Clearly the sponsors of the Safe Cosmetics Act of 2010 have never had to design a packaging label for a personal care product. Otherwise, they would realize that requiring cosmetic makers to list almost every chemical (yes, chemical, not just ingredients) in a product would result in a package labeling nightmare.
Section 613 of H.R. 5786 would require all chemicals, including "detectable" trace elements, to be listed on the ingredients label of a personal care product. That means that a product containing water, for instance, would be required to list water on its ingredient label, as well as every other trace element found inside the water. This might include trace elements such as as copper, nickel, lead, and silver, depending on the source of the water and how it has been filtered. Water, like most natural ingredients used in personal care products, contains dozens of chemicals. Many of these chemicals are trace elements.
Lela Barker of Bella Luccè regularly orders labels for her all-natural, non-toxic bath and body products line from us. In a fantastic blog post about her recent trip to Capital Hill to voice her opposition to opposition to H.R. 5786, she gave a perfect illustration of how this bill would affect product labels in her industry. If Lela was to put a massage bar on the market tomorrow made with just three ingredients, she wrote, the label would look like this:
Olive Oil, Cocoa Butter, Lavendar Oil.
Under the proposed legislation, the ingredients label for the same exact massage bar would look like this:
Olive Oil (Tri-Glycerides of Palmitic, Di-Glycerides of Palmitic, Palmitoleic, Stearic, Oleic, Linoleic, Arachidic Acid, Linolenic Acid, Squalene, Beta Carotene, Campesterol, Methylenecholesterol, Stigmasterol, Sitosterol, Fucosterol, 28-Isofucosterol, Stigmadienol, Brassicasterol, 7-Cholestenol,Ergostadienol, Avenasterol, Triterpene Alcohols, Tirucallol, Taraxerol, Dammaradienol Beta-Amyrin Germanicol, Butyrospermol, Parkeol, Cycloartenol, Tirucalladienol, 4-Methlene 24-Dihydroparkeol, 24-Methlenecycloartanol, Cyclobranol, 4-Methyl Sterols, Esters of Tyrosol, Esters of Hydroxytyrosol, Vitamin E (Tocopherols), Carotenoids, Oleuropein), Cocoa Butter (Tri and Diglycerides of Stearic Acid, Palmitic Acid, Lead, Oleic Acid, Linoleic Acid, Isoleic Acid, Beta Carotene, p-Hydroxybenzoic Acid, Vanillic Acid, Ferulic Acid, Syringic Acid, Phenylehtylamine, Theophylline, Aliphatic Esters, Aromatic Carbonyls, Caffeine, Theobromine, Diketopiperazines and Alkylpryazines), Lavender Essential Oil ( Cineole Octanol, Octanone, Alpha Bisabolol, Alpha Cadinol, Alpha Humelene, Alpha Phellandrene, Apha Pinene, Alpha Terpinene, Alpha Terpineol, Alpha Terpinyl Acetate, Alpha Thujene, Alpha Thujone, Beta Bisabolol, Beta Pinene, Beta Thujone, Borneol, Bornyl Acetate, Camphene Camphor, Cineolealpha Terpineol, Carvone, Caryophyllene, Carophyllene Oxide, CIS Alpha Terpineol, CIS Alpha Bisabolene, CIS Carveol, CIA Linalol Epoxide, CIS Ocimene, Citronellal, Citronellol, Coumarine, Cuminaldehyde, Eugenol, Furfural, Geraniol, Geranyl Acetate, Geranyl Butyrate, Hexanol, Hexyl Tiglate, Isoborneol, Lavandulol, Lavandulyl Acetate, Limonene, Linanlol, Linalyl Acetate, Methyl Heptenone, Myrcene, Nerol, Neryl Acetate, Oleanolic Acid, P Cymene, Rosemarinic Acid, Sabinen, Terpinenol, Terpinolene, Trans Carveol, Trans Epoxy Linalyl Acetate, Trans Linanol Epoxide, Trans Ocimene, Ursolic Acid).
Currently, the largest die we have in stock cuts labels that are 10.25 by 16.75 inches, and we can custom order dies for labels up to 11.5 by 17.5 inches. Even though this means we can print labels larger than a sheet of legal size paper, that wouldn't be large enough for many of the personal care products we currently print ingredients labels for under the proposed legislation. But a letter size label, 8.5 by 11 inches, would be large enough to list the ingredients for Lela's hypothetical massage bar. There would even be room to list information about how to use the product, list its name, and maybe even squeeze in the company logo and some fancy artwork as well. Isn't that great? Well, it would be ... if there was a market for massage bars as big as sheets of notebook paper.
And this is just the beginning of the packaging nightmare ... don't even get me started on how many of our customers will end up throwing away product labels they can no longer use and deplete their resources finding new packaging containers big enough for the labels they will have to have redesigned and reprinted in order to meet the proposed ingredient labeling requirements.
If the Safe Cosmetics Act of 2010 passes as written, however, all this talk about being forced to perform packaging design acrobatics will be a mute point. You see, we won't have to worry much about producing ridiculously oversized ingredients labels for our many wonderful customers who produce natural bath and body products and safe cosmetics if this bill becomes law. Because most of them, sadly, will not be able to afford to stay in business if this bill becomes law. That, my dear readers, is the true nightmare that will be experienced by small business owners who maker personal care products if HR 5786 is passed.