5 Ways The “Safe Cosmetics Act” Will Harm Consumers

First, let me explain what the “Safe Cosmetics Act” is. It’s a bill that has been introduced into the house by representatives Schakowsky (D-IL), Markey (D-MA) and Baldwin (D-WI). This bill’s stated purpose is to make the cosmetic industry safer through further regulation. While it sounds great on the surface, the group that is really behind this bill is the Compact For Safe Cosmetics, which is funded by the Environmental Working Group. Both have reputations for scaremongering and using arguments which are scientifically unsound. This bill has absolutely nothing to do with cosmetic product safety, but it will have drastic consequences to all cosmetic manufacturers, small and large. This will ultimately impact you the consumer.

If you are someone that keeps up with the skin care industry—especially with small independent cosmetic manufacturers—you’ve probably noticed twitter is abuzz with all kinds of information on this, and several industry leaders have already written about this (Kayla Fioravanti, Donna Maria Coles Johnson, Cindy Jones, Leigh O’Donnell, Anne-Marie Faiola, Kristin Fraser Cotte, and  many others).

How does this affect you as a consumer of cosmetic products, though? I’m glad you asked.

  • Less Natural Ingredients

There are two reasons why this bill would result in less natural ingredients on the market. The first is that the testing required for natural ingredients is necessarily more expensive than for synthetic ones (I’ll explain why in a minute), and the second is that MANY natural ingredients would be downright banned.

First, the testing: This bill requires cosmetic manufacturers to list every detectable element in each ingredient. While this may sound  like a good idea at first to some, upon closer inspection you can see this is actually not just a bad idea, it’s totally absurd! You see, the technology we have to detect trace elements these days are amazing. We can detect trace amounts of certain substances at parts per billion! This is really mind-blowing, but what it means is that many natural ingredients are going to be very expensive to test, because natural ingredients are much more complex than synthetically created ones. Synthetic ingredients usually only have a handful of compounds in them, because they can be created that way (in a sterile lab environment). Natural ingredients are derived from living organisms (like plants and flowers) and are inherently complex. In fact, parsley is made up of at least 204 different compounds, and many essential oils are composed of hundreds of compounds. The result of all this is that natural ingredients will be much more expensive to include in cosmetics because the testing to figure out what they are made of is much more expensive. This will lead to many companies choosing the more cheaply testable synthetic alternatives just to stay profitable.

The second reason—and this is the more important one—is that many wonderful natural ingredients would be downright banned. The bill bans many substances which are supposed carcinogens. The problem is that almost every living thing has trace amounts of all kinds of different chemicals that are suspected carcinogens. For example, we now know that apples naturally contain minute amounts of formaldehyde and a bunch of other “nasty” chemicals. This is really the topic for another blog post, but let’s just summarize with: It’s the the dose that makes the poison. Many compounds which are required by our bodies to function become toxic or carcinogenic in large quantities (even water will kill you if you drink too much!). Other chemicals are totally tolerable by our bodies in small doses (we’ve been eating formaldehyde for as long as apples have been around), but are highly toxic in large doses. The bottom line here is that this bill would mean manufacturers can not put extracts from apples, pears, bananas, basil, almonds, and thousands of other natural ingredients in their products, yet you can go to the supermarket and take them home and eat them.

Compounding this issue is that many things which are listed as carcinogens are based on ridiculous science. I won’t go into detail here, because this post is already going to be pretty lengthy, but Cindy Jones, Ph.D. of Sagescript has written a great post explaining this.

  • Less Product Choice

You probably don’t need me to tell you this now, but because of all the testing and regulations in this bill about ingredients, you will have less products to choose from for your skin. This bill will put out of business THOUSANDS of small, local, independent cosmetic manufacturers because they just can’t afford to spend the enormous amounts of money to test their products. The result is that the only products for sale will be the ones from the larger companies that have been able to afford the added expense.

  • Less Clear Ingredient Listings

Given that this bill requires manufacturers to list every constituent of each ingredient, the ingredient listings for cosmetic products (called the “ingredient deck” in the industry), would balloon to an absurd and unusable level. I love Kayla Fioravanti’s example of this in the possible listing of water. If a company puts water in one of their cosmetics, it’s entirely possible that it could come out looking like this after testing:

Aqua (lead, acrylamine, alachlor, alpha/photon emitters, antimony, asbestos, arsenic, atrazine, barium, benzene, benzo(a)pyrene, beta photon emitters, beryllium, bromated, cadmium, carbofuran, carbon tetrachloride, chloramines, chlordane, chlorine, chlorine dioxide, chlorite, chlorobenzene, chromium, copper, cyanide, 2,4-D, dalapon, o-Dichlorobenzene, p-Dichlorobenzene, 1,1-Dichloroethylene, cis-1,2-Dichloroethylene, trans-1,2-Dichloroethylene, Di(2-ethylhexyl) adipate, dinoseb, diquat, endothall, endrin, ethylbenzene, fluoride, glyphosate, hexachlorocyclopentadiene, mercury, radium, uranium, vinyl chloride, xylenes)

That’s just water! Now imagine trying to list that out for mango extract or basil essential oil. Not only is this scary to consumers, it’s less useful. Many cosmetics already have a large number of ingredients. Imagine a typical natural lotion that has 35 ingredients, each with 100-200 constituents and trace elements. You’re looking at an ingredient deck of at least 3500 individually listed ingredients. This is madness.

  • Less Affordable Products

The cost to test these ingredients is enormous, and the testing would have to happen multiple times. Take olive oil and shea butter as an example. This bill would require the company that refines the olive oil and shea butter to test for all of the constituent compounds in each, but also the manufacturer who combines them then has to test the finished product for all constituent compounds, to make sure nothing “unsafe” has developed as a result of the combination. The only way for companies to stay profitable is to raise their prices.

  • Less Money For Your Local Community

You might not be aware of it, but there are many thousands of small independent cosmetic manufacturers across the country. Chances are there are more than one in your local community, too! These people make a living (or some extra income) by making natural & safe cosmetics products and sell them on-line or in local shops. Putting these companies out of business with this draconian regulation just kills the American dream for thousands of people who have a passion for natural cosmetics and means those local communities which they operate in will take an economic hit.

Why This Bill is Unnecessary

  • The cosmetics industry is already safe. Our industry probably has the best safety record of any other industry. There have been virtually (or maybe absolutely) no reports of serious injuries, deaths, or diseases caused by cosmetics. No scientific studies have proven any links between cosmetics and cancer or other illness.
  • This industry already strives for safety. Nearly all cosmetic companies, especially independent ones, have the goal of providing safe products.
  • We’re already regulated by FDA. I can attest to this personally, as it’s been a struggle over the years to comply with the regulations put forth by the FDA. What we have is adequate, we don’t need more regulation.
  • It’s already illegal to sell an unsafe cosmetic. That’s right. If we sell an unsafe cosmetic we are liable, and the FDA will get involved.

A Call To Action

I know this legal mumbo-jumbo stuff is pretty boring, I’ve tried to keep this post as interesting as possible. I implore you to get involved in this, because this legislation will not only affect the independent cosmetic manufacturers you support, but it will affect you, too!

First, educate yourself about this bill. You can use the links in this post to read the bill itself, and read what others in our industry are saying. You can also do your own research. Then, if you decide that you’d like to support our cause, here are some things you can do to help out.

  1. Check out the website. Several people in our industry have started a website regarding our opposition to this legislation. You can find that site at http://www.opposeSCA.com/
  2. Sign the petition. The website also has a petition opposing this legislation. Please take a moment to sign it! You can find the petition right here.
  3. Call or write your representative. This bill is still in committee. That means it hasn’t been voted on yet. PLEASE call or write your representative to let them know where you stand on this. You can find your local representative right here.
  4. Chat about it on Twitter. There is already a hash tag started for this. It’s #OpposeSCA.
  5. Share it on Facebook. Just post a link to this or the oppose SCA website in your profile, maybe something like: “Do you use cosmetics, soap, body wash? There is a bill that has been introduced that could drastically affect the price you pay for these things and could put small manufacturers out of business. Read about it here http://opposeSCA.com and here https://thealabublog.com/?p=689
  6. E-mail this post to your friends. It will only take a minute. Let your friends know what’s going on in the skin care industry and that they can make a big difference.

Let me know what you think about the Safe Cosmetics Act in the comments section below.

Thanks for your support!

UPDATE: There is a video in support of this bill that the Compact For Safe Cosmetics had out for about a week. Lee Doren of How The World Works has recently published a great critique of  the video. You can watch that below.




  1. […] I can’t wait to see what’s in the bill this time around. Let’s hope all of our efforts last year didn’t fall on deaf […]

  2. Thank you, this is the best info I’ve found on the web

  3. The legislation would provide small businesses with access to studies performed by larger companies that would also apply their cosmetic ingredients. It would not force small businesses to perform their own testing.

  4. I am fairly new to this industry and have started a blog in efforts to help the family business, and become more engaged in researching and sharing my findings with customers, family and anyone who will listen.

    I do admit I did find the video “The Story of Safe Cosmetics” to be very interesting and shared it with others, however reading your post and listening to your arguments has got my attention. I am all for natural products and of course safe ones, I guess I am a little frustrated being so new to this industry as to where to get my information. You seem to be very passionate and knowledgeable on the topic and have listed some great resources. I look forward to following your blog and going through the many links that were provided with many of the comments to this post. If you feel there are any addition resources that I may benefit from I am all ears.

    This is definitely not the time to endanger the loss of more jobs. If everything you state is indeed true, then I too am opposed to more govt. regulation.

    Again so glad I stumbled upon your site and will begin researching this some more.

    • Hi Rob,

      Thanks for your post. It really brought one big question to my mind.

      Why is it a choice between ‘loss of jobs’ and a safer and cleaner environment?

      This ‘choice’ is often presented to protect the status quo from any attempts at real reform.

      I just found this report that details some ‘secret’ ingredients contained in cosmetics. You can find it at:


      Feel free to share it with your customers, family and friends. I am curious what your wife [and/or those who use cosmetics on a regular basis] thinks about this. I don’t use many cosmetics but reading this [as well as another report on musk I found last night [1]] made me think about the musk fragrance used in my deodorant.

      I have to let my wife read it and see what she thanks although sharing potentially depressing info is not fun. Reading NotsoSexy helped me realize the broader context of what is going on in this matter. This is really big business.

      You are right that finding objective information is a challenge, as is taking all the time needed to contact your elected representatives and bill sponsors to get information from legislation writers. I am thankful to Hal for posting my thoughts and links on this blog even though we might not agree on some of the points.

      But again, what I would really like to hear from you is – Why do have to choose between jobs and health?

      It seems transparent to me that safe, non-toxic products are a win-win and a competitive advantage for the small producer – as long as consumers will be able to know the whole story about what they are buying and not have some ingredients hidden.

      – John Jay Miller

      [1] http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1253742/
      [1] http://www.sott.net/articles/show/211760-The-Danger-of-Toxic-Consumer-Products-Fragrances

      • Rob,

        Thanks for reading. You’ll see that all viewpoints are welcome here. Stay tuned, as I am currently working on another post that more clearly lays out the areas of this bill which are problematic to small business.


        I don’t think we have to make a choice between jobs and a safer cleaner environment. This bill does nothing to make cosmetics safer. I just don’t see any peer-reviewed studies show any real danger in current cosmetics. I understand there a few reports that suggest there may be some danger to certain cosmetic ingredients, and there are numerous studies conducted by the EWG but their funding and motives are both questionable, and they are not peer-reviewed. The society of toxicology does not agree with most of these studies and has even published studies that show contrary conclusions. I am all about making things safer. What I object to is accepting the premise that cosmetics are currently dangerous and need drastic regulations to make them safe.

        As mentioned above, I’m currently working on another blog post that will more clearly lay out the specific areas of the bill that are problematic to small business.

    • Hi Hal,

      Thanks again for the venue.

      I am glad we agree on having safety _and_ jobs.

      1) One way this bill helps is by giving consumers all the information regarding what is in a soap/cosmetic. So consumers can be safer if they learn that some product contains substances that might harm them.

      Second, it also will establish a database of substances that are toxic/cancer causing so that producers can avoid using them.

      Both of those items add up to ‘safer’ to me.

      2) I think one premise of this bill is that cosmetics _may_ be dangerous but that is impossible to determine if their ingredients are kept secret. Providing transparency to consumers by insisting on listing all ingredients does not seem like a drastic regulation to me – rather it seems like common sense and the right of a consumer to know what they are buying.

      3) I am not carrying water for EWG but to accuse them, or anyone else, of having questionable motives and funding really requires some type serious evidence. Don’t forget that many industry funded studies are not peer-reviewed either, this is common practice in many fields and one learns to weigh such information accordingly.

      The NIH article referenced above discusses a peer reviewed article [1] from the journal Environmental Health Perspectives [2], “a monthly journal of peer-reviewed research and news published by the U.S. National Institute of Environmental Health Sciences, National Institutes of Health, Department of Health and Human Services.”

      The interesting thing about Nitromusk is that while considered nontoxic itself it “may pose a hidden threat to human health by enhancing the effects of compounds that are toxic.” In order to be able to do such groundbreaking [3] work we must know what chemicals are in the products we use – without that information no testing can ever be done.

      I look forward to your next post.

      – John Jay Miller

      [1] http://ehp03.niehs.nih.gov/article/info%3Adoi%2F10.1289%2Fehp.7301
      [2] ehp03.niehs.nih.gov/static/information.action
      [3] Ground breaking in the sense that “ … our data expand the definition of toxicity and detrimental effects to indirect and unanticipated consequences of these chemicals, even if the chemical itself might be nontoxic” — What might be safe itself is really toxic when introduced into another biological process – this is amazing information.

      • “3) I am not carrying water for EWG but to accuse them, or anyone else, of having questionable motives and funding really requires some type serious evidence. Don’t forget that many industry funded studies are not peer-reviewed either, this is common practice in many fields and one learns to weigh such information accordingly.”

        This may shed some light on the situation: http://bit.ly/9VctTy

  5. As Pamela admitted on the Soapmakers Guild web page devoted to this matter:

    “Self reporting isn’t working, the honors system, and self regulating, or buying your auditor (Arthur Anderson Accounting and Enron) regulation is not enforced when it comes to corporate America.” Pamela on 8.2.2010


    This is why we should support this bill.

    Soap makers also have an ethical responsibility to disclose all ingredients so that consumers can make informed choices.

    Just like labeling of food products that contain peanuts, soap products _can_ contain substances that can be very harmful/fatal to some people.

    Transparency is the way. The bill’s sponsors can find a way to rectify the labeling issues so that common ingredients can be listed as such. Water will be labeled as ‘water’; soybean oil as ‘soybean oil’ — just as it is now on food labels.

    No consumer should have to guess what is in a product.

    Paperwork, labeling and accounting are just part of being a business, I know a designer if you need one.

    Good work all, open discussion/government can solve problems that confront us.

    – John Jay Miller

    • Hi John,

      It sounds like you don’t have a good understanding of the current legislative environment. It’s already the law for manufacterers to label their products with the ingredients in them. Consumers already don’t have to guess. Creating an exception for things like soybean oil and water would basically mean no change from current labeling requirement. The difference would be the amount of paperwork and testing costs involved. 

      Also, I don’t follow your argument that regulation is not enforced, but the answer is more regulation. Perhaps you could explain that further.

      Thanks for your offer for a designer, but we already have one and already comply with the current rules and regulations, Which require us to list our full deck of ingredients for each product. 

    • Hal, thanks for the reply.

      As I mentioned, soap products can contain substances that harm some people. Soap Naturally [1] has useful tables of essential oils to avoid or use with caution.

      As for labeling of soap, its not required:

      “True” soaps are regulated by the Consumer Product Safety Commission, not FDA, and do not require ingredient labeling. [2]

      Here are the labels of two ‘soap’ items I have at hand, neither have any ingredient list:

      1) Package of 6 Dove bath bars; white, beauty bar for deep moisture, 1/4 moisturizing cream; 4.25 oz bath bars – No ingredient list on outside wrapping or individual boxes.

      2) Honey Almond, Body Bar, net wt. 2.6 oz/75g
      Made in China
      Marketed by Wal-Mart Stores, Inc.
      Bentonville, AR 72716

      Also, it would not be hard to identify a number of ‘handcrafted’ soap makers websites/products that do not have ingredient labels.

      Again, its all really a matter of transparency – people deserve to know what they are using. Personally, I am more concerned about soap labeling but it should be required with everything we purchase.

      I think that passing on the MSDS [material safety data sheets] from suppliers for documentation should suffice for this law. I have not seen any direct evidence to the contrary although there are a lot of undocumented claims on the web right now. It would be nice if someone that is really familiar with the legislative process [like yourself, perhaps?] could provide written documentation from one of the bill’s sponsors that, indeed soap makers will be required to submit water and items that have supplier MSDS info, for new laboratory testing.

      “Self reporting isn’t working …” is the message I wanted to convey because that is what soap makers now have. It was just a win/win that Pamela also pointed out that legal regulation also don’t work sometimes [she makes both points].

      I think non enforcement of legislation is largely a factor of some politicians, who do not believe in government regulation of corporations, being quite adroit at gutting funding for enforcement mechanisms. Think – tainted peanut butter, poisonous imported drywall, toys and dog food, SEC & Madoff, illegal immigration, the BP gulf oil spill… the list can go on and on forever.

      We just have to fight the good fight and try to protect ourselves and others from predators who put money above all else.

      The design issue can be important for those without the knowledge of good design practice. The offer was not directed to you in particular. This issue is related to packaging/labeling for pharmaceutical. The labels themselves can pose a danger themselves if they are not well designed. Perhaps soapmakers could have a designer referral service?

      I will also mention that one other BIG reason that ingredient labeling is of increasingly vital importance. Human engineered NANOPARTICLES.

      They have been linked to various deadly possibilites such as:

      – cause change to DNA across a cellular barrier without having to cross it. [3]
      – endocrine disruptors that alter hormonal activity [4]
      – can penetrate the skin and could enter the bloodstream [5]
      – can make their way into the brain by passing from the nose through the blood-brain barrier [5]

      and will soon be used in soaps as well as cosmetics, which already make some use of them.

      Hopefully they will be banned but given human nature it may well take a Thalidomide or Asbestos/Mesothelioma type occurrence for an outright ban. Barring that, we should know what items contain them so we do not willingly rub them on our bodies.

      Thanks again for the forum, open discussion/government can solve problems that confront us.

      – John Jay Miller

      [1]Soap Naturally, Garzena and Tadiello, Programmer Publishing, 2004

      • Hi John,

        Thanks for the reply. It’s pretty lengthy, so I’m going to attempt to break it down into your main concerns/points (let me know if I miss anything):

        1: Labeling of ingredients on Soap is not required,
        2: Self-reporting isn’t working
        3: SCA 2010 can probably be satisfied very easily (e.g. pass along MSDS)
        4: Human engineered Nano-particles present a significant risk and should be banned and/or labeled correctly.

        Ok, so, lets start with item 1.

        1: While it’s true that the labeling of ingredients on soap is not required, if you read the link that you provided [2], you’ll see this: “If a cosmetic claim is made on the label of a “true” soap or cleanser, such as moisturizing or deodorizing, the product must meet all FDA requirements for a cosmetic, and the label must list all ingredients.” So, while a “true” soap does not need to have the ingredients listed, the Dove bars that you mentioned are actually required to list the ingredients. Dove is at fault here for not complying with the current legal requirements, and the FDA (which is sorely understaffed) has not called them on it. The VAST majority of soaps (including ours) fall under the definition of cosmetics because of the way they are marketed. Additionally, the way to fix this is to remove the law exempting soap, not add any more laws.

        2: The idea that the soap/cosmetic industry is under some kind of system of self-reporting is nonsense. The FDA lays out the rules and we as cosmetic manufacturers are required to follow them. The fact that they are understaffed and can not keep up with enforcement on current requirements should go to show that adding more requirements right now is a little bit crazy. The problem is not a lack of legislation, it’s a lack of enforcement.

        3: The fact is that SCA 2010 would NOT be satisfied by a simple MSDS sheet, but in fact would require listing EVERY CONSTITUENT of every ingredient as an ingredient. Please see Subchapter B, Section 611, Paragraph E which defines an ingredient as (among other things) “contaminants present at levels above technically feasible detection limits;”. This definition is patently absurd, because unless you are going to classify arsenic, lead, formaldehyde, etc as NOT being contaminants, then we are going to be required to test for them and list them “above technically feasible limits”. As mentioned, these things occur naturally all around us. Formaldehyde is in many fruits (as well as your own body, right now), lead is in pretty much everything, etc. To have to test for and list these constituents is going to cost manufacturers (and ultimately consumers) a LOT of money. Please read the following two posts regarding SCA 2010. One is written by Kayla Fioravanti, who is a certified aromatherapist and is very active in the legislative realm pertaining to cosmetics, the other is by Robert Tisserand, who is regarded by many as the world’s foremost expert on essential oils. He also has many years of experience in the industry and has seen a lot of legislation come about (especially in europe) and has witnessed the effects of it. Here is Kayla’s post: http://bit.ly/d3ItCH Here is Robert’s post: http://bit.ly/bft9Ex

        4: I am not well-informed about nano-particles. I do not know much about their safety, but I have no problem requiring them to be labeled appropriately when used in cosmetics.

        In summary. Our position at Alabu is that current requirements are adequate (and many people do follow them), but the problem is that people who are not following them are either unaware of it, or they are not being called out by the FDA. The FDA needs to enforce current regulations, we don’t need new ones.

    • Hey Hal,

      Thanks again.

      First let me restate that I am specifically addressing how the bill would impact _soap makers_ ok? In each post I have tried to make this clear, sorry if I failed in that regard.

      1) In particular, I support the bill if it will require ‘soap makers’ to include ingredients in their labeling. In the previous post I provided ample proof that, currently, soap makers can, if they choose, avoid such labeling. The non-quoted portions of FDA link are not relevant and do not contradict my claim that, as the site says, ““True” soaps are regulated by the Consumer Product Safety Commission, not FDA, and do not require ingredient labeling.“ A soap maker can avoid ingredient labeling if they do not make certain claims.

      2) As these soap makers are free to label – or not – they are self regulating. They decide. We need specific legislation to require that all ‘soap-makers’ are required to label their products. Consumers need the transparency of labeling so they can make informed decisions.

      I do not know how else to say this. I can make and sell all the soap I like and _not_ put ingredient labels on the soap and it is currently legal – that should change.

      Yesterday I talked with a staff member of the bill’s sponsor and was assured that testing would not be required by end-product producers but rather, as is the case now, material testing would only be required by ingredient manufacturers – just as is the case now. Now, when you buy material to make soap [and cosmetics I imagine] you are provided an MSDS – material data safety sheet, to prove to you and your workers what, if any precautions are needed to handle the ingredient. That would not change.

      Although we did not have a lengthy discussion, as I understand it, if you procure some plant material and make your own batch of oil, fragrance, etc. you would be required to prove it is not contaminated, i.e. have it tested. That is only right and just as it is now I imagine but am not certain since I do not make soap ingredients.

      The staffer sent me an electronic plain english version of the bill’s main points that you can download from:


      under, ‘Safe Cosmetics Act One Pager.pdf‘

      this is the link:

      3) As to the matter of constituent testing, lead, formaldehyde, etc. the plain english document I mention above states:

      “Ingredient Labels on Cosmetics: The label on each package of cosmetics would be required to list the name of each ingredient. This includes the components of a fragrances and preservatives.”

      I think that is the relevant part anyway. I do not have a problem with this requirement.

      After looking at the Water / Aqua ingredient list you referenced from Kayla’s site – I think that is GREAT! Many of those items can accumulate in the body and people should learn about them and be able to avoid using them. Children and other vulnerable populations should definitely be able to avoid them. Check out the implications of having renal failure and you might get an idea of what I mean … the body simply can not tolerate toxins as well as a non-compromised person. Thats my opinion. The labeling issue can be handled … it will be a change but it is well worth it.

      An additional LARGE benefit of this may well be that people become educated about environmental issues that will be have an increasing negative impact on their lives. I wonder how people know that in 2003, 44 states issued fish consumption advisories for mercury contamination for fish caught in their state? [1] I think that all 50 states now have rivers and fish contaminated with mercury, but can’t find the reference at the moment.

      As you know this bill is in draft form and undergoing the ‘public comment/input’ phase. I would advise all concerned to contact the bill’s sponsors with questions and suggestions. That is what they are there for. Government is by and for the people – but only if citizens participate.

      As this process continues I think/hope the questions and issues can be worked out if we all work together to solve the problems at hand.


      – John Jay Miller

      [1] http://www.usgs.gov/themes/factsheet/146-00/

      • Hi John,

        You are correct, the fact is that as a soap maker you can make a soap and not list the ingredients. You say that you support this bill because it would require soap makers to list their ingredients. However the only thing that’s required to be done to make soap makers list their ingredients, is get rid of the law that exempts them. The fact is that this bill would absolutely require an outrageous amount of testing by small companies who simply can’t afford it. Regardless of what a politician tells you, literally dozens and dozens of people who have been in this industry for many years and have watched legislation pass in this country and other countries are very convinced about the consequences of this bill. I’d err on the side of caution with them than put my faith in what a politician tells me. Besides that, the proof is right in the bill itself, just read it! Kayla’s post does a very good job of laying out the reasons why this bill is going to put small manufacturers out of business.

        Also, in your first reply you said that “The bill’s sponsors can find a way to rectify the labeling issues so that common ingredients can be listed as such. Water will be labeled as ‘water’; soybean oil as ‘soybean oil’ — just as it is now on food labels.”, yet now you sat “After looking at the Water / Aqua ingredient list you referenced from Kayla’s site – I think that is GREAT! ” What caused you to change your opinion?

        I have no problem with new legislation, and I have made my voice clear to my representatives, but THIS legislation is a huge over-step by the government.

  6. Brillant. This is a great post on the SCA. I plan on linking to it later. Thanks for plain, simple and the dead on points on why this bill is bad, misguided and dangerous.

  7. I am sorry to hear you are taking a stand against this bill. I believe toxic chemicals in the environment desperately need regulation in this country. Did you know that some lotions, for instance, sold by a same company in Europe and in the USA, contain different ingredients, one formula for the USA and one formula for Europe? I am grateful to EWG for the database they created and consult it often. Please read the chapter on phthalates in Slow Death by Rubber Duck. I love your soap, but I do not buy your arguments. Instead of opposing the bill, perhaps you could write your congressman pointing out the issues the bill, in its present form, would create for small organic producers?

    • Hi Alexandra,

      Thanks for your comment. It’s not just us taking a stand against this bill. Nearly our entire industry is. Everyone from Proctor & Gamble to Suzy Soap-maker. This bill is bad for everyone. Also, what are “toxic chemicals”? To use an example from Lee Doren, your doctor may prescribe you one iron pill a day, but taking 20 could be toxic, even deadly. Chemicals are not toxic by themselves, they are toxic at certain dosages. It’s a common saying in the toxicology filed that “it’s the dose that makes the poison”. The fact is that the whole idea of “contaminated” and “pure” are misnomers put out there by activist groups like EWG and CFSC. Like most things in life, it’s not black and white like that. As noted earlier, apples naturally contain formaldehyde as part of their growing process. Does this mean they are not pure? No it does not. The vast majority of “questionable” chemicals that are found in cosmetic products have not been added there by evil corporations, they’re just trace elements of these chemicals that have tagged along from the beginning, and are in no higher concentrations than than they would be in the vegetables you at last night.

      EDIT: With regard to the differing product formulas. This is actually pretty rare. It doesn’t make financial sense for skin care companies to do this. If they have to make a special formula for the EU, most of the time they are just going to sell that same formula here instead of producing two different ones. Also, just because they have different laws in the EU does not mean their products are any safer. In fact there is ZERO evidence at all that skin care products in the EU are safer than the ones here.

    • Hal, do not see where to reply to your reply, so am adding it here. I just watched a European documentary about packaging in France and Germany, how it comes from China and contains BPA & phthalates. I hope you will encourage your readers to support the Safe Chemicals Act which was recently introduced in the Senate and is different from the Safe Cosmetics Act in the House. They should read Slow Death by Rubber Duck. That book changed the way I go about my life.

      Also, I recently saw a documentary from Sweden, an advance DVD. The documentary by Stefan Jarl has been called “the film of the century” by the United Nations Environmental Officer. The director interviews 23 professors and the conclusions are pretty bleak. Endocrine-disruptors like BPA do effect reproduction. One of the important discoveries revealed is that traditional scientific thinking on small doses has been abandoned. Small doses may be even worse.

      • Alexandra,

        I’m not familiar with these documentaries. Could you please specify which ones you’ve watched? I’d like to review them. I’ve also not read Slow Death by Rubber Duck, but I’ll look into it. With regard to BPA and phthalates, I don’t doubt that there are some professors who are concerned. However this is not the viewpoint of the FDA and the toxicologist community as a whole (please see http://bit.ly/a2WpbB, http://bit.ly/a6Nsnw). Also, can you tell me what toxicologist(s) are abandoning the “traditional scientific thinking on small doses”? This principal has been demonstrated tens of thousands of times and has had many decades of confirmation. I’m just curious which toxicologist(s) are all of the sudden abandoning this principal.

        Phthalates occur naturally in many other foods, including milk, fish, grapes and olive oil. Any traces detectable in human tissue are much more likely to come from this source than from sucking a plastic duck or receiving a blood transfusion (http://bit.ly/9RvNZY). Even highly-demonized parabens occurs naturally in many species (http://bit.ly/cQGoEh). You may also be interested in this (http://bit.ly/9oPx3M).

        I can’t recommend that my readers support the version of SCA introduced into the senate because I haven’t read it yet. I will gladly read it, but I wasn’t able to find it (at least not on opencongress.org). Could you provide a link to it? Thanks!

        Update: You my also be interested in this post regarding the unreliable nature of the Skin Deep Database: http://bit.ly/chaMmK

  8. Thank you for this excellent post and enhancing my own awareness on the subject. I signed the petition too.

  9. Great post and spot on information, Hal. You have a new fan and like-minded colleague here. 😀
    I wanted to add for Ria that she might check out some independent reviews of the Skin Deep Database. Respected fragrance chemist Tony Burfield, who joins me and others on the group blog http://www.aromaconnection.org had this to say about the “Not So Sexy” CFSC report http://bit.ly/9tQs45 If you search aromaconnection under regulatory, safety/toxicity, science, standards and other related categories you’ll find more info, too.
    You may be interested in my latest offering on http://www.wingedseed.com/blog that covers more on CFSC ethics, operations and politics – I wanted to broaden comments beyond the faulty science and regulations.
    Thanks again, it’s nice to get to know you and your mom’s (well, your’s too) company.

    • Thanks a ton Marcia! Great information for Ria and others, too. You’ve just given me a lot of reading material :). I hadn’t heard of aroma connection or your blog before. Glad to meet a like-minded colleague, too!

  10. […] many products we enjoy safely in this country with a wide range of choices at every pricepoint. The effect of the proposed legislation on the end consumer (that’s you) would be higher prices, fewer natural ingredients,  fewer product choices, […]

  11. Well put. I’m sharing this on Facebook!
    We make natural skin care products for children with locally grown Calendula and Honey in an effort to support sustainable agriculture. This legislation would make it impossible to use small scale organic farms as a source of skin care ingredients.

    • Thanks so much Patricia! We support our local farmers by getting all of our goat milk from them, of which we use an enormous amount of. It would be pretty much impossible for us to do this if this bill passed.

  12. I agree with the post except for 1 line:
    No scientific studies have proven any links between cosmetics and cancer or other illness.

    I have been doing some research on my blog about what lip products contain.And some ingredients can cause cancer or toxicity (neuro,skin,or other kind).These ingredients are generally considered as safe and are “natural”.But in some articles that I’ve read (I study biology, so reading articles is a must for me) they say practically to use at own risk and to be used in cosmetics under circumstances.
    So even if it’s FDA approved it doesn’t mean that we can use any cosmetic without any problem.These ingredients stay in your body because there’s no way your body can get rid of them.So in small quantities they might not be harmful, but since they pile up the amound goes up.Which is kind of worrying.
    And some companies don’t write these ingredients.Because they write nothing on the package.Which I think is wrong!
    I’m not pro-law, I’m just stating a fact.

    • Hi Ria,

      Thanks for brining this up. I may have worded that a little strongly, but do stand by the statement. I have not found any peer-reviewed studies that prove any links between cosmetics and cancer or other illness. Yes there are suspected carcinogens in cosmetics, but there are suspected carcinogens in mushrooms, broccoli, water, et cetera. Saying that they pile up is mostly irrelevant with respect to cosmetics. If these ingredients pile up from from use in cosmetics, they’ll almost certainly pile up from eating too many veggies then, right? Again, it’s the dose that makes the poison. The fact is that the cosmetic industry is one of the best safety records of any industry.

      Also, manufacturers that don’t list the ingredients on their packaging in full are breaking the law. The FDA does fine or even shut down companies that package their product illegally. If you see this happening, I suggest you contact the company and let them know their product is not labeled legally (many manufacturers simply aren’t aware of the rules, so it’s nice to give them a chance to fix it). If they don’t respond then contact the FDA and report them.


      • Ingreients like benzyl alcohol or titanium dioxide are proved possibe carcinogens but definite TOXIC and they are in many cosmetics AND other proucts like chewing gum, perfumes,toothpaste etc. There could be a place (maybe a website) where each manufacturer could write the whole list of ingredients or a leaflet inside each package. And yes they are in veggies but in way smaller amounts and in a different form (like binded on a protein etc, which can get out of the body). In the water it’s a really serious problem, since there’s been lead poisoning from using tap water. Once again I do not disagree with you but I’d rather know what I put on my face or even “eat” (this goes for lip products). I will go and sign the petition if I’m allowed, given that I don’t live in the States.

        • Ria, thanks for the comment. You shouldn’t have any problem signing the petition. I totally appreciate your concern, and I’m not discounting it, but I suspect you may be working from unscientific data. The studies I’ve seen do not show ANY toxicity for benzyl alcohol or titanium dioxide in the levels that they occur in cosmetics. Also, I have not seen any studies that suggest the trace amounts of suspected carcinogens are much higher in cosmetics than in vegetables. The following articles may be of interest to you:


          Thank so much for your support and interest in safe cosmetics!!!

          UPDATE: It looks like benzyl alcohol is actually pretty common in intravenous medications, and that the human body coverts it to a non-toxic form quite readily. See http://en.wikipedia.org/wiki/Benzyl_alcohol#Use_in_health_care


        • Bacteriostatic as in doesn’t allow (bacteria) cells to multiply .And from what you can read to what it does to lice…this can happen to your own cells.
          Yes, your body can get rid of it but if it is in a specific form. And with enzymes which are activated from a specific amound and higher. Until the enzymes work on the benzyl alcohol it can do damage.
          Also check this out: http://www.cosmeticsdatabase.com/ingredient.php?ingred06=700697
          …Strong evidence of human neurotoxicity
          …Classified as expected to be toxic or harmful
          …One or more in vitro tests on mammalian cells show positive mutation results

          Evidence, expected and the test might not proove that if you use it you’ll get hurt, but I’d rather be safe than sorry.
          Also the possible human mutagenic in biology terms means that since tests in human are banned they’ve tried the substance in several dosages either in cells or in animals and in several amouts tried they observed mutations.
          Also in plants, and fungi there are anioxidants, which help the body get rid of these substances, and as I mentioned it matters more in which form you get a chemical into your body. Besides there’s a limit to how much green leaf vegetables you’re going to eat. There’s no limit to how much lipstick you can apply.
          And believe me I’m working with scientific data. And I know that cosmetics companies can go without these chemicals, since many cosmetics don’t include them within their ingredients. I just don’t know why.

          • Hi Ria,
            If you are getting your information from cosmeticsdatabase.com, you are not working from scientific data. This site is sponsored by the Compact For Safe Cosmetics (CFSC), The Environmental Working Group, and ultimately the Tides Foundation. They have a terrible reputation for scaring consumers with unscientific data and are absolutely not to be trusted. Earlier this year the CFSC tried to pass a similar bill in Colorado, and when questioned on the science behind their stance, their representative actually said (paraphrasing) “we don’t have the science, I wish we did but we don’t, we just believe these chemicals are unsafe”. This group is all about scaring consumers, not safe cosmetics. Use their data with great caution, it’s not reliable.

  13. WOW! I had absolutely no clue about this until an employee of Fyrinnae Cosmetics tweeted this link. I am SO glad I did. This article truly scares me.

  14. Utterly brilliant. And, sadly, completely “on point.” You are my new hero…

  15. With all the extra crap we’d have to include on labels, I doubt I could make anything less than gallon sized product. The label wouldn’t fit on anything smaller! This is, of course, assuming I could afford to stay in business.

  16. Excellent points, Hal. I join you in opposing the Safe Cosmetics Act of 2010. Thanks for providing a compelling, thought-provoking post with easy action steps that anyone can (and should) take.

  17. […] Hal from Alabu has written an excellent piece here. on how this legislation would affect us all as […]

  18. […] This post was Twitted by Dyeingforewe […]

  19. One of the best posts I’ve seen so far on this subject. Good job!

  20. Nice blog, you made some very specific points. I wanted to twitter what was in water, but of course I can’t with the 140 character limit. If this passes each cosmetic would have to come with a book of ingredients.

  21. […] This post was mentioned on Twitter by Rose Carbajal, Alabu Skin Care. Alabu Skin Care said: 5 Ways The Safe Cosmetics Act Will Harm Consumers: http://bit.ly/buxaeM Important issue for sm business & consumers. Please read! #OpposeSCA […]

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