Thursday, September 15, 2016

Weekday Wonderings: Do you have to declare all the ingredients in a product? This, and reviewing how to read ingredient lists...

In this post, Grapefruit seed extract is NOT a preservative, Dedra asks: I have a question about a particular product. It is called Fig and Yarrow Underarm Lotion. I noticed that this product didn't have any preservative listed. I am sensitive to certain things so I emailed to ask them if their product had any preservatives. They replied saying it was "naturally preserved". Given what you have written, I am not sure what they could mean by this. 

Is it a law or rule that you must have ALL ingredients in a product listed? Could they simply be leaving out this information? 

I also read on another site some time back that many companies "hide" the fact that their products have preservatives in aloe gel. The article said that aloe gel cannot be produced without using a preservative, therefore any product that has aloe gel likely already has enough preservative and you may not need to add additional preservatives due to this. Could it be that they are getting their aloe gel from a supplier who already is using a preservative, therefore they do not have to use any additional preservatives? Or, because there is no water in their product, perhaps they don't need a preservative??? But I thought if a product has aloe, you HAD to have a preservative??? 

Here is their list of ingredients. What do you think is happening here? I would like to order their product but would also like more clarity on which preservative, if any, they are using. 

Aloe barbadensis (aloe) gel*, Hamamelis virginiana (witch hazel) extract*, Zinc oxide, Cocos nucifera (coconut) oil*†, Sage extract (neutral cane alcohol*, Salvia officianalis*), Glyceryl stearate, Sodium bicarbonate (baking soda), Cetearyl alcohol, Citric acid, Sodium stearoyl lactylate, Glycine max (soy lecithin)*, essential oil of: Aniba rosaeodora (rosewood).

You've asked a number of really great questions, and I think we'll have to spend a few days getting to each one, if you'll indulge me!

The short answers are...
  • I have no idea what "naturally preserved" means because there's no definition for the word "natural".  
  • Yes, a company has to declare all their ingredients in the ingredient list. 
  • If you have water or water soluble ingredients, or if the product will be in contact with water, like a body scrub, you must use a preservative. 

Firstly, let's take this opportunity to review how to read an ingredient list, then look at what's required. Ingredients should be listed in descending order of use. The first ingredient should should be the ingredient used the most. In lotions, it tends to be water. The next should have the second most, and so on until you reach ingredients that are used at 1% or less in the product. These still need to be listed, but they don't have to be in order.

Check out this post on reading ingredient lists and the 1% section

In Canada, the States, and the EU, ingredients need to be listed by their INCI or International Nomenclature of Cosmetic Ingredient name. That's the name we see when we see water listed as "aqua" or the botanical name of an oil, like Orbignya Oleifera (Babassu) Seed Oil for babassu oil.

In Canada, the ingredient must use the INCI name from the most recent edition of the handbook, the tenth edition. In America, "it is still permissible to use the 2nd Edition CTFA Ingredient Dictionary INCI names for many ingredients", although it's up for review. (Thanks, Lotioncrafter, for this information!)

You must include every ingredient in the product in the ingredient list. You cannot leave out information on ingredients found in the product. 

Related posts:
What's an INCI name?
How to read an INCI name (part one)?
How to read an INCI name (part two)?

If you want to learn more about labelling in Canada, click here
If you want to learn more about labelling in the States, click here. 

Let's look at an example of one of my products to see how I'd write up the ingredient list. How 'bout this one for one of my favourites, babassu and kukui nut oil lotion with Ritamulse SCG.

60% water
3% glycerin
0.5% allantoin

8% Ritamulse SCG
12% babassu oil
12% kukui nut oil

3% honeyquat
0.5% liquid Germall Plus
1% fragrance oil

If we list in this in order we would have...
60% water
12% babassu oil
12% kukui nut oil
8% Ritamulse SCG
3% glycerin
3% honeyquat
1% fragrance oil
0.5% allantoin
0.5% Liquid Germall Plus

My ingredient list could look like this...
Water (aqua), Orbignya Oleifera (Babassu) Seed Oil, Aleurites moluccana (kukui) seed oil, Ritamulse SCG (Glyceryl Stearate (and) Cetearyl Alcohol (and) Sodium Stearoyl Lactylate), Glycerin, Hydroxypropyltrimonium Honey, Parfum, Allantoin, Liquid Germall Plus (Propylene Glycol, Diazolidinyl Urea, Iodopropynyl Butylcarbamate)

You can see that every ingredient in the product is in the ingredient list using its INCI name.

In some situations, we have to break down the ingredients that consist of more than one thing - like the Ritamulse SCG, and liquid Germall Plus.

I know Ritamulse SCG has these ingredients at these percentages.
Glyceryl Stearate                       55-65% - I'll average at 60% - 8% x 0.6 = 4.8%
Cetearyl Alcohol                        20-30% - I'll average at 25% - 8% x 0.25 = 2.0%
Sodium Stearoyl Lactylate        10-20% - I'll average at 15%  - so 8% x 0.15 = 1.2%

As for liquid Germall Plus, I know it consists of...
60% propylene glycol - so 0.5% x 0.6 = 0.3%
39.6% diazolidinyl urea  - 0.5% x 0.396 = 0.198%
0.6% iodopropynyl butylcarbamate  - 0.5% x 0.006 = 0.003%

New list...
60% water (Aqua)
12% babassu oil (INCI: Orbignya Oleifera (Babassu) Seed Oil)
12% kukui nut oil (INCI:Aleurites moluccana seed oil)
4.8% glyceryl stearate
3% glycerin
3% Honeyquat (INCI: Hydroxypropyltrimonium Honey)
2% cetearyl alcohol
1.2% sodium stearoyl lacylate
1% parfum
0.5% allantoin
0.3% propylene glycol
0.198% diazolidinyl urea
0.003% iodopropynyl butylcarbamate

So my ingredient list would look something like this...
Water (aqua), Orbignya Oleifera (Babassu) Seed Oil, Aleurites moluccana (kukui) seed oil, Glyceryl Stearate, glycerin, Hydroxypropyltrimonium Honey, Cetearyl Alcohol, Sodium Stearoyl lactylate, Parfum, Allantoin, Propylene Glycol, Diazolidinyl Urea, Iodopropynyl Butylcarbamate

You'll note that every ingredient I use in the product, including ingredients found in more complicated ingredients like liquid Germall Plus, has to be included in the list.

So the long answer is still - a company has to declare every ingredient in their product.

Okay, that's way too much for one day...Join me tomorrow as we take a closer look at these ingredients! (Hit "newer post" at the bottom to see it)!


firegirl said...

The other day I saw a product that was 'self-preserving' - a face/body scrub with tofu as one of the ingredients in fact. I suspect that tofu might not be an INCI ingredient. I suspect the perfume (a not a small amount) is used to preserve the product (the company that produces this is well-known for its rather fragrant shops - ahem). What is going on here?


Unknown said...

Anne, I too was on that exact same website looking at the exact same self-preserving item containing Tofu. Funny thing was, I have a mini tub of that product sitting at home, but it doesn't list tofu on it and there were a few other ingredient differences. I think they sell two different versions of the same product (I found the second version, the one that doesn't contain Tofu on the US website). I am very curious as well how that company is getting away with it and what exactly is preserving it. I cannot imagine that tofu is a preservative. Things that make you go *hmmm*


Vicki said...

Speaking of ingredients, what ingredient is it in a shampoo or hair conditioner that "enhances curls" or somehow makes the product good for curls?

Vicki in California

Kimberley Scanlan said...

I'm interested in that too Vicki :) And also what ingredients we could use to enhance hair colour. I always see shampoos marketed for that.

Niki1695 said...

Hi, thank you for a nice explanation on how to count/list INCI ingredients. What about the case when the exact content in % of a composition raw material is not disclosed, neither in technical data sheet nor in CofA/MSDS?


Do you mean like on a supply store website? I was wondering this as well? I've been to a couple that have full disclosure on their products then I have been to some where they have such things as body/linen spray and only INCI is perfume?

firegirl said...

Kaylee, I was also wondering about the use of fragrance by the same company. Surely you couldn't achieve such strongly-smelling products by using fragrances at the recommended rates? I use my solid shampoo bar as room fragrance by leaving the tin open. However, I made Susan's solid shampoo bar with 2% essential oils and 1% fragrance oil and the smell is light and pleasant.

Eric Winter said...

Actually, in some cases, preservatives used in ingredients can be omitted from the ingredient list. In the CFR section 701.3 subsection (l), we find:

"(1) Substances that have no technical or functional effect in the cosmetic but are present by reason of having been incorporated into the cosmetic as an ingredient of another cosmetic ingredient."

So, if you're using a low percentage of an ingredient that is itself preserved, the preservative in that ingredient will have no functional effect in the finished product and can be omitted. The exact limits of what constitutes "no technical effect" are not seemingly defined but I think you could clearly leave off the 0.1% benzoic acid in an alcohol-free witch hazel when you use it for making bath bombs or at 5% in a lotion. If in doubt, list it.

In the example given above of underarm lotion, the preservatives in the aloe gel and witch hazel are clearly being omitted in non-legal manner since they are the major ingredients in the product and still at functional levels. Most likely they are benzoic acid and/or sodium benzoate and potassium sorbate.

Dervla said...

Love your blog. I have learned so much from you.My question is: Where can I find the % breakdown of ingredients like BTMS-50. You note that "In some situations, we have to break down the ingredients that consist of more than one thing - like the Ritamulse SCG, and liquid Germall Plus." I checked the MSDS sheets and it is not given there.

Susan Barclay-Nichols said...

Hi Dervla! Thanks for your kind words! I would ask your supplier for that information. I can't find it on my information about this ingredient either. I would also check with your health department or ministry that regulates cosmetic listings and see how they would suggest you list this, if you're thinking about how to put together an INCI list for a product. Sorry I can't be more helpful.