[OldPerry]

Data like that isn’t really easily available. 

Here is an analysis of the amount of lipstick.
http://thebeautybrains.com/2014/10/is-lead-in-lipstick-dangerous-the-beauty-brains-show-episode-54/

You might also look at the CIR and how they evaluate raw materials.
http://www.cir-safety.org/ingredients

[OldPerry]

People believe lots of things they want to be true.

[OldPerry]

You can find free formulas here.

https://chemistscorner.com/where-to-find-free-cosmetic-formulas/

[OldPerry]

@Alias - I agree that it would be difficult to compete against companies fighting in the “giant market.”  I think it is just as difficult to compete in the naturals market. There are so many brands.

Where it’s less difficult to compete is in niche markets for targeted consumers. As @zwapp has pointed out, if you can create a cult following then that is a good basis to build a brand. Finding an audience that wants what you are selling is much more important than any specific marketing angle. 

[OldPerry]

@Alias - The FDA has more power than you’re suggesting. Just because they don’t have immediate power to force a recall doesn’t mean they are powerless when they do issue a recall.
https://www.fda.gov/Cosmetics/ComplianceEnforcement/RecallsAlerts/ucm173559.htm

Bottom line is that it is not a good thing for a company to get a recall notice from the FDA.

[OldPerry]

I’d add that somewhat effective is not effective enough.

[OldPerry]

@chemnc - I suppose that depends on your customer.

[OldPerry]

I think that depends on what performance characteristics you want out of the shampoo.  If you are just looking for cleaning, sure you could make a shampoo with those surfactants. If you want foam, thickness, conditioning, etc. then you’ll need more than that.

[OldPerry]

The fact that your product is anhydrous does not mean you can skip stability testing and preservative testing. It only means you have a higher chance of passing a microbial test.  Stability test…well, you never know with stability testing and whether the product is anhydrous or not is irrelevant.  You should always do a stability test.

[OldPerry]

This is why we do stability testing. It’s difficult to predict when a system will experience pH drift.

[OldPerry]

You can try this…

http://www.lotioncrafter.com/microbial-test-kit-lotioncrafter.html

[OldPerry]

@HuskyBeard - Just because you can do something doesn’t mean you should do it.

It’s true that there is a low (but real) probability that you could proceed as you suggest and make a comfortable living for some time. You may never get sued or contacted by the FDA. They’ll probably catch up with you eventually.

But it’s very much like cheating on your taxes. You can do it and you might not get caught.  That doesn’t mean you should do it.

It’s a dubious business strategy to build a brand based on a lie or an unprovable claim. You’ll always be looking over your shoulder. And you won’t be able to feel good about your advertising and marketing because a regulator might catch up with you. Why would you want to do that when you can build a legitimate beauty brand?

Your product will not increase beard hair growth. You shouldn’t imply that it will. In my opinion, basing a beauty brand on that idea is just a terrible, unethical strategy.

[OldPerry]

@HuskyBeard - What evidence convinces you that the FDA is cracking down on small cosmetic businesses?  I’m not seeing it. In my opinion, the FDA has an extremely limited budget and they aren’t going to spend much of it on chasing down underfunded startups who don’t represent much of a risk to consumers.

I also think you misunderstand the cosmetic industry. It is a myth that Big Business or Congress cares much about start-ups. The tiny portion of the market that start-ups occupy is ignored by the big companies. When I worked at a medium sized corporation, if an idea couldn’t generate at least $10 million in sales in the first year we didn’t even bother pursuing it.  If a cost savings project didn’t save at least $200,000 in a year we didn’t bother. 

These numbers are just too small for big cosmetic companies to even care about.  Start-ups however, can exists rather nicely on $200,000 in yearly revenue.

The only time a big company cares about a start-up is when the start-up gets big enough to represent significant sales. And at that point the big guys just buy the company.

“Could I purchase a few amber glass bottles, buy a bulk inventory of each castor oil and essential oil, and mix/dilute them appropriately at my kitchen and sell it? “

I wouldn’t recommend making things in your kitchen to sell, but if you set up an area away from where you make food and follow all the proper GMP rules as outlined by the FDA there is no reason you couldn’t do this. This book is helpful. http://www.mariegale.com/gmp-basics

But it seems to me that you are looking for reasons not to launch your venture which means you probably shouldn’t. The product should really be the least of your worries. The thing that will determine success is your ability to market to your target consumer. That’s what you should be worried about.

@johnb - it doesn’t surprise me that big companies have ignored the beard market. It’s such a small market & the consumer is so different from their core consumer, they wouldn’t bother. 

[OldPerry]

I’ll chime in considering that I offer a course in how to start your own line. http://startacosmeticline.com

Let’s talk about the regulatory expert first.

You have to realize that most regulatory experts are professional nay sayers. This was true at the company at which I worked and from your description, it is also true of some regulatory consultants.  They have a certain outlook of the world which, while not wrong, can certainly be unhelpful.  When I was in the Innovation group at the company I used to work at our regulatory people wanted us to consult them on every chemical we were testing. They invariably told us we couldn’t use some certain technology. I think they were mistaken. They just have no benefit to saying “yes” to anything.  There is always a reason you can say “no” to doing anything.  If entrepreneurs listened to everything regulatory people said, no one would ever launch anything.

It is true that “just because your neighbor is breaking the law, doesn’t make it any more right” or that you should do it.  Don’t break the law!

Of course, don’t make hair growth claims. It doesn’t sound like that was the purpose of your product so as long as you aren’t making those claims that shouldn’t be an issue. Don’t imply that you’re growing hair either.

But let’s be real. The chances anyone would sue you is remote. If you are a start-up and set your business up as a corporation (talk to an accountant about this) this limits your liability for any lawsuits. Also, get business insurance if you are worried about it.

Lawyers are not looking around to sue start-up businesses. They go where the money is and unless you have a huge pile of investment money, you’ll be ignored.  If you get sued and have no money your business goes bankrupt and no one collects anything. It’s a waste of everyone’s time. This isn’t something I would personally worry about, although other people would.

I’m not going to go through a point-by-point refutation of what your regulatory expert told you. I can tell you that our big corporation made cosmetic claims all the time in which our claims support was simply a written explanation for why a claim was valid.  We didn’t conduct a test every time we claimed a hair product was conditioning or moisturizing. Perhaps it was a risk by if you use known conditioning technologies, a lawsuit against you would be a waste of time.

It’s probably true that any cosmetic company could get shut down at any time. Or at least they could be hampered with legal challenges. The reality is that this almost never happens.

If you’re looking for a reason not to start a cosmetic line, there are lots of reasons.  It’s a bit of a gamble. But cosmetic companies that fail almost always fail because they don’t have a good marketing strategy. If you’re big enough that someone wants to sue you, you’ll have enough money to hire lawyers to defend you.

Don’t break the law. Follow the rules to the best of your ability and deal with challenges as they present themselves. I personally wouldn’t let what these two consultant experts told you discourage you from moving forward with launching your brand.

Incidentally, the FDA has published a set of guidelines for small / home based cosmetic businesses which might be helpful for you. 

[OldPerry]

“vegetable glycerin”,  “Ammonium salt”, and  “deionized water” are not INCI names.  The company seems to be making an attempt to do a proper ingredient list but they are failing. So, if you can’t figure out the emulsion system, it’s just as likely that they are using something and not listing it.

But in looking at the product, in my opinion here are the ingredients that matter (assuming they are at least following the labeling rules for concentration).

Deionized Water, (Shea Butter)*, (Coconut ) Oil*, Macadamia  Seed Oil, (Mango) Seed Butter*, (Avacado) Oil, Vegetable Glycerin, Ammonium Salt

Whatever the ammonium salt is, that could be the emulsifier. Coupled with the Shea butter that might be stable.  That would be my guess, I don’t really know though.
  

[OldPerry]

This company doesn’t have a legal list of ingredients so the truth is they could be using some polymeric emulsifier and just not listing it.

[OldPerry]

Thanks for the update!

[OldPerry]

@Christopher - Indeed.

[OldPerry]

What active ingredients do you want to extract from the clay?

Here is a source for all the free cosmetic formulations of which I know. I’m sure you can find a sulfate free shampoo there.

[OldPerry]

@Bobzchemist - That is always the most important first question when talking about ‘natural’ cosmetics.

By some definitions of natural, it is impossible to make a natural shampoo and body wash.  There are no shampoo bushes or body wash trees.

[OldPerry]

Welcome to the forum!  Please feel free to start a new discussion on a cosmetic science topic.

[OldPerry]

He used to post in this forum more but stopped when he moved to the HI&I industry.  But here is a response from chemist Duncan Abbot that he had put on Facebook.  I thought it was pretty enlightening.

---

Err, yes no , maybe – It’s a bit more complicated than that.

Firstly they go on and on about “Paraffin” – and everyone will think of Kerosine / Esso Blue, whatever they put in camping stoves and the like.

Errrr No.

They are referring to materials like mineral oil (Baby oil is this with a dab o fragrance, and things like Vaseline) Not that flammable – yes they will burn, but they need a wick to do so convincingly – i.e. soaked sheets

If that happens, and the sheets or clothing are cotton based: well that’s not going to end well, as loads of kids found out in the 70’s with cotton nighties catching fire, with horrible results, before flame retardants were legally mandated for kids night clothing.

Secondly there is a big case for patient hygiene. If the sheets and clothing are that saturated with oil, they should be changed regularly, and washed, with a decent laundry detergent, that will suspend and remove oily residues. I am aware of a case where vegetable based massage oils have soaked into spa towels, they were laundered using cheap laundry detergent, and then ignited once they were removed from the tumble dryer.

The solution: Change your sheets regularly, Use a decent detergent, and a bunch of it. Hospitals should know this.

So this sensational story boils down to three things.

If you have to use emollients like E45, wash your sheets and nightclothes regularly using a decent detergent, on a good old hotwash, and if you see any staining from oil, wash them again.

Naked flames, and infirm patients never mix at the best of times

BBC Journalists need to get in touch with some-one with a bit of common sense and a modicum of science education

[OldPerry]

It’s hard to say from the info you gave. It could be air in the batch or it could be polymer kicking out of solution (or something else).  We’d need more information.

I don’t think lowering the pH is going to help with clearing it up but it might thin it out.

[OldPerry]

Visible light isn’t the problem that sunscreens are solving. SPF is a measure of how well a product protects against UV light.

Iron oxides also aren’t on the FDA’s list of sunscreen actives.
http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=352.10

[OldPerry]

@Zink - that is an interesting observation. When I first started in the cosmetic industry I would have agreed that most of the cosmetic chemists were men. But lately, I’ve noticed many more women coming in as chemists than men. If I had to guess men still outnumber women but the ratio is around 55:45.  Of course, that could just be my biased experience talking, I don’t know the actual numbers.