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Labels
Hi! Any regulatory friends out there? I’ve read through the labelling guidelines for both the USA and Canada and am wondering, I thought there was a rule that you didn’t have to list ingredients that are present under a certain percentage, but I don’t see it anywhere. Did I make it up?
The other question I have is in regards to contaminants. Specifically in this case, emulsifier 165. My supplier lists some contaminants - Ethylene Oxide (75-21-8) at < 1ppm and 1,4-Dioxane (123-91-9) at <10ppm. They don’t include these in their INCI name nor their labels. They do however label for California Proposition 65. Why aren’t they listed on their label ingredients?
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6 Replies
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Ingredients label of virtually all ingredients but trade secret (FDA approval req’d - only ~one ever) and incidental ingredients
The provisions of this section do not require the declaration of incidental ingredients that are present in a cosmetic at insignificant levels and that have no technical or functional effect in the cosmetic. For the purpose of this paragraph, incidental ingredients are:
In this case - Substances that have no technical or functional effect in the cosmetic but are present by reason of having been incorporated into the cosmetic as an ingredient of another cosmetic ingredient.
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Thanks, that’s very clear. No one knows anything about California Proposition 65 labeling on cosmetics?
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If you put an ingredient in your formula on purpose for some specific reason you should list it. There is no lower limit where if you are below it you don’t have to list the ingredient. That’s made up.
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AH, thanks!
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For Prop 65 requires labeling for material that cause cancer or reproductive toxicity - “known to the State of California to cause cancer birth defect or other reproductive harm.”
The state lists the chemicals https://oehha.ca.gov/proposition-65/proposition-65-list/
There is a ‘safe harbor concept that allows risk assessment exemption of labeling.
For example, you’ll see warnings for alcoholic beverages, fisingc lures (the paint).
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