This is how powerful marketing and blatant unethical dissemination of information can be, including words from professionals whose titles are highly regarded in the industry. Here you have – Rodan and Fields – two dermatologists (a title they love to flaunt) claiming two things: 1) that they “invented” a product. First of all, ANYONE with some knowledge of basic ingredient chemistry can “invent” a product, send it to a lab, have the chemist formulate it and pay a branding company to get your name/logo all over the place. I recently had a client who came in as a client (her excuse) because she wanted to introduce herself as a future vendor – she was “creating” a new skincare line. When I asked her about specific ingredients, she had no clue what I was talking about. She wasn’t even in the cosmetics industry, and said she needed to get back to her chemists to see if they were using any of the ingredients I mentioned. So there you have it. YOU, my friend, CAN create a new skincare line! Just Google it. 2) R&F claim that their products are “pharmaceutical grade” (see picture). READ MY LIPS: the FDA does NOT, I repeat, does NOT differentiate between “different types” of cosmetics and their information is simply untrue. The FDA has absolutely NO SAY when it comes to cosmetics. And because people believe what they are told, let me offer you some quotes from the FDA directly:
– FDA’s legal authority over cosmetics is different from other products we regulate, such as drugs, biologics, and medical devices. FDA does not have the legal authority to approve cosmetics before they go on the market, although we do approve color additives used in them (except coal tar hair dyes).
– FDA encourages cosmetic firms to report product formulations through the VCRP. However, the companies are not legally required to tell FDA about their products and safety data.
– Because the law does not require that bad reactions to cosmetics be reported to FDA, we may be unaware of problems.
– FDA can inspect manufacturing facilities to determine if proper controls and practices are being followed. FDA also works with U.S. Customs and Border Protection to examine imported cosmetics. But because resources are limited, only a few establishments are inspected each year, and just a fraction of imports are physically examined.
– FDA does not have the resources to sample and analyze all cosmetics on the market.
– The CIR is an independent, industry-funded panel of medical and scientific experts that meets quarterly to assess the safety of cosmetic ingredients based on data in the published literature as well as some that is voluntarily provided by the cosmetic industry. The industry data may or may not be complete. FDA takes the results of CIR reviews into consideration when evaluating safety, but the results of FDA safety assessments may differ from those of CIR.
– FDA cannot require recalls of cosmetics, but works with companies to make sure their recalls are effective.
– There are no regulations or requirements under current United States law that require cosmetic manufacturers to print expiration dates on the labels of cosmetic products. Manufacturers have the responsibility to determine shelf life for products, as part of their responsibility to substantiate product safety.
– In direct response to this marketing piece from R&F:
Cosmetic products are not expected to be aseptic; however, they must be completely free of high-virulence microbial pathogens, and the total number of aerobic microorganisms per gram must be low. Since there are no widely acceptable standards for numbers, temporary guidelines are used instead. For eye-area products, counts should not be greater than 500 colony forming units (CFU)/g; for non-eye-area products, counts should not be greater than 1000 CFU/g. The presence of pathogens would be particularly important in evaluating as unacceptable a cosmetic with a marginally acceptable count, e.g., 400 CFU/g for an eye-area product. Pathogens or opportunistic pathogens whose incidence would be of particular concern, especially in eye-area cosmetic products, include S. aureus, Streptococcus pyogenes, P. aeruginosa and other species, and Klebsiella pneumoniae. Some microbes normally regarded as nonpathogenic may be opportunistically pathogenic, e.g., in wounds.
For details about ALL MICROBIAL AND PATHOGEN TESTING required for manufacturers, use this link: http://www.fda.gov/Food/FoodScienceResearch/LaboratoryMethods/ucm073598.htm
– For more information, go directly to the FDA website and go through some of the links. Just pick and choose and you will soon find out there is NO SUCH THING!
FAIR PACKAGING AND LABELING ACT: http://www.fda.gov/RegulatoryInformation/Legislation/ucm148722.htm