it is demonstrably false that things like moisturizers don’t have an impact on skin metabolism. They do. Even touching your skin can be shown to stimulate the production of certain compounds in skin. This is all true so it makes the situation complicated.

FDA weighs in

It is interesting to guess about the FDA feelings on this topic. This recent letter they sent to Dr Brandt Skincare is illuminating.

Essentially, Dr Brandt was making claims on their website that make their products illegal drugs. Here is a listing of some of the claims they made which make a cosmetic product an illegal drug.

1. “Boosts collagen production”
2. “[A]dvanced collagen boosters and botox alternatives that actually work”
3. “[H]elps breakdown fat deposits…”
4. “[R]epairs damaged skin”
5. “[A]ntibacterial action”
6. “helps fade dark circles by stimulating microcirculation”

So it seems that the FDA is serious about cracking down on companies who are adding ingredients in their cosmetics and then claiming that the products will have some kind of interaction with skin metabolism.

The bottom line is that you need to focus on telling people the results of your product. Avoid telling them how it works. In truth, consumers care more about the benefits of your product than the features anyway.



  1. Avatar

    i am a bit confused and saddened, as i do read clinical reports, scour through clinical documents when an active has piqued my interest.. i want to know that it does work before investing my time and resources toward acquiring it and formulating with it toward the desired end..

    for example, japanese knotweed polyphenols, or trans-resveratrol .. from what i have read, clinical data as well as the info jen was kind enough to detail on her site, it seems like this may help with my acne-prone skin if i include it in my formulations for personal use.. (formulating for myself has vastly helped my skin, whether the actual formulations or learning enough about each potentially problematic ingredients to exclude them.. IPM and myristyl myristate did horrible things to my skin in my test runs.. they are just so delightful in terms of skin-feel, i really wanted them to work.. *sigh*)

    Point being: Is the clinical data on Trans-Resveratrol all fluff? I mean, it is supposedly an excellent antioxidant, if nothing else..? Maybe i misunderstood the point of the article.. :/

    Thanks for reading, replying..

    1. Avatar
      Perry Romanowski

      Hello amanthani and thanks so much for your comments. It can be discouraging to learn the truth about so many ingredients in which we have hope they are going to have some benefits.

      Certainly, many people would disagree with my position about active ingredients and their effectiveness. You can find lots of raw material suppliers, formulators, and cosmetic companies who are convinced that the ingredients they are adding are having a benefit to the skin. Usually, the people that believe these things are people who have a vested interest in something working.

      You have to understand that the Lotioncrafter website is trying to sell you a raw material so the information there is not unbiased. They couldn’t very well tell you that the ingredient does nothing and still expect people to buy it. Websites where people financially benefit from you holding a certain belief are not a good place to find reliable information. That is not suggesting they are lying, it’s just that they are not necessarily presenting the entire story.

      If the Resveratrol actually worked in the way implied, it would be a drug in the US and not allowed. But if you read the description you see words like “helps” and “stimulate cell renewal” and other vague claims. There is no evidence (of which I’m aware) to show that using resveratrol on your skin as applied from a cosmetic will have any measurable effect on the condition of your skin. If there were such a study, no doubt the results from it would make it into the advertising information for the ingredient.

      I’m sorry to be discouraging and I don’t mean to be. However, we don’t want our quest for finding materials that actually work get sidetracked by wasting time and money on ingredients that don’t.

      1. Avatar
        Julio Carreon

        Hi Perry, if the Resveratrol doesn’t make the things they say, why it has an INCI name to add to the cosmetics formulations?

        Thank you so much for replying.


        1. Avatar
          Perry Romanowski

          It’s added to support the story and get consumers to buy products. People want to believe stories about their products.

  2. Avatar
    Nafisah Abdalla

    Hi Perry.
    Your article was very interesting! Funnily enough, this is a topic I am finding slight difficulty to get a grasp on at the moment. Is there a specific amount or percentage of an active ingredient that must be added to a cosmetic product for the brand to make claims?

    1. Avatar
      Perry Romanowski

      If it’s a cosmetic, there is no specified amount of an ingredient that you have to include in the formula. You just can’t claim something is in your formula if you didn’t actually add it.

  3. Avatar
    Randy Wickett


    In my experience it really doesn’t matter to the FDA what the “active” or combination of “actives” does, only what it is claimed to do. There are many cosmetic ingredients, retinol, niacinamide and many other that have been clinically shown to provide positive benefits to at least fine lines and wrinkles and/or give more even skin tone. They may indeed boost collagen and elastin or perhaps work by stimulating metabolism in the epidermis, however, the product will probably not be considered a drug by the FDA unless the company is foolish enough to claim that they work by stimulating collagen and elastin or make some other drug claim.

    1. Avatar
      Perry Romanowski

      Thanks for the input Dr Wickett! I guess it does just come down to what you claim.

  4. Avatar

    Hi perry, I have a query to to ask your guidance. I want to do further studies in cosmetic science from Cincinnati university but I am confused about the course as they have two courses mentioned in the website and they are Graduate Certificate (GC) and nationally acclaimed Master of Science (MS) in Pharmaceutical Science with emphasis in Cosmetic Science but I am confused which to select should I go with certificate course followed by MS or do only MS. Please guide me. Thanks. Have a great weekend.

    1. Avatar
      Randy Wickett

      You can start with the certificate and then transfer to the MS program or you can apply straight to the MS. The advantage of the certificate is that you don’t have to take the GRE (graduate record exam) to apply and all credits will transfer to the MS. Feel free to contact us for more information.
      R. Randall Wickett, Ph.D.
      Emeritus Professor of Pharmaceutics and Cosmetic Science
      James L. Winkle College of Pharmacy
      University of Cincinnati

  5. Avatar

    Hi Perry.
    Very interesting article, thank you! What I don’t understand is: isn’t focusing on the result of your product the same as saying how it works? I mean, for FDA isn’t saying that a cream lightens dark spots the same as saying that because it contains “this and that” it will lighten dark spots? Any effect is considered by FDA as selling an illegal drug, so basically what can we do? Produce creams/cosmetics, sell them without claims and implicitly tell the consumer that they are not useful..just a placebo?

    1. Avatar
      Perry Romanowski

      Thanks for the question. No, not exactly. Here is the difference.

      1. Focus on result – “Your skin will look and feel wonderful with our product”
      2. Focus on how it works – “Our special peptides stimulate collagen to make skin look and feel wonderful”

      The claim of “lightening dark spots” is a drug claim so you can’t say that. But you could say “evens out your skin tone”

      It can get complicated and there is some subjectivity to this. Many companies err on the side of saying too much. Then they get a letter from the FDA and have to change their advertising.

      1. Avatar

        Thanks Perry. Indeed I’ve seen some of the FDA letters you mention and it seems quite difficult to find a balance between what words are allowed and what makes your product become a drug.
        Initially, I thought it was a good idea to take example from large companies, but then I noticed that even large corporations like L’Oreal make these kind of mistakes, and they do get the FDA’s letters!

      2. Avatar

        I have a question. What is the difference between saying it lightens age spots or evens the skin tone? Wouldn’t including any lightening ingredients automatically make it a drug even if you don’t claim it? My mom’s friend wants me to make her a lightening serum for her son and I will be getting paid, so I would like to get some advice. If you have any legal/FDA sites that offer advice on this issue, I’d appreciate it. Thank you so much!

        1. Avatar

          I am using ingredients such as Vitamin C. Also, can you include oils in cosmetics (for sale) that have skin regenerating benefits i.e. pomegranate oil or scar lightening i.e. rosehip oil? I would like to include simply for the skin benefits. Would using one of those oils categorize the product as a drug? I don’t know if I’ll ever make a face product with such oils if it’s too hard to comply with legislation, but I’m trying to get more information.

        2. Avatar
          Perry Romanowski

          If you include Hydroquinone then yes, it would be considered a drug whether you claim it or not. Other ingredients like Kojic Acid, Arbutin, etc. often used for the purpose have not been proven to be effective so including them in your formula would not make the product a drug. “Lightens age spots” is a specific claim about how the product works. That would make it a drug. “Evens skin tone” is a more general claim that has an ambiguous meaning. That makes it a cosmetic claim.

          However, I should say that I’m not a lawyer so you should really talk to an expert in the legalities of these types of products.

  6. Avatar
    Selina Jackson

    Thanks so much for this information, I would have never thought that adding a simple ingredient would turn “lotion” is a drug lol

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