The Real Cost of Unnecessary Pre-Market Test Proposed by Skin Deep & The Campaign for Safe Cosmetics
There is a misperception that cosmetics are untested. That couldn’t be further from the truth. I’ve been formulating a new shampoo and I’ve had at my fingertips a variety of test results to help guide me in choosing the right ingredients to not only fit my standards for human safety but also environmental impact. I have studies on the biodegradability, oral toxicity, eye irritation, contact sensitization, skin irritation, inhalation studies, 28 day subchronic toxicity study, mutagenicity, carcinogenicity, mammalian toxicity, studies on how ingredients interact, what percentages are best used, by products, pH, and every other detail you can think of needing to know before using the ingredient in a products.
A closer look at what Skin Deep and the Campaign for Safe Cosmetics wants legislated made me realize it isn’t the cosmetic ingredients themselves that they are demanding pre-market testing on, since most of those have a massive amount of pre-market testing already, it would be testing for finished products that they are seeking. Since it is already illegal to sale a product that is contaminated in any way it isn’t the already required microbiological testing that they want, it is testing to show that from nature or as a by-product finished cosmetics do not contain anything from their list of ‘dangers’.
In order to show small businesses and consumers the impact of the legislation that organizations like Skin Deep and Campaign for Safe Cosmetic would require I researched the cost of having one batch of a single product one scent tested to prove that it is free of many of the alarm bells rung by Skin Deep and Campaign for Safe Cosmetics.
The tests it would take to get approval if Skin Deep and Campaign for Safe Cosmetics could force legislation through for additional regulation on the cosmetic industry would include:
$440.00 Paraben results in ppm
$950.00 Nitrosamine results in ppm
$950.00 Phthalate Free results in ppm
$700.00 per metal Heavy Metals (Lead, Arsenic, Cadmium) results in ppm
$275.00 Mercury results in ppm
$1185.00 Standard 9 Metals
$750.00 1,4 Dioxane results in ppm
$275.00 Formaldehyde results in ppm
$300.00 Ethylene Oxide results in ppm
$450.00 Residuals results in ppm
$1500.00 Fragrance allergens
$350.00 Fragrance Allergens Confirmation test per sample, per per allergen
Total $8125.00 or more pre-market testing per product
If testing was required per lot number per SKU of product the prices of cosmetics would sky rocket. Even if the testing was required per formulation per SKU the testing would put the majority of small businesses out of business over night. The testing is not only over the top, but it is uncalled for since all cosmetic chemicals are pre-market tested, all FD&C colors are premarket tested per lot per color and the ingredients are known to be safe based on testing and history.
More about the author: Kayla Fioravanti is the Vice President, Chief Formulator, ARC Registered & Certified Aromatherapist for Essential Wholesale and its lab division Essential Labs. Read more from this author