“Change is the law of life” John F. Kennedy American President (1917-1963)
Consumers or customers holds the right to know about what they subject their body to. Generally, cosmetic companies declare a list of ingredients in descending order of quantity on product labels except for trade secrets. Companies do not disclose most of the fragrance and flavor ingredients because “fragrances and flavors” probably falls under the umbrella of “Trade secrets.” However, the Fair Packing and Labeling Act (FPLA) of US FDA recommends mandate listing of ingredients with concentration levels above 1% followed by a flexible listing of ingredients that do not exceed 1% on a case-by-case basis (1). On the other side of the world, Europe almost follows the same process, and additionally, it mandates fragrance disclosure if it crosses the levels of 100 ppm (for rinse-off products) and 10 ppm (leave-on-products) (2)
The ingredients that have a concentration of ≤1% could be listed based on the availability of space on the label and various other factors which left to the discretion of manufacturing and marketing company. Surprisingly, cleaning products are not governed by FPLA which made customers or consumers spring to action to get a chance to know about the ingredient levels in cosmetics (levels ≤1%) and cleaning products (any level). The frequency exposure to cleaning products is, in fact, higher when compared to cosmetics because of the amounts used in daily life.
Today, giant global companies are seen taking bold decisions where they voluntarily disclose or share the ingredients list showing the composition up to ≤1% in the products.
To name a few:
- Procter & Gamble
- SC Johnson’s
- Johnson & Johnson
- Amazon etc.
P&G came up with the road map to disclose ingredients for fabric, home, and beauty care products (up to 0.01%) at the end of 2019 in the US and Canada P&G News. (3) Unilever has already trodden the same steps and completed ingredient disclosure for its home, beauty, and personal care products in Europe and the US with the creation of focussed webpages for their product ingredients (4). Walmart took significant steps for ensuring transparency under sustainable chemistry policy and in fact, started the ingredient disclosure way back in 2015 for its private brands (5). Johnson & Johnson launched the website for their baby care products to disclose the entire ingredient list with no exceptions (6). The online retail giant Amazon is set to follow the footsteps of branded cosmetic and consumer companies regarding the transparency of ingredients according to the recent chemical management policy released by them (7). Above all, it is appreciable that SC Johnson is a first global company who initiated ingredient disclosure program in 2009, and to penetrate this program to every corner of the World, SC Johnson started providing the ingredient information in 35 languages (8)
A lot of Non-government Organization (NGO’s) express their appreciation for this breakthrough decision by global market players. This decision could be a result of the legal “Right to know act” of US (1986) or customers changed the direction of thought towards demand and accept the products they know well. Regardless of what might be, today’s scenario reflects on the evidence that to gain customer or consumer trust, companies must move out of the conventional box of thinking for ultimate business success. P&G plans to go the extra mile to understand the cumulative exposure of ingredients by providing additional information on where else these ingredients are be found, such as everyday fruits, foods, etc. Unilever disclosed the ingredients of top products like Dove, Axe, Degree, Nexxus, Suave, Tresemme, and Vaseline. It’s Interesting that companies like Coca Cola, Colgate-Palmolive, Hershey, Kellogg’s, P&G, SC Johnson, and Unilever have already put forward transparency of ingredients through the App named “Smartlabel App” that could help customers with the information about product, ingredients in products, any allergens, certifications associated with it and many (9). The most crucial step Unilever took is to design a Suppliers-Responsible sourcing policy which imparts clear lines of responsibility to its chemical suppliers. Moreover, California passed “Cleaning Product Right to Know Act”, authored by Senator Ricardo Lara, Senate Bill 258 which would make California the first state to require ingredient labeling for natural cleaning products used by millions of consumers and workers daily (10). Walmart’s disclosure policy has made in alignment with California “Cleaning Product Right to Know Act” to ease product suppliers, wherein product suppliers need to follow California’s hazardous chemicals list. No specific harmful chemicals list exists for Walmart as they prefer California’s hazardous chemicals list. It is interesting to note that Amazon plans to disclose the information in their website with the support of third-party certifications, such as Safer Choice, Made Safe, Green Seal and Cradle to Cradle (7)
Today, customers’ purchase decisions are based on the use of ubiquitous mobile technology where customers hate to wait for a long time to know about the product when they are in a Supermarket. Customers love to get swift information through technology and the interested product in front of eyes while shopping. I feel all giant global companies rather than providing a comprehensive list of product information in their webpages can use unique App technology to answer the customer’s inquisitiveness which would further foster their business.
This pragmatic shift by global companies reflects the fact that end-users like customers or consumers changes the operation process. Nevertheless, it is fair to applaud these global companies who come up with best and bold decisions. I feel labeling of an extensive list of ingredients and their respective levels of safety on product label remains tedious, and no more a viable option considering the limitation of the size of the outer product cover. I concede with the move of some companies to turn into mobile-based smart label applications for delivering the product information to the customers.
Additionally, I feel it is evident that giant global companies have the power to implement the change and ask to follow it for its supply chain. However, it cannot be the same for medium-sized companies and small-scale companies who also disseminate products to common people all over the world. Therefore, government policies and the law should only drive this change (transparency of ingredients), like what the California government has done.
During my research and review on this topic, I popped up with this question!!
“Does disclose alone the ingredients up to 0.01% or (100 ppm) will take care of endocrine-disrupting chemicals, which show their adverse effects at still low levels??” This need debate!!
- Food and Drug Administration-Cosmetic Labeling Guide
- Labelling of ingredients In Cosmetics Directive 76/768/EEC” (February 2008)
- P&G News. P&G Expands Transparency Commitment to Include Fragrance Ingredients across Product Portfolio.
- Unilever Press Release-Unilever delivers enhanced ingredients transparency for its home, beauty and personal care products
- Walmart 2016 Global Responsibility Report
- J&J Latest news-Johnson’s® Baby Unveils a Groundbreaking 100% Ingredient Transparency Disclosure For Its Products
- Amazon Sustainability-Responsible sourcing
- SC Johnson Press-Release- SC Johnson Keeps Global Promise, Expands Ingredient Transparency to Latin America
- Smartlabel App
- California Legislative Information. SB-258 Cleaning Product Right to Know Act of 2017.
Pradeep Dadisetti, Lead – Toxicology at FMD K&L
Pradeep is an experienced toxicologist, who brings on to the desk the adept combination of lab side Regulatory toxicology (GLP-OECD testing) and bench side regulatory toxicology (REACH, US EPA, UN-GHS, Safety assessments, PDE, OEL, etc). Trained for Regulatory Chemical safety assessments. By qualification Pharmacologist and Toxicologist, had a past experience in Inflammation mediated cancer, mouse models and several molecular biological techniques. Industrial experience in Regulatory Toxicology in a GLP setup carrying out core battery toxicology testing for global clients and currently actively involved in Chemical and pharmaceutical regulatory assessments and data mining. He supports additional ethical angle- alternatives to animal testing and certified to perform in-vitro skin safety testing by Skinethic Academy (L’Oreal). He loves to apply toxicology for current living conditions of human and society.