MarkBroussard
Forum Replies Created
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You’re light on your oils at only 6%. Up that to 12% or so. Also, cut down on your GMSE from 5% to 2.5%. Dimethicone at 3% is high, 1% would suffice. Add 2-3% Butylene Glycol. All of these changes should help.
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You can do all of that in an Excel spreadsheet. Seems to me to be a waste of time.
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The software your client is using would appear to be totally useless for cosmetic product development. I’m involved in the development of AI tools for cosmetic chemists and AI is great for tasks for which you have a good dataset and routine/repetitive workflow.
As for AI replacing cosmetic chemists or being able to create effective formulas, that’s a long way off in my opinion. Where AI can be useful in product development is in competitive analysis of top selling products. For instance, you are tasked with developing a Moisturizer. You can use AI to evaluate the top selling, top rated moisturizers on the market to identify common features/ingredients that are most likely responsible for that superior performance and then use that as a guide in your own product development.
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I have not made an Activated Charcoal Shampoo in some number of years. But, if I recall, unless your shampoo is viscous enough it will eventually precipitate out.
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The FDA unfortunately did not clarify in this statement the they are only Delaying Enforcement of Product and Facility Registration mandates under MoCRA.
The deadline for MoCRA Compliance on all other mandates such as Safety Substantiation and Adverse Event Reporting remain December 29, 2023.
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The real curse is that “Free-From” marketing is allowed in the US. A missed opportunity of MoCRA was to prohibit “Free-From” marketing.
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You are not going to get any effect whatsoever from Tocopheryl Acetate. The conversion rate on the skin is only 6% or so. Better to use tocopherol or tocotrienols.
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You can sign up for a Demo on http://www.cosmex.ai
cosmex.ai
Cosmex - Supercharge Cosmetic Formulation
Cosmex is a software tool that instantly validates whether your cosmetic formulas meet dozens of industry and regulatory standards
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Yes, it is an annual subscription priced by number of seats and the specific modules you elect to subscribe to
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Yes, live demos are available. Take a look at the website homepage and it will give you an idea of some of the features
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There are several labs in the US that conduct SPF testing. The best prices I have found are actually Evalulab in Montreal, Canada. The test in accordance with FDA guidelines.
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You’re falling into the “more is better” trap. It is well established that 15% L-Ascorbic Acid is the optimum amount. The additional 5% LAA that you are trying to add will not make the product better.
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Are they claiming that the Hyaluronic Acid itself is Organic, or are they claiming that the Hyaluronic Acid Serum is Organic? For instance, if you put 1.0% Hyaluronic Acid in 96+% Organic Aloe Vera Juice + Preservatives, it may be possible to create a certified organic Hyaluronic Acid Serum.
Most HA is biotechnologically-manufactured, the HA itself cannot be certified organic.
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$3,000 per month, but I think they recently dropped the price. How much does this tool cost?
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This sounds like The Good Face Project. I have done a demo of Good Face and it is impressive. But, quite pricey on a monthly fee basis. I just signed up to demo this tool. Thanks for bringing it to everyone’s attention.
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Why not just add edta/phenoxyethanol/sodium benzoate to the extract? I am assuming the supplier of the extract sells the extract unpreserved? Or, ask the supplier to preserve the extract.
No, I don’t think adding Citric Acid to the extract is going to help with mold contamination.
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Just because someone has an MS in Cosmetic Chemistry does not mean they will necessarily be good at it. Same as any discipline. Having a college degree mainly has an impact on getting your first job out of school. After, that, it’s all experience that counts.
I remember when I got my MBA and got my first job out of school. At the end of my first week on the job, i remember sitting back and thought “Damned, they didn’t teach me jack about how business really works”
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Safety Substantiation: The FDA clearly states that neither MoCRA nor the FDA require specific tests to establish Safety Substantiation so there will not be a specific set of tests required by FDA.
The FDA does talk about Micro and Ingredient Toxicology from published data in its discussion of Safety Substantiation with no mention of Patch Testing. But, one can reasonably surmise that these three components are the essential elements of establishing safety. The granular specifics of Safety Substantiation are going to be established by the retailers such as Amazon, Ulta, Sephora etc. who are currently requiring PCT and HRIPT. For ingredient toxicology a full CPSR is not required in the US and EU firms are offering scaled-down ingredient tox reports for the US market.
Anhydrous Products: There are challenge tests for anydrous products available from various labs. Probably worth the $500 or so to run one to build your Safety Substantiation Dossier.
If you are DTC and not trying to sell through Amazon et al, then you best approach is PCT, HRIPT and Ingredient Tox Report.
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More will be known about that towards the end of 2023 when the FDA will present their reportable list of fragrance allergens. Once that list is published, there will be a 6 month public comment period and the list will be finalized in mid-2024 and the labeling requirement will go into effect at the end of 2024.
My guess: It will be the 26 EU fragrance allergens, plus some from the additional 56 going into effect in the EU in September 2023, but not all 82 EU fragrance allergens.
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Why use Sodium Phytate, which raises the pH, to then have to lower the pH with a different acid? Simply use Phytic Acid as your chelator and pH adjuster.
Adding Sodium Benzoate will help because it is stronger than its analog Sodium Anisate. But, Sodium Benzoate is not really going to help you with bacterial contamination. You simply need a co-preservative that is effective against bacteria which is why I inquired if Phenethyl Alcohol was an option for you.
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What specific Chelator are you using? You keep saying Chelator, but never define it and that makes it difficult to provide to you any really useful guidance. Are you are able to use Phenethyl Alcohol and as boosters Pentylene Glycol or 1,2 Hexanediol?
And, as @PhilGeis mentioned … what is your packaging? is the consumer able to come into direct contact with the product in the packaging such as a wide-mouth jar or even an eye dropper that is then placed back into the container? Or, are you using airless pumps? Your problem may not be just a weak preservation system, but also packaging that accentuates contamination in use.
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What other preservative or co-preservatives are acceptable to you besides the Sodium Anisate / Sodium Levulinate?
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You normally measure GHK Cu solutions in ppm (parts per million). You can purchase pre-mixed 2000 ppm solutions for instance. Active Peptides is a good supplier.
If you are using GHK Cu powder, 0.2% GHK Cu in 99.8% water would be a 2,000 ppm solution. 2% would way too strong.
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Here’s the language from the FDA MoCRA Draft Guidance For Industry
“Safety Substantiation: Companies and individuals who manufacture or market cosmetics have a responsibility to ensure the safety of their products. Neither the law nor FDA regulations require specific tests to demonstrate the safety of individual products or ingredients.”
“A Responsible Person (ie: the Brand) is required to ensure and maintain records supporting adequate safety substantiation of their cosmetic products. Manufacturers (Brands) can use relevant safety data that is already available to support the safety of their products. Animal testing is not a requirement for marketing a cosmetic product. It’s important, however, that all data used to support the safety are derived from scientifically robust methods.”
Yeah, I have never had an anhydrous product run through PCT, but have seen it offered by a couple of labs. Interested in hearing your thoughts/advice on micro testing on anhydrous products.
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Amazon already has listing criteria information that they require a brand submit prior to being listed on the site. This is something they are already doing. Yes, Amazon will do this as a liability prevention measure to ensure they do not become ensnared in a lawsuit by listing products by a company that is not in compliance with MoCRA. Seriously, any idiot can look at a PCT test results from a certified lab that is deemed a Pass (which is stated by the lab on the PCT final report) and determine that the product passed PCT.