16 | www.CosmeticsandToiletries.com Vol. 130, No. 6 | July/August 2015
REGULATORY | C&T
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© 2015 Allured Business Media.
More than ever before, consumers are being bombarded with both positive and negative messaging about ingredients used in personal care products. As a result, more consumers are reading product
labels and driving demand for safer, and more natural, products in the
personal care space.
According to Kline and Company’s Natural Personal Care market report,
as of 2013, the global natural personal care market was $30 billion and has
grown at a double-digit pace since 2008. By 2018, it is expected to grow to
Another result of this mixed messaging is consumer confusion; specifically, confusion about what makes a product safer, and what makes a
product natural versus nature-inspired or pseudo-natural. For the most
part, governments have been silent to vague on this topic.
If the messaging is positive about a new natural ingredient then consumers will want products that contain that ingredient; consider the recent
keratin, and argan and marula oils trends. Industry responds by formulating
products with that hot new ingredient and, in some cases, positions the
product as more natural. The reality is the formula may only contain the
ingredient at trace levels. Existing regulations do not require a minimum
amount of a listed ingredient be used in a product; only that the ingredient
be present in the formula.
On the other hand, if messaging about an ingredient is negative,
consumers will want products that do not contain it—but they don’t always
understand why the ingredient is thought to be “bad.” Industry responds in
one of two ways: one way is to defend the safety of the ingredient, particularly if that ingredient has a long history of safe use and there is significant
data available. The second way is to reformulate and add a “free-of” claim
as it relates to the “bad” ingredient; paraben-free or sulfate-free, for example,
which validates the change and creates a new marketing opportunity for
It is in this area where new regulations are emerging. In the European
Union (EU), EU Commission Regulation No. 655/2013 has outlined
the common criteria for the justification of claims, including the type of
evidentiary support required to make cosmetic claims. Free-of claims may
not be made if the ingredient is already banned. For example, hydroquinone
Global Regulatory Associates, Inc., Raleigh, N.C.
The Regulatory Environment’s Confounding Nature
for Natural Personal
regulation • natural
ingredient • paraben
consumer • confusion
messaging • product
What makes a product
safe? What makes a
product nature-inspired or
and pending regulations—
and the mixed messaging
confusion for the
consumer and safety
dilemmas for product