Doesn't the FDA require a vendor to list ALL of the ingredients in their product?

[sparkle25]

So I love supporting black beauty brands and try to get all of my cosmetics from them as long as the product has ingredients that work for me and my hair and are mostly if not all natural. So there is a particular vendor that I was going to purchase something from. I wrote her and asked her what the full ingredients list was, because I could not find them listed anywhere on her website of anywhere else online. She wrote me back a kind of snippy email saying the FDA does not require her to list all of her ingredients on her product or on her website, and said she will never list the full ingredients. If that is so, then why does it say on the FDA website: Cosmetic Labeling and Label Claims

Excerpt from the FDA Website: What labeling information is required?

Ingredients. If the product is marketed on a retail basis to consumers, even it it is labeled "For professional use only" or words to that effect, the ingredients must appear on an information panel, in descending order of predominance. [21 CFR 701.3]. As an alternative, when cosmetics are distributed on a mail-order basis, the package mailed to the consumer may contain readily visible instructions for locating the ingredient declaration, such as in a product catalog (currently interpreted as including a website), or instructions for requesting a copy of the ingredient declaration. Mail-order distributors must respond promptly to such requests [21 CFR 701.3(r)]. Remember, if the product is also an OTC drug, its labeling must comply with the regulations for both OTC drug and cosmetic ingredient labeling, as stated above.

Is there some sort of loophole in this or what? Because from what I can see they have to list everything.

 

[Subscribe]

Cosmetic's are the least regulated products on the market. Companies do not have to list their secret ingredients. I don't see any ingredient list on my MAC lipstick or Dior eyeshadow.

 

[IronButterfly]

Looking at what you've compiled, it would seem vendors must comply to requests regarding ingredient information. But not knowing EXACTLY how the wording in [21 CFR 701.3(r)] is interpreted, there may be ways around said "rule".

As far as cosmetics go, in general, the FDA is pretty lax anyway. For example, there is no mandate requiring "fragrance" ingredients be divulged, and many fragrances contain carcinogens.

If I were you I'd RUN as fast as I could from a vendor like that!

 

[sparkle25]

Cosmetic's are the least regulated products on the market. Companies do not have to list their secret ingredients. I don't see any ingredient list on my MAC lipstick or Dior eyeshadow.

I have asked MAC what is in their studio fix and they directed me to a place where I could find out. That expert says if its not listed they basically have to point you in the right direction

 

[NappyNelle]

They are supposed to, but many of the small, natural and homemade companies do not. I only order from the vendors that have an ingredient list, although I cannot confirm that the ingredients and facilities have been checked out by the FDA.

On another note, the FDA is way too lax with their job, especially when it comes to our FOOD. Imagine what people may put in products?! *shudders*

 

[Subscribe]

They are supposed to, but many of the small, natural and homemade companies do not. I only order from the vendors that have an ingredient list, although I cannot confirm that the ingredients and facilities have been checked out by the FDA.

On another note, the FDA is way too lax with their job, especially when it comes to our FOOD. Imagine what people may put in products?! *shudders*

I agree. The food we consume is a joke. All the food chains said they were using 100% beef --- 100% pink beef SLIME and the FDA approved that Thank goodness they mainly use that PINK BEEF SLIME in schools now,

 

[sparkle25]

Yes I know the food industry is ripe with poison and health hazards. I only eat food purchased from the co-op and the local farmers markets

 

[MileHighDiva]

Whose the vendor? You can PM, if you don't want to put them on blast.

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[sparkle25]

^^^^^ I should put her on blast but will send you a PM right now

 

[sparkle25]

I agree. The food we consume is a joke. All the food chains said they were using 100% beef --- 100% pink beef SLIME and the FDA approved that Thank goodness they mainly use that PINK BEEF SLIME in schools now,

Thank goodness only in schools? Who wants their kids eating that crap???

 

[MileHighDiva]

Le sigh! I wish these vendors would get it together. The Brothas and Sistahs can take back our hair care market, but not with all of these shenanigans

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[prettyinpurple]

Many smaller vendors have their homegrown list of ingredients. I think there's a loophole for smaller businesses or something.

But when they go mainstream and mass produce for stores they must fix the list to follow standard practices. Many times people think that they changed ingredients when in fact they just listed them in the proper order. They also use the proper scientific names of ingredients -- following the INCI.

It happened with Qhemet. I wonder if Oyin will change since they'll be in Target.

So stuff that says 'aqueous infusion of blah blah blah' is not a proper label for the big time. Of course there's our favorite 'made with love' lol.

 

[prettyinpurple]

However I would not buy anything from a vendor who gave me that rude reply.

People need to know the full listing in case of allergies or sensitivity to ingredients. Many vendors will e-mail you the list even if they don't publish it publicly.

I hate when a website just lists 'key' ingredients. Lame. Pet peeve: They need to describe the fragrance in the description too.

 

[sparkle25]

Le sigh! I wish these vendors would get it together. The Brothas and Sistahs can take back our hair care market, but not with all of these shenanigans

Sent from my Speak & Spell using LHCF

This is the wrong game to be in to be playing games like this. This community don't play. I have seen threads where girls are going HAM on vendors to the point where I feel bad for them even though they deserve it for it to even have gotten to that point.

 

[sparkle25]

However I would not buy anything from a vendor who gave me that rude reply.

People need to know the full listing in case of allergies or sensitivity to ingredients. Many vendors will e-mail you the list even if they don't publish it publicly.

I hate when a website just lists 'key' ingredients. Lame. Pet peeve: They need to describe the fragrance in the description too.

Then she told me " Im not sure if you tried my product or know of some one who has but it doesn't cause any problems most likely it's going to help you. If you fear of being irritated I would suggest you get a sample"

 

[Saludable84]

Then she told me " Im not sure if you tried my product or know of some one who has but it doesn't cause any problems most likely it's going to help you. If you fear of being irritated I would suggest you get a sample"

In the end I wouldn't deal with this vendor. I don't bother with any vendor that couldn't tell me their ingredients or at least for certain ingredients, tell me their supplier. I am very funny about that. Especially when some products/ingredients can only be cultivated in certain countries that have high mineral contents in their soil like lead. I personally would like to know who this vendor is, but I'm don't finding new products and I only purchase from people who list their products anyway.

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[sparkle25]

I'm not buying anything from this woman.

 

[iVR]

So I love supporting black beauty brands and try to get all of my cosmetics from them as long as the product has ingredients that work for me and my hair and are mostly if not all natural. So there is a particular vendor that I was going to purchase something from. I wrote her and asked her what the full ingredients list was, because I could not find them listed anywhere on her website of anywhere else online. She wrote me back a kind of snippy email saying the FDA does not require her to list all of her ingredients on her product or on her website, and said she will never list the full ingredients. If that is so, then why does it say on the FDA website: Cosmetic Labeling and Label Claims Excerpt from the FDA Website: What labeling information is required? Ingredients. If the product is marketed on a retail basis to consumers, even it it is labeled "For professional use only" or words to that effect, the ingredients must appear on an information panel, in descending order of predominance. [21 CFR 701.3]. As an alternative, when cosmetics are distributed on a mail-order basis, the package mailed to the consumer may contain readily visible instructions for locating the ingredient declaration, such as in a product catalog (currently interpreted as including a website), or instructions for requesting a copy of the ingredient declaration. Mail-order distributors must respond promptly to such requests [21 CFR 701.3(r)]. Remember, if the product is also an OTC drug, its labeling must comply with the regulations for both OTC drug and cosmetic ingredient labeling, as stated above. Is there some sort of loophole in this or what? Because from what I can see they have to list everything.

I think this is only for retail. Retail and small business are not on the same playing field.

 

[Saludable84]

I think this is only for retail. Retail and small business are not on the same playing field.

When you have a tax id and/or selling your products to the public, a lot of things change and everything applies to you. I work for the govt. trust me, you are exempt from nothing just because you are a small business. In actuality, your held more responsible because you have the most to lose. Quickly at that.

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[sparkle25]

I really don't know why for a second she thought that she would not have to list them. I asked another natural hair vendor if they had to list their ingredients. While the particular vendor I asked just for some reassurance does list her ingredients, she too thinks she doesn't have to and says she only does out of curtesy for the customer.

 

[SunRai Naturals]

That is horrible customer service OP. I'm glad that you aren't going to deal with that vendor because she doesn't deserve your business.

 

[sharifeh]

You know , maybe they really don't have to list everything I was talking to someone yesterday and she was telling me mainstream shampoos and conditioners don't have to list everything If something is 1% of the formulation then they don't have to list it , Isn't that why some bkts are supposedly formaheldahyde free but they still have 1% formaheldahyde that they don't list?? I dunno just some thoughts, it's worth researching though
I don't have any actual knowledge on the subject... Just hearsay for me

 

[loulou82]

It is my understanding that small businesses are not exempt from public disclosure of their ingredients just because of their size. There are ways to get an exemption BUT that designation must be formally requested and approved. If you are putting a product into the steam of commerce then you must abide by the rules and you be ready to accept liability if something goes wrong (like a defective or injurious product). The United States Code sets out the law via statute and the CFR (Code of Federal Regulations) parses out the details for the laws interpretation and implementation.

http://www.fda.gov/cosmetics/cosmeticlabelinglabelclaims/cosmeticlabelingmanual/ucm126444.htm#clga

21 U.S.C. 321-392
The cosmetics marketed in the United States, whether they are manufactured here or are imported from abroad, must comply with the labeling requirements of the Federal Food, Drug, and Cosmetic (FD&C) Act, the Fair Packaging and Labeling (FP&L) Act, and the regulations published by the Food and Drug Administration under the Authority of these two laws.

Procedure for Requesting Exemption of an Ingredient Identity From Public Disclosure


21 CFR 720.8
The first step in processing a request for trade secrecy, i.e., a request for exemption from label declaration, of the identity of a cosmetic ingredient is the submission to FDA of [certain information].

If the vendor was haughty with me about a simple ingredient inquiry I would forward her the applicable USC and CFR.

Don't these folks know that if they are sued and have not properly insured and separated the business as a legitimate LLC or other business entity then a customer can sue THEM and come after personal assets?? Did they even get a business license? Are they paying taxes?

 

[loulou82]

sharifeh

I thought the 1% and under guideline stated that if an ingredient was 1% of the formulation then the company did not have to list it in descending order and could label it in whichever order they wanted. So a conditioner contained 1% preservative and .5% avocado oil- the company could list the avocado before the preservative because both were 1% and under. I may be off though.