Futurechat

The Indian drug and cosmetic act states specific standards for labeling, however it can be further strengthened by learning from other countries. In addition, I have listed down some additional recommendation that might be useful in making the products customer friendly.

Clarity of Communication – Further details on font, size, color, clarity of communication, label types as detailed out in US, FDA. It has been noticed that in Indian products, implementation of the spirit of the Indian drug and cosmetic act is frequently absent. Information is written in very small font, difficult to comprehend and sometimes obscured by vignettes that may obscure the lettering. Small size products, where the all information cannot be printed should appear on a tag, tape or card affixed to the container.

Language – While the act states that communication should be in English, I believe that in a country like India communication in a local language should also be made mandatory.

Ingredients - Ingredients are often written in the very small font size and more over the scientific naming of the ingredients makes it hard for a normal user to be able to know the risks involved. I believe that a centralized database should be maintained regarding the intensity of  all ingredients and products on human body.

Warning Statements - Caution statement should be included in all the cosmetic products, clearly mentioning that certain ingredients in the product might cause problems in certain individuals. While this is mentioned in the Indian drug and cosmetic act, and several suppliers do mention cautionary statements, many cosmetic products don’t.

Dermatological Testing Outcomes – Dermatological testing out comes should also be included along with the product, if not possible, should be posted on the websites of the brands.

Banned Substances – Certain ingredients, which are banned in other countries, should not be used in India. While this is regularly done by the Indian authorities a comprehensive database, available to the public on the web will increase transparency and ensure compliance.

Environmental Concerns – A statement that the ingredient used in the product or packaging do not cause any environmental problems should also be included.

This post is a concluding post in a series. The earlier posts are listed below

• The Lack of Beauty Information
• Beauty Products – Thoughts on Packaging and Labeling
• Information Map For Beauty Products
• Indian Standards for Cosmetics Labels
• Notes on Cosmetics Labeling Standards in the EU
• Notes on Cosmetics Labeling Standards in the US

Continuing on the theme of Cosmetics Labeling Standards , the follow are my notes on US Standards.

A label may consist of more than one panel. It may consist of a front panel, side panels and a back panel. Back and side panels are generally called information panels.

The “principal display panel” is that part of a panel that is most likely to be shown or examined under customary conditions of display for retail sale. Usually, it is the front panel of the label of the outer package.

Labeling

The following information must appear on the label of the outer container, which usually is a box, folding carton, wrapper etc. holding the inner (immediate) container.

Principal display panel
Name of product
Identity
Warning
Net quantity of contents

Information panels
Directions for safe use
Warnings
Name and place of business
Ingredient declaration
Another required information

The following information must appear on the label of the inner (immediate) container holding the cosmetic product.

Front panel
Name of Product

Information panels
Directions for Safe use
Warnings
Name and Place of Business
Net Quantity of Contents
Any Other Required Information

Panel display: The required information must be on a panel, which is presented or displayed under customary conditions of purchase. This eliminates placement of required information on a bottom panel of a cosmetic unless it is very small and customarily picked up by hand where inspected for possible purchase.

Panel Size: The label must be large enough to provide sufficient space for prominent display of the required information.

Style and Size of Letters: The type must be of such size, and at least of the required minimum size, and have such style that the required label statements are easily readable.

Ingredients: 1/16″ / 1/32″(labeling surface, less than 12 sq. in.)
Net contents: 1/16″ (PDP Less Than 5 Sq. In.) / 1/8″ (PDP 5-25 Sq.In.) / 3/16″ (PDP 25-100 Sq.In.)
Warning: 1/16″

Letter Height: The lower case letter “o” or equivalent when upper and lower case letters are used.

Background Contrast: The contrast must be sufficient to make the required label statements conspicuous and easily readable.

Obscuring Designs, Vignettes: The required statements must not be obscured by vignettes or other designs or by crowding with other printed or graphic matter.

Name and place of business

The name and business address appearing on the label may be those of the manufacturer, packer or distributor.

Corporate name
Manufactured for …
Distributed by …
Address
Principal place of business

Location: If the cosmetic is sold at retail in an outer container, the net contents statement must appear (1) within the bottom 30% of the PDP of the outer container, generally parallel in line to the base on which the package rests, and (2) on an information panel of the inner container. The bottom location requirement is waived for PDPs of 5 square inches or less.

The PDP may be a tear-away tag or tape affixed to a decorative container or to a container of less than 1/4 oz., or it may be the panel of a display card to which the container is affixed.

Prominence: The declaration must be a distinct item, separated from other printed matter by a space equal to at least the height of the lettering used in the declaration and twice the width of the letter “N”.

Conspicuousness: The print must be easily legible bold face type in distinct contract to background and other matter on the package. The letter height must be at least that of the lower case letter “o”, and the aspect ratio of height to width must not exceed 3:1.

The type size, should be same as mentioned in labeling.

Warning Statement

Regulations also require that the label of a cosmetic product shall bear a warning statement whenever necessary or appropriate to prevent a health hazard that may be associated with the product.

Prominence: A warning statement must appear on the label prominently and conspicuously as compared to other words, statements or designs so that it is likely to be read by ordinary consumers at the time of purchase and use.

Conspicuousness: The lettering must be in bold type on contrasting background and may in no case be less than 1/16 inch in height.

Language Statement

All label or labeling statements required by law or regulation must be in the English language.  If labeling bears foreign language representations, the required statements must appear on the label or other labeling as required in English.

Ingredient labeling

The ingredient declaration may appear on any information panel of the package, which is the outer container in form of a folding carton, box, wrapper etc. if the immediate container is so packaged, or which is the jar, bottle, box etc.

Prominence: The declaration must appear with prominence and conspicuousness so that it is likely to be read and understood (read with ease) by ordinary individuals under normal conditions of purchase. The letters must not be obscured by design, vignettes, background or crowding.

Type Size: Not less than 1/16 inch in height. It may be not less than 1/32 inch in height if the total surface area available to bear labeling (which excludes bottom, shoulder, neck, flange, decorative or sculptured surfaces) is less than 12 square inches.

The type size consisting of upper and lower case letters is determined by the height of the lower case letter “o”.

Continuing on the theme of Cosmetics Labeling Standards , the follow are my notes on European Union Standards .

Labeling

Containers and/or packaging must bear, in indelible, easily legible and visible characters:

The name or trade name and address or registered office of the manufacturer or of the person responsible for marketing the cosmetic product within the Community;

The nominal contents at the time of packaging, by weight or by volume;

For products with a minimum durability of less than 30 months: the date of minimum durability indicated by “Best used before the end of…”;

For products with a minimum durability of more than 30 months: the period of time after opening for which the product can be used without any harm to the consumer (this information is indicated by a special symbol representing an open cream jar);

Particular precautions for use;

The batch number or product reference to permit identification;

The product function.

This information must be in the national or official language or languages of the respective Member State. Moreover, the label must contain a list of ingredients, in descending order, preceded by the word “Ingredients”.

If the pack size is small, still the manufacturer or importer has to attach the details of the products, as it should appear in the label by tagging it to the product.

Ingredients / Composition

The Directive sets out a list of substances, which cannot be included in the composition of cosmetic products, and a list of substances, which cosmetic products may contain only under the restrictions and conditions, laid down

The Cosmetics Directive also contains lists of colourings, preservatives and UV filters permitted in cosmetic products.

Bans the test of products on animals and also bans certain ingredients that may cause problems to the people.

Animal testing

The Directive puts an end to animal testing by imposing bans on:

Testing finished cosmetic products and ingredients on animals (testing ban);

Marketing finished cosmetic products which have been tested on animals or which contain ingredients that have been tested on animals (marketing ban).

My earlier blog posts touched on aspects of label communication usability.

In this mind map an attempt has been made to put together a series of thoughts on the information provided by 2 manufacturers, Hindustan Unilever for Ponds Age miracle and Garnier Skin Naturals Light. It is not an attempt to highlight any shortcomings, but just a simple analysis from my perspective of what I read  and what it means to me.

You can also see it here

Are you worried when you hear about the adulteration in foods, the harmful effects of plastics and general hype about chemicals used in cosmetics, shampoos and soaps? I know that I have started becoming really wary of the marketing hype surrounding new product launches and miracle cures.

Last Sunday, when I was giving a fantastic performance of imitating a couch potato I was woken out of my reverie when I saw the Garnier ad promoting a fairness cream followed up by Ponds ad also offering similar benefits.  It wasn’t the ads that woke me up, but the dissimilar tag lines Garnier offered a cure from age spots in 1 month whereas Ponds just 7 days.

Every summer my sister and I suffer the freckles that spot our faces and we often debate what to do about them. One summer Aloe Vera was tried, another summer Multani Mitti pack, a more recent addition has been a Lakme sun screen which has had no effect. Just a few days back my sister went out to get herself a Ponds, while I have been using the Garnier.

But having paid no attention to TV for a while I have probably missed the communication behind these products. When I did pay attention, this sunday, I was assailed with doubts. Which were further strengthened when I realised that the product labels on the jars don’t seem to say anything at all.

I have 2 fundamental concerns

Who do we ask?
If  an ad promises 7 days vs another promising a clear skin in 30 days. Is  the  first cream stronger than the other? Can it then harm my skin? Who do we ask? Should one ask the company or is there anyone else who can give a balanced scientific view?

Why is there no information?
At first glance there seemed to be no information on the jars or on the websites of both companies.
When I mentioned this to my sister, she remembered seeing the ingredients on the cardboard boxes the jars came in. So, I promptly brought a jar of each. And yes, they both have ingredients on the outside covers. But, is it just me who throws the boxes away and keeps the jars? I asked a few friends and none of them ever keep the boxes! So,there…..

Now that, I stand corrected. so change the above heading to

Why is there no clarity of information?

• If the product is being advertised so heavily, while stating that it has natural ingredients(Garnier Skin Naturals), how much of Vitamin C and Lemon Extracts, does it have? Is it then a ‘Natural’ / ‘Herbal’ product?

• Also why does the product not exist on the corporate website with detailed description. As of writing, The Garnier page on the L’Oreal India website does not mention any products  . The Garnier International site does not mention India as a country it operates in! While I am ready to acknowledge that L’Oreal does have a complete section on the research behind the products. In the absence of clarity on a specific product, questions remain unanswered.

• The Ponds India site specifies the India products but falls short of detailing out ingredients  on the website, other than basic information about Advanced CLA4 Complex. Though I honestly don’t know what that means, it also raises a doubt, ‘What on earth is CLA4?’

In addition to all the confusion above, the tuesday morning article in Times of India on ‘Site to tell you what labels don’t has worried me no end. The web is awash with information on the harmful effects of chemicals in cosmetics. Take a look at ‘Skin Deep’ and ‘Good Guide’. Even worse is a statement made by Environmental Working Group that states that the US FDA does not mandate safety checks on cosmetics.

So my question to you is ‘What is the price of beauty? Are we impacting our health for short term looks?

So, let’s take a detailed look at some of the issues.

Labeling

• What are the international and domestic labeling norms.  Is compliance to domestic labeling standards enough? Or is the Indian consumer wanting more? Should labels exist on product packs and on inside jars / tubes etc.? Could the labels be a bit more user friendly?

Web

• What role does the web play in information dissemination?  And does it clarify  or confuse?  What is the role of corporate / product sites? Should product rating sites be trusted?

Natural versus Chemical

• Everyone is proclaiming themselves to be green.  How can we believe anyone?
• Should we buy products that proclaim that they are Ayurvedic  or 100% natural, or others that clearly state that they use chemical compounds which have been tested for safety?
• My bottle of Forest Essentials shampoo states that some people might be allergic to some ingredients. Does it mean that ‘natural’ may not necessarily mean safe, just as ‘chemical’ may not necessarily mean unsafe?

Regulatory body

• Do we need a regulatory body that  transparently evaluates  formulations and makes this information known publicly?

My subsequent posts, will cover each of the topics listed above.