Cosmetics Regulations - USA vs EU
Saturday, October 2, 2010 at 3:05PM 
Being an American expat living in London, or more correctly being an American/British dual national living in London, I take a lot of pride in both nations and am constantly playing one nation off against the other to anyone who will listen. For example to the Americans I brag about how in old Blighty we get more vacation time, better vacation destinations (in 2 hours you can be in Rome, Barcelona, Paris!),and how consumers and employees have better legal protection. To the Brits I brag about the great American holidays 4th of July, Thanksgiving, the lack of bureaucracy, the great customer service, and all of the space (from national parks to homes, to the width of the roads).
One of the great things about living in Britain (apart from everything mentioned) above is the European Union consumer protection around synthetic chemicals in beauty products. In the US the FDA does not regulate what beauty companies can and cannot put in personal care products, unless the product is considered a drug. Let me repeat that: the FDA does not regulate what beauty companies can and cannot put in personal care products. Pretty shocking no? If it’s any consolation though Botox is considered a drug and in 2009 the FDA started requiring that manufacturers of botulinum toxin put labels on the bottles regarding the risk of adverse events when the toxin spreads beyond the site where it was injected). Of course the consumer is unlikely to see the label when they visit their cosmetic surgeon but progress is progress. One of the reasons why I especially fly the EU flag on consumer protection in personal care products is the fact that only 9 chemicals are banned for use in personal care products in the US whereas over 1100 are banned in the EU. It might seem like 1100 is a lot (especially in comparison with 9) but considering the tens of thousands of chemicals out there, it’s not really. Plus I’ve never seen in any country a label on a beauty product like this:
What got me thinking recently about the differences between US and EU regulation (or lack of!) was when I noticed on the back of my Korres Evening Primrose Eye Cream two different ingredient lists – one for US and one for EU. It’s a shame that beauty companies who reformulate their products to pass the EU standards don’t just use the same formulation for the US market. Seems like double work to me. Here are the two lists:
US label:
Active ingredients: ZINC OXIDE
Other ingredients:
WATER, C12-20 ACID PEG-8 ESTER, GLYCERYL STEARATE, BUTYLENE GLYCOL, GLYCERIN, C12-15 ALKYL BENZOATE, ISODECYL LAUATE, COCOGLYCERIDES, OENOTHERA BIENNIS (EVENING PRIMROSE) OIL, PEG-100 STEARATE, OLIVE OIL (OLEA EUROPEA) UNSAPONIFIABLES, SIMMONDSIA CHINENSIS (JOJOBA) SEED OIL, CETYL ALCOHOL, AMORPHOPHALLUS KONJAC ROOT EXTRACT, FRAGRANCE, LACTIC ACID, LONICERA CAPRIFOLIUM (HONEYSUCKLE) FLOWER EXTRACT, LONICERA JAPONICA(HONEYSUCKLE) FLOWER EXTRACT, PANTHENOL, PHYTONADIONE, POLYHYDROXYSTEARIC ACID, RUSCUS ACULEATUS (BUTCHERBROOM) EXTRACT, SODIUM ASCORBYL PHOSPHATE, TOCOPHERYL ACETATE, XANTHAN GUM.
EU label:
AQUA, C12-20 ACID PEG-8 ESTER, GLYCERYL STEARATE, ZINC OXIDE, BUTYLENE GLYCOL, GLYCERIN, C12-15 ALKYL BENZOATE, ISODECYL LAUATE, COCOGLYCERIDES, OENOTHERA BIENNIS (EVENING PRIMROSE) OIL, PEG-100 STEARATE, OLIVE OIL (OLEA EUROPEA) UNSAPONIFIABLES, SIMMONDSIA CHINENSIS (JOJOBA) SEED OIL, BENZYL SALICYLATE, BUTYPHENYL METHYLPROPIONAL, CETYL ALCOHOL, CITRONELLOL, GERANIOL , HEXYL CINNAMAL, HYDROXYCITRONELLAL, HYDROXYISOHEXYL 3-CYCLOHEXENE CARBOXALDEHYDE, ALPHA-ISOMETHYL IONONE, AMORPHOPHALLUS KONJAC ROOT EXTRACT, LACTIC ACID, LONICERA CAPRIFOLIUM (HONEYSUCKLE) FLOWER EXTRACT, LONICERA JAPONICA(HONEYSUCKLE) FLOWER EXTRACT, PANTHENOL, PARFUM, PHYTONADIONE, POLYHYDROXYSTEARIC ACID, RUSCUS ACULEATUS (BUTCHERBROOM) EXTRACT, SODIUM ASCORBYL PHOSPHATE, TOCOPHERYL ACETATE, XANTHAN GUM.
Some obvious differences: the US label has an active ingredient. I don’t see that this adds any value since the active ingredient is not necessarily the most abundant ingredient (in the EU list it appears 4th). You would be most familiar with zinc oxide for its use in sunscreens (which is why the cream has an SPF of 6). The definition of active ingredient also seems to be debated on the internet but according to the FDA it is “any component that provides pharmacological activity or other direct effect in the diagnosis, cure, mitigation, treatment, or prevention of disease, or to affect the structure or any function of the body of man or animals.” Also the EU list of ingredients is longer. The extra ingredients in the middle that don’t appear in the US version (benzyl salicylate, butyphenyl methylpropional, citronellol, etc) aren’t that great. They all rank between 4 and 6 out of 10 on the Environmental Working Group’s Skindeep Database. However the one thing these extra ingredients might be doing which could tip the scales and make the EU formulation slightly less toxic compared to the EU version is that they push fragrance (parfum) further down the list (which means that there is a smaller percentage of fragrance in the overall product.) Out of all of the ingredients fragrance/parfum is definitely the worst. Under that short little name there can be thousands of possible toxic chemicals.
Korres’ tagline is “natural formulations, maximum results.” The results I can’t really speak for since I’ve only used the product a few times. It was a sample I had which I took on holiday. Plus I’m not much of a believer in eye creams anyways. However this product does have a high percentage of ingredients which are naturally derived. Overall the US version ranks 6 out of 10 in the Environmental Working Group’s Skindeep Database which isn’t great, but I have seen worse eye creams. On balance I wouldn’t go out and buy the full size version of this product as I think there are better options out there. When I find some better ones I’ll let you know!
Reader Comments (5)
Thanks for posting this information. It is very helpful, indeed. I wonder which pays better for consumers, the American or the English law? This does need further attention, since this pertains to people's health.
Brad Kent
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Great post... It is very helpful, indeed. I wonder which pays better for consumers, the American or the English law? This does need further attention, since this pertains to people's health.
These lists both describe the same formulation. The extra items on the EU list are components of the fragrance. These have to be declared in the EU so that people who are allergic to them are able to avoid them. I don't know of any companies that regularly reformulate products to meet the different requirements of the two markets. The regulations are so similar almost anything that is legal in one is legal in the other. I think the EU regulatory framework is a little bit better than the US one in some minor ways, but both protect consumers well enough.
The ratings of the Skin Deep Database are another matter altogether. I am more surprised when they get something right than when they get it wrong. I think it is best to ignore it altogether.
Great post, I'm a new reader and have noticed that you've mentioned the Skin Deep database over several different articles, which as an American expat reader in England I have found interesting, as pretty much no other British beauty bloggers that I have come across have seemed to have heard of it at all.
Few other bloggers seem to mention regulations like these and just keep it to just fluff and product reviews. It's wonderful having someone buck against the trend. Keep up the fantastic and thorough posts!