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February 2005

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Personal Care Product Labeling:
Finding Your Way Through a Maze of Words

by Ingrid Gulliksen, WSGC Staff

We’ve all seen various terms (or general claims) on personal care product labels. But what do these and other labeling terms really mean? Who defines these terms? Who ensures that all companies manufacturing or marketing the products define labeling terms in the same way and abide by these definitions?

The Consumer Reports-affiliated organization Consumers Union explains the meaning of each general claim, as well as stating who verifies it. Consumers Union provides a Guide to Environmental Labels, which evaluates and issues a “report card” on personal care product labeling terms. This “report card” asks these seven questions: 1) How meaningful is the label? 2) Is the label verified? 3) Is the meaning of the label consistent? 4) Are the label standards publicly available? 5) Is information about the organization publicly available? 6) Is the organization free from conflict of interest? 7) Was the label developed with broad public and industry input? However, questions 4, 5, and 6 present a kind of “catch 22” situation regarding our fifteen labeling terms: There are no label standards for any of these terms, so the question of publicly availability of non-existent standards is unanswerable. Consequently, since there are no standards for these fifteen labeling terms, there is also no independent certifying organization standing behind the standards...because they don’t exist! So this too is an unanswerable question.

Here are the answers to questions 1, 2, 3, and 7.

 

 

 

 

 

 

 

 

 

 

Unscented
What this general claim means: There is no standard definition for the term “unscented.” There is no official agency, government or otherwise, that verifies this claim. Unscented is a general claim that may imply that the product does not have any odor or scent. Some products labeled as unscented may in fact contain fragrances which are used to cover up the chemical smell of the other product ingredients. The label is not meaningful, and is not verified; the FDA has not defined the term unscented. The meaning of the label is not consistent, and the label was not developed with broad public and industry input.

Environmentally friendly
There is no government or official definition of the term “environmentally friendly.” This term is a general claim that implies that the product or packaging is in some way beneficial to or harmless to the environment. Except for the manufacturer/marketer of the product, no one verifies this claim. The label environmentally friendly is not meaningful, the label is not verified, the meaning of the label is not consistent, and the label was not developed with broad public or industry input.

Cruelty free
Cruelty free is a labeling term that implies that no animal testing was done on the product or its ingredients. The FDA has noted that cosmetic companies’ unrestricted use of the phrase “cruelty free” is possible because there is no legal definition of the term. Other than the manufacturer or marketer of the product, no one verifies this claim. The cruelty-free label is not meaningful, and can mean whatever the manufacturer/marketer wants it to mean. Some companies do not use and never have used animal testing either directly or indirectly. Some have used animal testing in the past, but do not use it now; some do no animal testing themselves, but contract out to have animal testing done for them. The label is not verified; there is no FDA definition of cruelty free. The meaning of the label is not consistent, and the label was not developed with broad public and industry input.

No CFCs
There is no government or official definition for this term. This claim is generally used on personal care products sold in aerosol cans, to mean that the product does not contain chlorofluorocarbons, a type of chemical that harms the earth’s ozone layer. However, a product that does not contain CFCs could still contain other chemicals that harm the ozone layer. Except for the manufacturer/marketer of the product, no one verifies this claim. No organization verifies the No CFCs claim. However, because products labeled No CFCs do not in fact contain CFCs, the meaning of the label is consistent. The label was not developed with broad public and industry input.

Hypoallergenic
There is no standard definition of the term hypoallergenic. No one verifies this claim other than the company that manufactures or markets the product. The label hypoallergenic is not meaningful, is not verified, and is not consistent. However, the label was developed with broad public and industry input. In 1974, when the FDA proposed its regulations for labeling products as “hypoallergenic,” they received numerous comments from both the public and the cosmetics industry. Two manufacturers of “hypoallergenic” cosmetics challenged the FDA, and initially lost. The companies then appealed, the court overturned the case on the grounds that the manufacturers would be unable to prove that their products caused fewer allergies, and the court said that the FDA should ban the use of the term hypoallergenic.

Alcohol free
There is no government or official definition for this term. There is no organization behind this claim other than the company manufacturing or marketing the product. The label is not meaningful; there are several types of alcohol found in cosmetic products, and some manufacturers define the term “alcohol free” as merely ethyl alcohol free. For example, a cosmetics product labeled alcohol free and not containing ethyl alcohol can still contain benzyl alcohol, cetyl alcohol, or other types. This label is not verified; the FDA has not formally defined the term alcohol free. The meaning of the label is not consistent; alcohol free could mean something different on each cosmetic product. And finally, the label was not developed with broad public and industry input.

Sensitivity tested
There is no government or official definition for this term. No one verifies this general claim other than the company that manufactures and/or markets the product. The label is not meaningful. Sensitivity tested is a general claim that implies that a product was tested for sensitivity on skin. According to the FDA, personal care products manufacturers are not required to perform any tests or provide any supporting evidence showing that products labeled “sensitivity tested” produce fewer sensitivity or allergic reactions than unlabeled products. The label is not verified; the FDA has not defined the term sensitivity tested. The meaning of the label is not consistent and can have different meanings for different products. The label was not developed with broad public and industry input.

Environmentally safe
There is no government or official definition of the term environmentally safe. It is a general claim implying that the product or packaging somehow benefits or causes no harm to the environment. Other than the product’s manufacturer/marketer, no organization verifies this claim. The label environmentally friendly is too vague to be meaningful, and the label is not verified. The meaning of the label is not consistent, and the label was not developed with broad public or industry input.

Allergy tested
There is no government or official definition for this term. There is no organization behind this claim other than the company manufacturing or marketing the product. The label is not meaningful because, according to the Food and Drug Administration (FDA), manufacturers are not required to perform any tests or provide any supporting evidence to demonstrate that products so labeled produce fewer allergic reactions than other products. The FDA also states that nearly all cosmetics are likely to cause an allergic reaction in some individuals. The allergy free label is not verified. The FDA, under the regulatory authority given by the Federal Food, Drug, and Cosmetics Act, can take action on products it considers “misbranded” (misleading to consumers) or adulterated (contaminated and potentially unsafe) after such products have already been marketed. But because the FDA has not formally defined the term allergy tested, taking action would be difficult. The meaning of the label is not consistent, and can have different meanings for different products. The label was not developed with broad public and industry input.

Non toxic
There is no standard definition for this term. No one verifies this claim, other than the manufacturer/marketer of the product. Non toxic is a general claim implying that the product and/or packaging is beneficial to or causes no harm to the environment. The label is not meaningful, is not verified, is not consistent, and was not developed with broad public and industry input.

Biodegradable
Although there are no specific standards for the term biodegradable, the FTC has issued general guidelines in the use of this term. According to the FTC, biodegradable should mean that a product is degradable (able to decompose) when exposed to air, moisture, bacteria or other organisms, and that the materials will break down and return to nature within a reasonably short time after customary disposal. There is no organization that verifies the use of this claim except for the company manufacturing or marketing the product. The FTC nor any other organization certifies that the term biodegradable is used correctly or truthfully. However, the FTC has taken action in the past against companies for making unsubstantiated, misleading, and/or deceptive biodegradable claims. The label is somewhat meaningful, although it can be misleading. The label is not verified, and the meaning of the label is not consistent. The biodegradable label was developed with broad public and industry input—the FTC sought public comments when its guidelines were developed.

Non irritating
There is no government or official definition for this term. Except for the manufacturer/marketer of the product, no one verifies this claim. The label is not meaningful; according to the FDA, manufacturers are not required to perform any tests or provide evidence to demonstrate that products labeled “non irritating” produce fewer allergic reactions than other products. The label is not verified, not consistent, and was not developed with broad public and industry input.

No animal testing
This is a general claim implying that no animal testing was done on the product and its ingredients. There is no government or official definition of this claim; the FDA has noted that cosmetic companies’ unrestricted use of these phrases is possible because there are no legal definitions for these terms. Except for the manufacturer/marketer of the product, no one verifies this claim. The label is not meaningful because there is no standard definition of “no animal testing.” Some companies do not do animal testing either directly or indirectly. Other companies do animal testing regardless of how the product is labeled; others do not themselves do animal testing but commission laboratories to do animal testing for them. The label is not verified, is not consistent, and was not developed with broad public and industry input.

No synthetic detergents
There is no standard definition of this term. No one verifies this claim other than the manufacturer/marketer of the product. The label is not meaningful; all soaps and detergents are synthetically produced because they are formed by chemical reaction. The main cleaning ingredients in detergents are surfectants: chemicals that reduce the surface tension of water so that it can quickly wet a surface and remove soil. In order to make a surfectant, oil must be chemically processed; therefore, all detergents are “synthetic.” The label is not meaningful, not verified, not consistent, and was not developed with broad public and industry input.

Fragrance free
This is a general claim that implies that the product does not contain any kind of fragrance; however, there is no government or official definition of the term fragrance free. No independent organization supports this claim; fragrance free can mean whatever the company manufacturing or marketing the product chooses it to mean. Since there is no standard definition of fragrance free, the label is not meaningful. Products labeled fragrance free can contain fragrances that are used to cover up the chemical smell of the other product ingredients. The label fragrance free is not verified, its meaning is not consistent, and it was not developed with broad public and industry input.