This product may well be ‘Security Protected’ but every one of its ingredients is illegible — obscured by the sticker which has been placed over the listing, almost certainly by the retailer (to whom I complained), not the skincare brand (which is Nivea).
Although worldwide there remain outstanding issues regarding the transparency of labelling of household products such as wall paints and laundry products, when it comes to cosmetics, there are tighter regulations. Ingredients must be present, and visible.
In the US, here’s the Cosmetic Labelling Guide from the Food & Drug Administration. With some exceptions, ingredients — “in descending order of predominance” — must be listed, a rule which is now four decades old. Furthermore, the text must be “Prominent and conspicuous to render it easy to be read and understood by ordinary individuals under normal conditions of purchase”. Lettering of 1/16th of an inch in height is usually required.
In the EU, here’s Regulation 1223/2009 on Cosmetic Products, which states that ingredients must be reproduced fully on cosmetic products in “indelible, easily legible and visible lettering” — although there do not appear to be size requirements, as in the US. Furthermore: “The list of ingredients shall be established in descending order of weight of the ingredients at the time they are added to the cosmetic product.”
The Nivea sun care product pictured above happens to be MI-free — as should be all leave-on products now in the EU — but of course, the legibility of ingredients labels is not only important to MI-allergy sufferers, but those with allergies to other cosmetic ingredients (such as fragrances, lanolin, nut oils) and to those with eczema, or ethical, religious or environmental sensibilities. All these people need to check ingredients on cosmetics to ensure that they are free from the ingredients that they need or want to avoid. All the samples of the Nivea products on the shelf were ‘security protected’ in the same way, in the same location so it was impossible to ascertain both what was present — and absent.
Reporting problem products
Have you seen any cosmetics — be they MI-free or MI-containing — with obscured or unclear ingredients labelling? Did you complain to stockist, retailer or manufacturer? In general, do you find it easy to locate — and read — ingredients on packaging? Do share your stories, and if you’d like to share pictures, you can do so on my Facebook post here, or please email me images here.
Do complain, by the way. It’s important to complain – whether relevant to MI allergy or not. We need to foster a wider understanding that clarity of ingredients is vital information to a diversity of consumers.
And finally, if you need a reminder of the terms used on ingredients labels for MI and other isothiazolinones, then see our Other Names for MI article, although only a few of the examples will ever be seen on cosmetics, as most ‘alternative’ names turning up on non-cosmetic products and their safety data sheets.