OldPerry
Forum Replies Created
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@PeaceLoveOrganics - send me a message and let me know what the new name you want. I can change it.
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Well, better to only lose $50 than lose your house in a lawsuit.
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@PeaceLoveOrganics - no, being COSMOS certified will not mean anything legally in the US. It’s an EU standard. But you can test the legal system. Get a good lawyer, make your case and maybe you’ll win. It’s not a risk I would take but as I said, I’m not a lawyer.
Yes, USDA standards are not realistic for the vast number of cosmetics. Cosmetics are different from food. They are not natural.
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@RDchemist15 - great questions.
My advice to follow USDA guidelines if you are making the claim is strategic. I’m not a lawyer and this is not a question of science or chemistry.
What I do know is that California has a law related to the labeling of the term “organic” as used in cosmetics. Their law is enforceable.
http://www.fdalawblog.net/2012/08/california-labeling-requirements-for-organic-cosmetics-not-preempted/The California Organic Products Act of 2003 (“COPA”) prohibits any product handled, processed, sold, advertised, represented or offered for sale in California from being sold as organic unless it is labeled with terminology similar to terminology set for in the regulations by the National Organic Program (“NOP”). COPA specifically applies to cosmetic products sold or labeled as organic or made with organic.So, if your product ends up for sale in California (whether you brought it there or not), you better be following the COPA labeling rules or face a fine. There are lawyers in California who specifically look for products that use the term organic. They will sue you and you will have to prove that you are following the USDA organic product rules.
You’re right the USDA does not have authority over cosmetics. They have created guidelines for companies who want to make organic claims for cosmetics. The FDA says “Cosmetic products labeled with organic claims must comply with both USDA regulations for the organic claim and FDA regulations for labeling and safety requirements for cosmetics.”
https://www.fda.gov/cosmetics/cosmetics-labeling-claims/organic-cosmetics -
PeaceLoveOrganics said:@Perry actually found a great post if anyone else asks. http://theorganictarian.com/discover-5-benefits-aco-usda-organic-standards-certification-products/
This article is terrible and should be ignored. Anyone who claims this…
“You are what you absorb, so why is the average woman putting 120 chemicals on their bodies every day? Most of them untested. Many linked to cancer or reproductive issues.”
…is misinformed at best and lying at worst. I wouldn’t trust them to walk my dog.
Most of the chemicals that that average woman puts on her body HAVE been safety tested. They have not been linked to cancer or reproductive issues. Here’s a simple thing you can do if you are skeptical of my claims.
1. Get the ingredient list of a standard cosmetic product.
2. Count how many ingredients there are
3. Look up the safety information about each ingredient on the Cosmetic Ingredient Review site. https://cir-safety.org
4. See how many are not listed (I bet pretty much all are except maybe the natural extracts).The things that haven’t been tested are not commonly used in cosmetics. The fact that other countries ban ingredients is only a result of the fact that they ban ingredients that no one uses in cosmetics. Jet fuel is banned from cosmetics in the EU but not in the US. It’s a pointless ban. but I digress…
USDA is the most strict standard. It’s also the hardest to follow if you want to make functional cosmetic products that people want to use.
But if you want to make the claim “made with organic materials” you better follow the USDA NOP guidelines (at least if you are going to sell in the US).
https://www.ams.usda.gov/sites/default/files/media/OrganicCosmeticsFactSheet.pdf
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Interestingly, at the company I worked we would have a lot of QA/QC samples that were taken off the production line. They would be opened and a sample was taken out to run QC checks. Those practically full bottles were then gathered in a bin and ultimately destroyed (or taken home by R&D chemists).
Someone once made the suggestion to donate those products to shelters or charities and our legal department said we couldn’t do it for liability reasons.
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The answer to your question depends on a couple of factors.
1. If you are selling cosmetic products in the US and you want to use the term “organic” you should follow the USDA NOP Organic standards. (https://www.ams.usda.gov/sites/default/files/media/OrganicCosmeticsFactSheet.pdf) If you do not, lawyers in California and around the country will likely sue you.
2. If you don’t want to follow the USDA standards, don’t use the term “organic.” Stick with “natural” or “green” or something like that.
3. If you are formulating natural, there is no standard legal definition for the term. This isn’t to say that there isn’t a legal definition. The FTC has fined companies for claiming 100% natural when they are using synthetic chemicals.
https://www.ftc.gov/news-events/press-releases/2016/04/four-companies-agree-stop-falsely-promoting-their-personal-care4. If your consumers find Ecocert or COSMOS certification compelling then they are worth following. The reality is that most consumers have no idea what Ecocert or COSMOS are. You could just as easily come up with your own standard, create your own graphic seal, and certify yourself following your own natural standard.
If you want to be as “organic” as possible the first step is figuring out what you mean by that. The reality is that cosmetics are not natural. Pretty much all of them require some kind of human processing and most require non-natural chemical reactions to produce functional chemicals like surfactants, thickeners, preservatives, colorants, etc.
Groups like COSMOS or Ecocert have relaxed their natural standards over the years so they allow some ingredients produced via synthetic chemistry. They had to do this to expand the number of customers who would certify products.
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I was wondering about that. Why would the FDA contract with a company that is under investigation by the FBI?
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Yeah, it depends on a lot of factors. Some people might charge as much as $25,000 or as little as $500. I guess ultimately the answer is charge as much as the client is willing to pay.
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What they are doing is probably not legal.
I’ll preface this by saying I’m not a lawyer & this is my non-legal opinion. I suppose if they got the product and then did stability testing and microbial challenge testing to demonstrate safety, they could probably defend themselves in court. They would probably lose but at least they would have an argument.
I don’t believe the FDA would approve of this sales technique because safety cannot adequately be proven.
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Your question “would this work well” is a difficult one to answer because the answer depends on what you define as “working well.” The experience of a shampoo, the lather, the way it leaves hair, the rinsability, etc. is a subjective measure. Whether you, or more importantly your consumers think it works well is the most important factor and that is not an answer anyone on this board can give you.
I can tell you that when I was involved in a blinded, home use test of the top selling shampoos the one that performed the best contained Sodium Lauryl Sulfate, Sodium Laureth Sulfate and Cocamidopropyl Betaine. Alternative surfactant systems were not as well liked by consumers.
However, that test compared the formulas with a general group of consumers. It didn’t test it with your consumers. Consumers were also blinded to the ingredients they were using.
All this is to say that maybe Disodium Laureth Sulfosuccinate will work for your consumers, or maybe it won’t. You have to try it and see.
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Yep, ceramides aren’t cheap.
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In my opinion, if you are using standard humectants, occlusive agents, and emollients you will see no benefit from using willowherb. This is a “claims” ingredient that helps tell a story but doesn’t have a consumer noticeable effect.
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Sure. I just don’t want the idea that these alternative preservatives are “good choices for most cosmetic formulas” to be propagated unchallenged.
They certainly can work in specific instances but they are not generally good choices.
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It’s unlikely consumers will notice any difference so it probably doesn’t matter.
Use glycerin ones because then you at least get some humectancy.My recommended use level is 0.1 %
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@Pharma - I didn’t thoroughly review her website so have no basis for disagreeing with your assessment. I agree just because a brand claims it’s “science based” doesn’t really mean that it is.
I know it’s just a name but a term like Chakra sets off my skeptical alarms as it is the kind of thing that woo woo peddlers use. It encourages “magical” thinking and short circuits rationally based beliefs. At best marketing hype and at worst scammy.
This type of thing probably appeals to consumers but in my view, scientists should not encourage it.
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For your body, washing hands with soap and water is better than hand sanitizer. Most important is that it removes the virus from your body even if it isn’t killing it.
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@EVchem - the word “Chakra” is a red flag for me. It says to me “not science based.”
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@PeaceLoveOrganics - no, not for most formulas. Benzyl Alcohol is a known allergen. Organic acids destabilize emulsions.
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In my view this is just lazy, unfocused formulating. There is no good reason to include 7 surfactants in a shampoo. You can make a good shampoo with 2 or 3 surfactants.
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Fatty alcohols are used in shampoos to make the product look opaque. They aren’t put in there for any functional benefit. They will actually slightly reduce the effectiveness of the shampoo. A better option would be Glycol Monostearate as a pearling agent.
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The INCI name according to the manufacturer is…
Glycerin & Water & Quillaja Saponaria Wood Extract & SaponariaOfficinalis (Soapwort) ExtractYou should still use a preservative if you use this, it has water in it.
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ACV doesn’t have any hair benefits so any level you use is going to be for marketing reasons or to reduce the pH of your formula.
The amount you use to reduce the pH depends on what else is in your formula.
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1. You must list every ingredient you put in your formula.
2. You have to list things in order only if they are in the formula in a percentage higher than 1%.
Ingredients above 1% use level have to be listed in order of concentration.
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I would think, the less chemical exposure to a baby the better. So keep it simple and don’t use any extracts. Not only do you not have any way of knowing what is actually in an extract, they don’t provide any benefit.
I’m a big believer in keeping things simple. Less ingredients is better.
You really don’t need anything more than Petrolatum.