Why Cosmetics Need Preservatives

Why do cosmetics need preservatives?  Below you will find out the legal reasons, a little chemistry and some information that might help you sort through the different preservative free claims made by certain companies.

The Federal Food, Drug and Cosmetic Act “prohibits the introduction or delivery for introduction into interstate commerce of cosmetics that are adulterated or misbranded (Sec. 301). A cosmetic may be deemed adulterated (Sec. 601) for essentially four reasons, namely:

1. It may be injurious to users under conditions of customary use because it contains, or its container is composed of, a potentially harmful substance.

2. It contains filth.

3. It contains a non-permitted, or in some instances non-certified, color additive.

4. It is manufactured or held under insanitary conditions whereby it may have become injurious to users or contaminated with filth.”  If a product is not preserved it would be deemed illegal for sale based on numbers one and two of the Federal Food, Drug and Cosmetic Act.

Anything that contains water (ie. creams, gels, lotions, etc) is a paradise for bacteria, yeast, fungi and molds, and the natural sugars in plant extracts are their favorite snack food.  Bacteria is a fact of life in cosmetics, foods and pretty much any organism that contains even a trace amount of water.  David Steinberg has trademarked the perfect saying when it comes to bacteria, “Remember, Preservatives are Safer than Bacteria™”

Whether you want to bury your head in the sand or not every cosmetic either has a 3 day shelf life or some form of preservative.  If a cosmetic has even a trace amount of water it must be preserved by some method.  There is no such thing as a preservative free cosmetic.  Determining the water activity of your product is the shortcut to deciding if you need a preservative or not.  If you product is bone dry with no water then it does not need a preservative.

Bacteria require water to grow and the majority of cosmetics contain high enough water levels to easily grow bacteria.  Simply put, bacteria require water to support life and if you have enough water it will thrive. Gram positive and gram negative bacteria prefer slightly basic conditions pH 7.5 and warm temperatures 37 degrees Celsius (98.6 degrees Fahrenheit.)  All gram negative bacteria are disease producing.  The good guys are the gram positive bacteria.  No bacteria can grow very well at pH of 8.5 to 9.  Fungi, yeast, and molds prefer acid conditions (pH 5.5-6) at room temperature to multiply.

Cosmetic products must be preserved for two main reasons.  Insurance companies would never cover unpreserved products and the FDA requires that products are not “injurious to user under conditions of customary use because it contains, or its container is composed of, a potentially harmful substance” and they may not “contain filth.”  Products are not required to be sterile but they may not be contaminated with a pathogen all other counts must remain low and remain that way under foreseeable consumer use.  The products must be tested for adequacy of preservation during the development of the product and each batch tested before released for sale.

Many natural substances offer some antibacterial benefits.  Certain essential oils, like Tea Tree, Thyme and Oregano at high concentrations can be helpful with some strains of bacteria.  Unfortunately, your bathroom, purse, car, or desk drawer is not an ideal condition natural cosmetics. Steam, heat, direct sunlight and other adverse conditions help encourage bacterial growth and most “natural preservatives” can’t be used in strong enough concentrations to fight contamination without running the risk of skin irritation or allergic reactions. Others are useful only against certain strains of contaminants and for limited amounts of time.  While Vitamin E, Neem and Rosemary Oleoresin Extract (ROE) work wonders at keeping oils from turning rancid, they don’t protect against all forms of gram-positive, gram-negative bacteria and yeast which are common in unprotected cosmetic products.

My daughter Selah did a science project last year that is a wonderful example of why broad spectrum preservatives are an absolute necessity in cosmetics.  She made a lotion using 1% tea tree essential oil as the “natural preservative system” under perfectly sterile conditions.  The product looked, smelled and felt perfectly normal and safe, but the pictures below show the results of the micro-test that we ran on her product after 3 days.  A visual inspection of the lotion was not enough to know that the lotion was full of bacteria and yeast.  Yuck!

The first photo is of the lotion itself which showed no visual signs of the yeast and mold that was growing inside of it.  The product smelled just as fresh as it smelled on the first day.  This is why you need preservatives!

Broad-spectrum preservative can be used to boost the preservative action of the natural ingredients, providing protection against a broad range of bacteria, microbes, yeast, fungi and molds. Bacteria can break down ingredients in a product, making it less stable and effective, as well as posing some serious health risks for which you, as the seller, can be held liable.  It is dangerous to sell food at a local fair that you knew had mold growing on it the day before, right? So why sell any personal care product to the public that you know is not properly preserved.  Not only is it dangerous to sell cosmetics that are not properly preserved, it is illegal.

After a great deal of testing, research and development, Essential Wholesale has developed a stable organic preservative system used in our Organically Preserved Cosmetic Bases. In our regular Cosmetic Bases we use stable broad spectrum preservatives along with other natural inhibitors and antioxidants to help with preserving our bases. We feel confident that this is a very positive paraben-free alternative for all of our customers worldwide. We understand that a truly natural broad spectrum preservative is not currently available.   There have been attempts by some companies to influence you to believe that they do exist, so we will keep our ears and eyes peeled for something that is effective as well as continue to research and develop our own systems.

We are familiar with all of the so called “natural” preservatives on the market, but have not found the test data on any of them to be conclusive when compared to known broad spectrum preservatives. Our own CTFA and USP Challenge Testing have not been favorable for any of the commonly known “natural” preservatives currently available. They all have very limited success and if they are effective it is only on certain strains.  Our advice is to beware since you are liable in the end for anything you sell to a consumer.

By combining the healing and nutritive benefits of plant extracts and whole food ingredients with the advances of science, we were able to create products that are safe, effective and gentle. In a word, preservatives can guard against impurities and support the healthful actions of nature’s finest botanicals and your customers deserve that kind of protection.

The standard preservative system used by Essential Wholesale includes several natural inhibitors along with broad spectrum preservatives is used to prolong the shelf life for a minimum of 12 to 24 months or more. Our system is accepted by the governments of all states and countries including the EU and Japan. Some of the natural inhibitors and antioxidants we use are Tocopherol (Natural Vitamin E), Azadirachta indica (Neem) Oil, Rosmarinus officinalis (Rosemary) Leaf Extract, Salix nigra (Black Willow Bark) Extract (not White Willow Bark which does not have the same effect).  In some cases we use a blend of Essential Oils, Potassium Sorbate, Citric Acid, Usnea barbata (Usnea Lichen) Extract as well.  As you know, no preservative system is fool proof and so proper handling is vital. We suggest a dark, cool, dry place out of direct sunlight and avoid contact with non sterile objects like your fingers.

We are able to develop a product for you using any broad spectrum system of preservation that you’d like but please keep in mind that there may be additional costs. Also, minimum size orders may vary depending on the product.

Preservatives are necessary because the water portion of a product is the perfect breeding ground for mold, fungus, bacteria and yeast.  It is only a matter of time and all cosmetics will go bad. What is frightening is that the product might look and smell just fine, but be filled with micro organisms that are dangerous for your skin and health.

Some products may look fine on the outside, but when you run them through micro testing, the bacteria, yeast, fungus and mold count can be off the charts. Other times, the signs of contamination are more visually obvious. Possible signs of a product going bad can be a rancid odor, product separation and visual evidence of mold in a variety of colors. The problem with the visual or smell test is that they can be very deceptive to the untrained nose or eye.  An unstable, under-preserved product can be contaminated by the water in the product, spores in the air, even unseen contaminates in your packaging and the germs on your hands. A good stable preservative system can keep your product safe and free from these microorganisms for years.

We are often asked, “Why does brand X not use any preservatives?” or “Why don’t you use that “natural” preservative?” And our answer is always the same. As our research has been extensive, it has included testing many chemical, semi-synthetic and natural preservatives on the market today. It has also included running tests on many of those Brand X products you are referring to. In our research there are five possible answers to the question of how Brand X uses no preservative.

  • There is a preservative system on the market with the INCI name of “Fragrance”, which does not disclose the actual ingredients and hides the preservative in the ingredient itself which acts like a broad spectrum preservative and is used in some of the biggest “natural” lines on the market.
  • There are many products on the market that failed USP and CTFA Challenge Testing and grew yeast, mold, bacteria and fungus quickly. And when asked why they are still making the efficacy claims they are, the manufacturers simply state that “They passed OUR testing requirements.”
  • They do not fully disclose their ingredient list. This is common of all size companies that mislead their customers, thinking they are protecting their formulas. Their products do not fail micro tests, showing the amazing abilities of broad spectrum preservation yet, they do not have any ingredient listed that has any preservative properties at all. We find that odd at best.  This is a highly illegal method of hiding preservatives but extremely common.  The Federal Food, Drug and Cosmetic Act states that a product “may be deemed misbranded (Sec. 602) for reasons of:1. False or misleading label. 2. Falure to state prominently and conspicuously any information required by or under the authority of this act. 3. Misleading container presentation or fill.”
  • They might be using ingredients that do not require preservatives. For instance a product that does not contain water might not require preservatives, only an antioxidants such as Vitamin E.
  • They could be using extracts in one or two different methods. Tinctures used at the right percentage create an effective preservative option. But be careful as many extracts are made in a propylene or butyl glycol base and are themselves preserved with parabens, triclorisan or urea but not disclosed as the manufacturer is only required to list it as an extract since they are considered “processing aides”. These used at high enough levels without fully disclosing the other ingredients can create an effective preservative system. But be careful you don’t give up one chemical for another.

We hope that helps with many of your questions about “WHY PRESERVATIVES” and hope that you make the right choice for the safety of your customers. We believe we have made the right decision for your safety and the FDA agrees with us.

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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


  • http://www.indiebusinessblog.com Donna Maria Coles Johnson

    Thanks for this excellent and authoritative post! When it comes to cosmetics, most people don't know that the fact that it's not visible doesn't mean it's not there. Plus, start-up cosmetic companies need to know that preservatives are necessary, and must outweigh the marketing desire to call something “all-natural.” I like natural too, but not if it's also gross!

  • http://sagescript.blogspot.com Cindy Jones

    Can't tell you how many times I've heard someone say that they've never had any trouble with their products even though they don't use preservatives. Sometimes people forget that bacteria, yeast and most fungi are microscopic and we can't see them with the naked eye and if they have gotten to the point where you can see them, the product was unsafe a long time before that. That is why microbiology testing is done. A microbiology test (APC and fungal/yeast count) will tell you an approximate number of microbes that are in a given product even though you cannot see them.

  • SUSAN

    “There is no such thing as a preservative free cosmetic.” Again, I must disagree. “There are some ingredients that have their own anti-microbial activity. These are alcohols, antioxidants, glycols, some herbal extracts, essential oils and a host of other ingredients. Even Zinc Oxide when used as an inorganic sunscreen will have sufficient anti-microbial properties at high enough concentrations to inhibit microbial growth. In this case a preservative-free claim can safely be made. Ingredients listed as preservatives must be used as such but ingredients not appearing on any government preservative lists but do have their own inherent anti-microbial activity can be used to make a preservative-free claim but the product…”

    Legally, ingredients that are NOT listed on the Annex VI part 1 or 2 of the EEC Cosmetic Directive 76/768/EEC – including the 7th amending Commission Directive 94/32/EC.1, legally are not considered preservatives. An example, products which employ hurdle technology can have a safe shelf life by making the water itself less bio-available…rather than chemically killing bacteria.http://www.personalcaremagazine.com/Story.aspx?…

  • http://greenskincareblog.com/ Kristin Fraser Cotte

    Hi Susan,

    Thanks for your comments. I think Kayla addresses that point above when she stated, “They might be using ingredients that do not require preservatives. For instance a product that does not contain water might not require preservatives, only an antioxidants such as Vitamin E.”

  • SUSAN

    I'll try again; “Legally, ingredients that are NOT listed on the Annex VI part 1 or 2 of the EEC Cosmetic Directive 76/768/EEC – including the 7th amending Commission Directive 94/32/EC.1, are not considered preservatives.”

    Therefore, water-containing cosmetics which contain various ingredients such as alcohols, antioxidants, glycols, some herbal extracts, essential oils and a host of other ingredients may be legally and correctly preservative-free…and also shelf safe. They are what the industry refers to as “self-preserved” – the synergy of the ingredients creates an environment such that preservatives are not needed.

  • http://www.sterlingminerals.com/ Katherine@sterlingminerals

    Please forgive my confusion on what point you are trying to make here Susan but as you stated:

    “Therefore, water-containing cosmetics which contain various ingredients such as alcohols, antioxidants, glycols, some herbal extracts, essential oils and a host of other ingredients may be legally and correctly preservative-free…and also shelf safe. They are what the industry refers to as “self-preserved” – the synergy of the ingredients creates an environment such that preservatives are not needed.”

    It seems to me this is a classic example of cherry picking data to suit your argument when in fact the entire article needs to be taken into account. No where could I find this statement within the article that “the synergy of the ingredients creates an environment such that preservatives are not needed.”

    If you carefully read and take the article in it's entirety you would also see the following:

    “Preserving a product using only natural preserving ingredients not listed in the Cosmetic Directive allows the declaration of “preservative-free”. As a consequence, not all natural preserving ingredients are declared as preservatives under EU regulation. This means that, by definition, there are no all-natural preservatives on the market so far.”

    As I understand it, this preservation system will not be recognized or accepted under EU regulation for safely preserving a product and keeping consumers from harm. It may be legal to state but doesn't mean it is a safe method.

    Another portion to the article:

    “An adequate preservation system must also prevent, as a third purpose, the re-contamination of the product during its usage and the possible cross contamination among users. Other factors, for example the desire for “green” or natural products, also impact the type of preservative system that is used.”

    Cross contamination or moisture gaining access to the ingredients that you describe will not withstand microbes that are introduced in this fashion. No micro study supports your theory on preservatives not being needed! Plus in order to achieve an antimicrobial effect the concentration levels of an organic type of preservative would need to be so high then you run into the skin irritant factor and other problems with skin health.

    More from the article:

    “One of the main goals of the COSMOS standard is to achieve an accepted labelling by defining five type of ingredients for personal care products (among them the physically processed agro-ingredients, the chemically processed agro-ingredients and the synthetic materials) by establishing their percentages, and by defining a final product labelling depending on the percentages of the different ingredients.6 The use of some natural ingredients can complicate the decision for the right preservative system. The integration of components like wood particles, inorganic materials, or different untreated organic extracts into a formulation is often a source of further contamination. Moreover, many of the natural personal care products contain a large amount of water and nutrient substances which facilitate microbial growth. Under these conditions it is necessary to follow preset preservation guidelines to prevent in-use contamination. Nowadays, some “green” preservatives can assure the right preservation for a broad spectrum of products. However, traditional preservatives like parabens, formaldehyde releasers and isothiazolinones cannot be avoided due to the composition of some formulations.7,8″

    Depending on your ingredient of choice, there is not certainty of cross contamination already present in even a treated organic ingredient. Cross contamination can occur anywhere from greenhouse to lab to formula. Herbal extracts for instance are in an alcohol tincture which stabilizes this ingredient as a stand alone influence, but once incorporated into a formulation, especially when using water, the effects of the tincture will not withstand the process since the tincture will be used at levels typically at less than 1% whereby losing their efficacy. Even if extracts are combined increasing tincture levels, they are not designed to support antimicrobial growth.

    This last portion pretty much says it all:

    “Developing countries

    The utilisation of traditional preservatives is also of utmost importance in many developing countries where the environmental conditions often favour the growth of microorganisms and negatively influence the stability of most of natural preservatives. Green or natural preservatives are known to be even less stable than the traditional ones. Okek et al reported that during a broad screening of the bacteriological quality of skin moisturising creams and lotions distributed in a developing country, most of the products were found to be contaminated.9 This was mainly related to poor or inconsistent manufacturing standards. Utilisation of traditional and reliable preservatives can help to ensure the microbiological safety of the product. The variety of personal care products necessitates finding individual solutions for the challenge of offering product safety. The choice of an appropriate preservative system needs to be balanced between different aspects such as:

    • The physical and chemical compatibility of preservative and formulation.
    • Regulatory issues.
    • Skin tolerance.
    • The achievement of a stable formulation.

    The final selection of a preservative system needs to consider many parameters beyond just the desire to use a “green” preservative. Ultimately, the most important selection criteria should be that the preservative system best helps to ensure the microbiological safety and quality of the product.”

    Thanks for providing the article since it only further supports Kayla's analogy to preservative free versus using them. So again, not sure what point you were trying to make, unless it was just trying to debate semantics of the legal aspect which then serves no other purpose except to make one appear foolish! Taking things out of context as is the habit of many “green” thinkers does nothing to support this cause.

  • honuheath

    This is an excellent point. When I first started making my own stuff just for myself and friends, I still used a preservative. I wanted something that was good for my skin and that included protecting myself against dangerous microbes. I don't mind products labeled as “mostly natural” or “99% natural,” since this means they are safer for me and my family to use. I've carried that over into my small business and have never traded “all-natural” for “prone to icky growths.”

  • SUSAN

    The context is, Kayla made blanket statements that happen not to be always correct.

    Here is a simple example: “”Cosmetic products must be preserved for two main reasons. Insurance companies would never cover unpreserved products”

    This is not true. I know a lot of soap makers who have insurance and 100% preservative-free soaps. Their soaps are legally cosmetics. Insured. No preservatives.

    There are PLENTY of businesses making cosmetics and adding preservatives and selling them, and their products are not shelf stable or free of bacteria. They don't bother to test them…they don't want to spend the money. Just adding a preservative is no guarantee of a safe product.

    Just as there are plenty of shelf stable, safe cosmetics that are free of preservatives…they are self-preserved using any number of methods not limited to pH, hurdle technology, etc.

    As for your comment that “So again, not sure what point you were trying to make, unless it was just about trying to debate semantics of the legal aspect which then serves no other purpose except to make one appear foolish! Taking things out of context as is the habit of many “green” thinkers does nothing to support this cause.”

    I'm proud to be a green thinker…sorry you missed the point.

  • SUSAN

    Kristen my comments apply to cosmetics that contain water. That is the whole point of hurdle technology…if there is no water the technology would not be used.

  • http://www.sterlingminerals.com/ Katherine@sterlingminerals

    I did not miss any point Susan since you did not clearly make one until now. You placed a small blurb about legalities within the article with no explanation other than defending the preservative free thing as being legal to claim and you used a EU reference, not FDA. You also used a blanket statement by viewing the article completely out of context and then respond in this way because I took the article in whole and not in part as you did. Your responses have been ambiguous at best. The team of experts on here are not mind readers so if you wish to make a point, then clearly stating it would go far in getting an articulate response.

    Also, Soaps are not considered a cosmetic, they are soap under FDA. So Preservatives are not necessary!

    Kaylas remarks about legal are in reference to this statement as it would be illegal based on these regs:

    1. It may be injurious to users under conditions of customary use because it contains, or its container is composed of, a potentially harmful substance.

    2. It contains filth.

    3. It contains a non-permitted, or in some instances non-certified, color additive.

    4. It is manufactured or held under insanitary conditions whereby it may have become injurious to users or contaminated with filth.” If a product is not preserved it would be deemed illegal for sale based on numbers one and two of the Federal Food, Drug and Cosmetic Act.

    In terms of insurance since your argument is based on soaps, this does not apply, in regard to insurance for cosmetics, this would be a question for Kayla and perhaps she can answer that one since I don't have this issue as mine are preserved so it has never been a topic for discussion otherwise and I am fully insured.

    So we'll see if Kayla wishes to chime in on that point.

    Thanks for clarifying your point!

  • SUSAN

    “…Soaps are not considered a cosmetic, they are soap under FDA. So Preservatives are not necessary!”

    You might want to review the laws…a bar of “true soap” can be legally a cosmetic under the law. All synthetic detergent bars are legally cosmetics, whether they are labeled soap or not.

    But you are correct…they don't need preservatives, like I said. If you are unaware of the FDA regulations regarding what is soap and what is cosmetic…and for that matter what is a drug, you might want to review the FDA website. They make the laws very clear. If you'd like a few links Katherine, I'd be happy to post them.

    You might want to make special note of cosmetics that make claims for things like acne, or any other health claim…those are drugs, by law. Lots of cosmetic companies break that law!!

  • http://www.sterlingminerals.com/ Katherine@sterlingminerals

    Again I am dealing with ambiguity once again Susan. I am stating that a soap isn't a cosmetic based on your comment of your friends making soaps and they are legally a cosmetic. The answer was unclear….if you wanted an answer that was different then clarifying what made them a cosmetic would have been helpful, such as cosmetic claims. Soap is only a cosmetic when a claim is made such as moisturizing, deodorizing, beautifying or antibacterial for it then becomes a drug, but if there are no claims in regard to the bar of soap then it is defined as just “soap” such as for cleansing.

    Susan I am fully aware of FDA regulations and comply fully so you don't need to provide me with links. If you want concise answers then please be concise in your replies. Plus I would advise you to review the FDA labeling regs in regard to “soap” because what you stated:

    “You might want to review the laws…a bar of “true soap” can be legally a cosmetic under the law. All synthetic detergent bars are legally cosmetics, whether they are labeled soap or not.”

    Your last remark is in part true to the first part, but a synthetic detergent bar is legally a cosmetic but it cannot legally be labeled “soap”. Soap is regulated by the consumer product safety commission and no ingredient lists are required, and when it is no longer a true soap, must be referred to as a beauty bar or deodorant bar, etc etc. and only then will it fall under FDA regs and labeling requirements. If something is made from synthetics and it is labeled soap then this is a form of mis-branding.

    Here is a clear explanation on this subject from the FDA website: http://www.fda.gov/cosmetics/productandingredie

  • http://twitter.com/essentialU Kayla Fioravanti

    Susan,

    My point is that there is always something in the product that is acting as the preservative. Whether it is alcohol (which is effective), antioxidants (which only act as antioxidants to the oils and do nothing for the water portion), herbal extracts (which either means the alcohol in them is preserving the product or they are extracts in glycol with added synthetic preservatives acting to preserve the product or essential oils (which in most cases either fail or are at such high concentrations that as an aromatherapists I can't recommend that). From the photo above of the failed microtest that product was “preserved” with 1% tea tree.

    From the article you referenced, “Since many cosmetic products cannot be sterile-manufactured or packaged, preservative systems are required. The first purpose of a preservation system is to inhibit microbial growth that leads to product spoilage. The second purpose is to protect the consumer from infection risks.”

    Also from the same article, “can be utilised to AID in the preservation of a product.” The key word there being AID in the preservation.

    The key point here also is what Katherine has already stated below…

    “Kaylas remarks about legal are in reference to this statement as it would be illegal based on these regs:

    1. It may be injurious to users under conditions of customary use because it contains, or its container is composed of, a potentially harmful substance.

    2. It contains filth.

    3. It contains a non-permitted, or in some instances non-certified, color additive.

    4. It is manufactured or held under insanitary conditions whereby it may have become injurious to users or contaminated with filth.” If a product is not preserved it would be deemed illegal for sale based on numbers one and two of the Federal Food, Drug and Cosmetic Act.”

    There are far more dangers hidden in an unpreserved cosmetic (that contains water) than there is in one that is properly preserved.

  • SUSAN

    “Your last remark is in part true to the first part, but a synthetic detergent bar is legally a cosmetic but it cannot legally be labeled “soap”. “

    Wrong, Katherine…detergent bars can be labeled soap. Go into ANY grocery store…99% of the bars labeled soap are actually detergent bars, and follow the laws regarding cosmetics as far as the rest of the labeling goes…a cosmetic product, that comes into regular contact with water, that does not need a preservative.

    But please…do not take my word for it! Here is a quote and a link:

    “Products consisting predominantly of synthetic detergents may be identified in labeling as “soap” if they are intended for cleansing the human body and have the characteristics consumers generally associate with soap.”

    http://www.fda.gov/ICECI/Inspections/Inspection

  • SUSAN

    “Susan I am fully aware of FDA regulations and comply fully so you don't need to provide me with links.”

    So, you are labeling your OTC drugs in accordance with the FDA regulations. Good for you. You obviously have been in the industry for many decades, glad to know you are on top of all the legal issues…you know…for things like following the OTC drug monographs for products you claim have an SPF, medicinal claims like publishing testimonials related to acne or rosacea, claiming anti-inflammatory properties for ingredients, you know…the basics everyone selling OTC drugs should know!

  • http://www.sterlingminerals.com/ Katherine

    I have removed my original comment since I have decided to no longer engage in further debate with this individual and I apologize to any readers for becoming engaged in an argument that clearly went off point of the original article.

    I allowed this to become personal and I shouldn’t have. So for my part, I will no longer participate in a debate with someone who simply wishes to spin this off subject which then detracts from being helpful to those whom visit this site.

    Thank you!

  • http://www.sterlingminerals.com/ Katherine@sterlingminerals

    I do not make drug claims for any of my products, and I also do not formulate soap! And I don't make SPF claims. I appreciate the fact you enclosed a link to the FDA however as I have found through many instances with the FDA such as the link I provided there is contradictions within the entity as it stated legally could not be identified as soap. In speaking with the FDA I have been informed on what is allowed and what isn't within my website and I have clarified and modified much to be in compliance. All websites are a work in progress, but since you haven't seen my labeling on my products, your accusations without facts is simply without merit. I am not going to debate this issue with you further.

    If you need to be right then you can be right! Since your tone has been one of rudeness since the beginning with your second comment to Kristen! You have done what is typical, you have spun this into a personal attack and taken us completely off the original subject of this article, instead of sticking with the issue at hand which was about preservatives. And you are still debating semantics about a cosmetic soap coming into contact with water not needing preservatives. I also blame myself for partaking in this with you when this first spun off of the subject…so thank you for reminding me also to stay on task.

    As I stated before this is no longer productive and is now counterproductive to the original intent of this article and the original post you offered us with a link….When the article was clarified, it clearly was not to your liking. Now I will disengage from further contact with you and you keep attacking those that disagree with you on personal level, since it goes so far for keeping things on a professional level.

    Cheers!

  • SUSAN

    “I have removed my original comment since I have decided to no longer engage in further debate with this individual and I apologize to any readers for becoming engaged in an argument that clearly went off point of the original article. I allowed this to become personal and I shouldn't have.”

    I see all your original comments including the personal attack “not sure what point you were trying to make, unless it was just about trying to debate semantics of the legal aspect which then serves no other purpose except to make one appear foolish! Taking things out of context as is the habit of many “green” thinkers does nothing to support this cause.”

    So while we're at it…if you think I am so clueless and pointless, how about you agree to remove the logo for the Natural Ingredient Resource Center “Truth in Labeling” pledge since upon review of your website, the ingredient in your products don't meet with the requirements…and since I wrote them dear, I should know.