I must admit that you’re completely correct in terms of limits imposed on salicylic acid. I might have been too quick to say that this is a grey area.
I rechecked the regulation and the guidances and there is in fact a way of marking the ingredients as ‘for professional use’.
Salicylic doesn’t have this designation.
The problem I have here is that there are tons of products marketed as having all sorts of concentrations of salicylic acid on the european market. Only a month ago I was at a trade show with products for esthetitians/cosmetologists and you could find anything you like there made by companies from all over the continent. (like in the post above, the benchmark company is from Spain and openly publishes a brochure stating 6% salicylic acid)
‘I think the carve-out here in the regulations is that if a product is sold to qualified professionals only, and not the general public, then the regulatory requirement does not apply provided the product is safe.’
I would love to be able to pin down some legal document that makes a statement to that effect and will certainly look into it.
@MarkBroussard@BartJ In EU there is indeed sometimes a different regulation for professional use like here . In the case of salicylic acid, however, the same rules apply for professionals as for general users. As I stated above : Max 3.0% rinse-off Max 2.0% in other products.
I’m happy to hear you’re getting into this as well. When applying such a product please protect your lips and the edge of nostrils with a bit o petrolatum until it’s absorbed. Looking forward to see what’s your experience with the project!
A few questions come to mind though: Why use Retinyl Palmitate when you have Retinol aboard?
If Palmitate is the yellow bit, what colour(and form) is your Retinol?
Also it’s worth mentioning that when Retinol is your primary peeling active, you want to be a little higher in the pH. Say 5.5. Your acids are there just to support, you no longer need to prioritise them in the formula. They disrupt the stratum corneum but it’s Retinol that causes the removal.
Desquamatization of the upper layers. Then the driver of poly20…( or a premix) …..like I said, whoever put this together created an elegant work of practical art.
Retinol and RP combined have caused a peeling effect in past for me..lol…so, the yellow seems to come from the RP., otherwise it is pale yellow. That can be hidden in the LOI and not be telling a lie. RP is one of the unsung heroes in skin care. Retinoic acid is your irreversible end product, and too much will cause peeling, but RP is essential cofactor to many other reactions.
Also it’s worth mentioning that when Retinol is your primary peeling active, you want to be a little higher in the pH. Say 5.5.
Hmm…yes….was working off the brochure you had posted (ph 1.7-2.0) but did not see..and here pH 4 ..skin will buffer the low pH of the product ( which this isn’t, per se), so should be fine. Feels a little warm upon application, but then dries to nothing…wash off…apply whatever…see what happens in 48 hrs. If not peeling, will increase Retinol and see if that works.