[Perry44]

Thank you for letting me know. So sorry for your loss.
Kevin was a frequent contributor to the forum about 10 years ago and I always appreciated his insights.

[Perry44]

Yes it is happening. Some of the stuff has already been implemented.

What’s in Effect (and has been actively happening):

• Adverse Event Reporting: Companies have been required to report serious adverse events associated with their cosmetic products to the FDA since December 29, 2023.

• Facility Registration and Product Listing: Cosmetic manufacturing facilities were generally required to register with the FDA by July 1, 2024. Companies also had to list their cosmetic products, including ingredients, with the FDA by December 29, 2023, for existing products. The FDA has reported a significant increase in registrations and listings compared to the previous voluntary program, indicating widespread industry compliance with these mandatory requirements.

• Safety Substantiation: Companies must have records to support the safety of their cosmetic products.

• Mandatory Recall Authority: The FDA now has the authority to issue mandatory recalls for unsafe cosmetic products.

• Professional Use Labeling: Specific labeling requirements for cosmetic products intended for professional use became effective.

And some of the stuff has been delayed…

Where There Are Delays (and the FDA is behind schedule):

• Good Manufacturing Practices (GMPs): The FDA is mandated to establish federal regulations for GMPs for cosmetic facilities. A proposed rule for GMPs is now anticipated by October 2025, which is later than originally envisioned.

• Fragrance Allergen Labeling: Rules requiring the disclosure of certain fragrance allergens on cosmetic labels are still in development, with a proposed rule expected by January 2025 (a pushed-back timeline).

• Talc Testing for Asbestos: The FDA is mandated to establish standardized testing methods for detecting asbestos in talc-containing cosmetic products. A proposed rule for this is anticipated by December 2024, also a revised timeline.

In summary, MoCRA is very much happening, and companies are complying with the implemented requirements. However, the FDA is behind schedule on developing some of the more detailed new regulations mandated by the Act. The “DOGE cuts” and broader efforts to reduce federal staffing and regulations are likely contributing factors to these delays, as they impact the FDA’s capacity and prioritization of its many responsibilities.

[Perry44]

This time they got the Big Guys involved.

Inevitable. Clean beauty / EcoBeauty / Natural…. None of this is an ownable position for a brand. If it gets popular, the big guys will just adopt it, adjust it so it fits with what they were already doing, and declare victory.

I just wonder what the small guys will vilify now?

[Perry44]

I’m confused. What does this have to do with floor cleaners?

[Perry44]

New name for a thing that has been around for decades. Any ingredient derived from a plant or animal can be called “biocosmetic”.

This reminds me of renaming surfactant solution as micellar water.

[Perry44]

What are the ingredients?

You’ll likely get better/more responses if you include the list of ingredients. But yes, it’s possible to replicate any product on the market. Also, no you don’t have to include all 42 ingredients to do it.

[Perry44]

In the US, there aren’t really bans on ingredients except things that have been proven to cause harm. I know this is true in the EU too but they also will ban ingredients that “might” cause harm.

[Perry44]

What were the lessons you learned (besides don’t hire someone who will drive your business out of business)?

What kind of bad marketing decisions did they make?

Presumably, they thought they were making good decisions.

Did you have the power to approve what they were doing with your brand?

[Perry44]

I’ll answer some of this (other stuff I don’t know). If you have an INCI and CAS number you should be able to market the ingredients. However, you’ll also need to have evidence that the ingredients are safe for use in cosmetics. Some testing or report or something.

[Perry44]

ACV (Apple cider vinegar) is an acid, specifically Acetic Acid. So yes, it will change the pH of a water based system. It will definitely lower the pH of something higher than pH 6

[Perry44]

When you say “split” I’m assuming you mean it separated? 1.6% EO is very high so that is likely your problem. Also, I think Allantoin can contribute to separation.

If you were selling the product you should probably throw it away. If you are using it yourself, just Shake before use and it should be fine. Unless, of course you have some microbial contamination. Then you should just throw it away.

[Perry44]

This is the best of our courses to get you started.
https://chemistscorner.com/learn-more/practical-cosmetic-formulating/

• This reply was modified 2 months, 4 weeks ago by  Perry44.

[Perry44]

That’s wishful thinking. If you put Citric Acid in a formula, it should be listed. However, you can just note your objection and the company is going to do what they want. If it is just a label run-out, the chances of them being found out is not high. Make sure they change it when the next round of labels are printed. It’s still wrong & they should print new label (really how much could that cost?) but if they are such a small company that they worry about a few thousand dollars for labels, they’re probably small enough to get away with it.

[Perry44]

I think it is pretty much impossible to clear the name of the Big Guys. Consumers are just really anti-big corporation.

[Perry44]

You can tell these companies aren’t really sincere in their efforts. If they were, they could reduce their carbon footprint or environmental impact very easily.

Just stop selling so much and stop trying to sell more and more every year!

But sustainability and capitalism don’t really mesh.

[Perry44]

Yeah, everyone “steals” from everyone else. If you are a small brand and are doing well, a big company wouldn’t hesitate to take your idea and try to make it bigger. Or if the idea is too hard to copy, they’ll just buy your company. This shouldn’t be surprising.

[Perry44]

Yes

[Perry44]

You have to be able to prove that your products are safe. If you do not have paperwork, how would you be able to verify safety? Even if you use food ingredients you’ll need proper documentation to prove your products are safe.

[Perry44]

In California, some types of Aloe are listed on Prop 65 which means if you use them you have to put a cancer warning on your label.

[Perry44]

Respectfully, a hard disagree. Natural compounds are much more likely to cause allergic reactions than synthetics.

[Perry44]

Yeah, the GHPC is probably fine. It’s also possible that your PQ7 is a little high 0.6%. Typically, 0.2% is enough. I don’t know the nature of your separation but 1/4 the volume seems pretty high. This usually means an oil but it could also mean a polymer, like PQ7. It’s water soluble so it shouldn’t be a problem but you never know with these things.

[Perry44]

I agree. It is very easy to be mislead by AI because it presents answers as if they are just true. If someone does not know enough about a subject they can easily accept misinformation that would be obvious to a subject expert.

[Perry44]

What synthetics are more hostile to skin than EOs?

[Perry44]

Google is not necessarily more reliable than the AIs and the AI also gives a description of how it calculated the results. So, there are some good reasons to ask the AI a question like this.

[Perry44]

I ran this on Deepseek and got the following…
“Final Answer:

For 300 ppm hard water, you need 0.6–0.9 grams of STPP per liter, depending on efficiency requirements. For 100 liters, you’d need 60–90 grams of STPP. Adjust based on exact water chemistry and system conditions.”

This is much closer to what ChatGPT was saying. I don’t think there can be an “exact” answer because some of the answer relies upon real world conditions. ChatGPT gives you the theoretical maximum.

Interestingly, I asked ChatGPT why there was a discrepancy and it said this…

ME: “did Deepseek make an error? Shouldn’t your responses be the same?

ChatGPT said:

Great question — and you’re absolutely right to ask this. Let me give it to you straight:

Did DeepSeek make an error?

Not exactly — but it was inconsistent across answers.

In DeepSeek’s first answer (3.5–5 mg/L STPP), it clearly underestimated the amount needed to soften 300 ppm hard water. That amount would only remove about 5 ppm of hardness, which is nowhere near 300 ppm.

In DeepSeek’s latest answer (600–900 mg/L STPP), the recommendation is much more realistic and aligns closely with mine from the start (~1.1 g/L for full chelation).

So what happened?

DeepSeek initially applied a rule of thumb commonly used in detergent or light-duty cleaning formulations (where you’re just reducing hardness a bit to prevent scale or improve cleaning), but misapplied it to your question, which was about fully softening 300 ppm hard water.

Then, in the second response, it corrected course by:

Applying proper molecular weight ratios (STPP 368 g/mol vs. CaCO₃ 100 g/mol)

Recognizing that you need a 2:1 or 3:1 ratio to account for real-world inefficiencies

Recommending 0.6–0.9 g/L, which makes sense

Should our responses be the same?

Yes — ideally, all responses should be consistent if the question and assumptions are clear.

In this case, my response and DeepSeek’s final corrected one are aligned. The inconsistency came from their initial answer being too low.

Summary:

DeepSeek’s first answer (~3.5–5 mg/L) = way too low for 300 ppm

DeepSeek’s final answer (~600–900 mg/L) = realistic, consistent with stoichiometry

My original answer (~1.1 g/L) = slightly more conservative, full chelation basis

Bottom line = we agree now

Let me know if you’d like a version of this written for a report or presentation — I can lay it out cleanly.