I’m moving in two months so I need to fill up some of my bulky bottles and jars and get them on to new homes. So please stop by for my moving sale, where my body products are 50% off.

On sale now:

Scrubs

Sunny Citrus and Vegan Sugarcane Scrub with Sunflower Seeds

Cedar, Sage and Rosemary Olive Oil Refined Sugar Scrub

Lavender and Spikenard Vegan Sugarcane Scrub in Olive Oil

Massage/Hair Oil
Relaxababy

Rub Me All Over

Blood without Carnage

Rosemary for Your Hair

Perfume Solids
Jungle Sweat

Trashion Fragrances

Soaking Salts
Patchouli

Lavender

Citrus

Minty Fresh

Lurid

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Given my recent explorations into greenwashing, I was unsurprised to find that animal testing may well belong in that category of “claims made without validation.”

I’m aware that animal testing is funded, allowed, even encouraged – I’m especially aware of it living as I do near the University of Minnesota, where a great deal of medical research goes on, and where, consequently, a great deal of protesting follows.

As far as my personal position on animal testing goes, it may not be a popular view, but I prefer to be honest:

• Under no circumstances should cosmetics be tested on animals. EVER. If you’re putting lipstick on a pig, you’re swine.
• I have had many relatives die from cancer. I would like cancer to go away for every living being. Because I would like cancer to go away, I am willing to live with the suffering of some animals, since the Geneva Convention rules out excess use of testing on violent Death Row inmates, my preferred alternative.
• If a really excellent alternative to animal testing exists – something that could happen if we could get over our superstitions about cloning technologies – it should be used.

As to the FDA, there reads a hands-off tone as far as regulations of animal testing goes:

“Animal testing by manufacturers seeking to market new products may be used to establish product safety. In some cases, after considering available alternatives, companies may determine that animal testing is necessary to assure the safety a product or ingredient. FDA supports and adheres to the provisions of applicable laws, regulations, and policies governing animal testing, including the Animal Welfare Act and the Public Health Service Policy of Humane Care and Use of Laboratory Animals. Moreover, in all cases where animal testing is used, FDA advocates that research and testing derive the maximum amount of useful scientific information from the minimum number of animals and employ the most humane methods available within the limits of scientific capability.”

They do, however, link to the National Toxicology Program at the Department of Health and Human Services, where alternatives to animal testing are researched.

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I see a lot of newcomers to the bath/body/botanics industry promoting various lotions, potions and brews using the ubiquitious “No chemicals!” “No preservatives!”  credo to peddle their goods. And while peddling is a business necessity, these particular phrases aren’t so useful.

I have already discussed why “No chemicals!” is meaningless – everything is chemical. As to the “no preservatives!” discussion – well, I find the shelf life of Wonderbread and Twinkies disturbing, too, but given first that bath and body is not something you should be eating and second that few people routinely throw out their b&b goodies after six months¹ and fewer still refrigerate their lotions and potions, preservatives, reviled as they are, are a good idea. Without those preservatives, you could wind up getting very, very sick. Yes, the implication is that the preservatives themselves might make you sick. But the microbes that grow without their presence will make you sick.

In fact, the FDA spells it out pretty plainly: “A cosmetic is adulterated if

• it consists in whole or in part of any filthy putrid, or decomposed substance;
• it has been prepared, packed, or held under insanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health.”

It may be clean when you put it in the jars, but if it turns bad, it’s illegal. You would be culpable unto the law if you sent someone a lotion that eventually molds.

The big fuss about using preservatives is in the use of parabens – while the FDA is OK with them, they do seem to show up in an awful lot of cancerous removals. And, as is pointed out in this ingredients series by Luscious Naturals, parabens are not the only game in town. There are safer alternatives in preservation, and while perhaps not all are ideal – I certainly had a hilarious experience with the limitations of neem last winter – there are enough workable options available.

It is always worth investing in a customer’s long-term safety, and that was the original intention of using preservatives.

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1. yes, you are supposed to dispose of all cosmetics within three to six months of first use [↩]

There are a few new goodies released at Magickal Realism for you to enjoy:

Our sunny citrus olive oil and vegan sugar cane scrub has soft-ground sunflower seeds to soften up the sensation of grit just a little bit. Very wakey-wakey, with niaouli, grapefruit, sweet orange, lime, lemon, mandarin and tangerine.

Among our new fragrance releases are Incognito and Book Dust:

Incognito clings to your skin as though it’s part of your aura. A very subtle blend of an amber essential oil bouquet¹, honey, cypress, myrrh and frankincense for that royal hiding among the commoners feel. Samples are currently available here.

Book Dust is part of Magickal Realism’s Fancy Pants line. A complicated herbal green, it melds together sassafras, chamomile, dill, lotus absolute, honeysuckle infusion, verbena essential oil bouquet, and natural vanilla extract to create a fragrant impression of an old library. This is one I wear myself, often, when I need a general feeling of comfort.

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1. all amber is an essential oil bouquet [↩]

In my quest to understand regulations that much better¹ I’m delving even deeper into FDA regulations on cosmetics. So yes, another regulations series from me.

I am reviewing this time some of the layman’s documents provided by the FDA, in this case, their user-friendly document Is it a Cosmetic, a Drug, or Both?

What jumped out at me was this statement:

The FD&C Act does not recognize any such category as “cosmeceuticals.” A product can be a drug, a cosmetic, or a combination of both, but the term “cosmeceutical” has no meaning under the law. ((emphasis my own.))  I found this entertaining because US Vogue in particular has been obsessed with “cosmeceuticals.” Apparently they’re once again chasing after the Emperor’s latest outfit.

In a nutshell, unless the FDA tests and approves it, you can’t say that a product is good for any given condition in any customer communication whatsoever, whether that be verbal, in print, on the Internet or anywhere else. So when someone makes a lotion for treating excema they cannot legally say it is for treating excema even if every study under the sun actually concludes that the tea tree oil in the lotion helps the condition.  So, for instance, that dandruff shampoo? The FDA had to approve it before it could be sold as “dandruff shampoo.”

But this isn’t where it stops. If a product is commonly used a certain way, it will be considered a drug – even if the producer doesn’t have those expectations. Toothpaste with fluoride is named as a specific example of this. So if the public is aware of a certain chemical frequently used for a specific cause, the cosmetic will be classified as a drug regardless of the intended use of the producer (although there is probably a process involved.)

Most difficult among these guidelines is the following:

“Consumer perception, which may be established through the product’s reputation. This means asking why the consumer is buying it and what the consumer expects it to do.”‘

Now that’s difficult – it means that if people begin swearing by, say, Tiger Balm for its healing properties, then Tiger Balm becomes classed as a pharmaceutical even if no such claims were ever issued by the originating company. It basically makes all cosmetics producers responsible for what their customers may say about the product.

Since perception is a grey area, I’m curious as to what is required to fit a given legal definition.

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1. though word of written law is so enormous and changeable that 100% familiarity is unlikely [↩]

Last week, prompted by a mention on a Cropwatch missive, I posted inquiring about the Global Harmonization Act for 2008, and could not find the legislative information or actual verbiage of the act anywhere, except for one small snipped saying I could find it on a website (I couldn’t) and that I could write a certain address with an SASE – however, given the nature of legislative acts in the United States, I assume I couldn’t afford the postage let alone the truck to haul all the paperwork. I even contacted my city/county library, and the reference librarian pulled in a government documents specialist – and this was what they could tell me:

“What I did find was information on the Global Harmonization Task Force GHTF formed in 1992. U.S. Canada, the European Union, Japan and Australia were founding members. Its objective is: ‘to encourage convergence at the global level of regulatory systems of medical devices to facilitate trade while preserving the right of Participating members to address the protection of public health by regulatory means condsidered most suitable.’ There is a notice in the February 6, 2007 issue of the Federal Register vol.72, no. 24 concerning the recommendations of 3 of 5 study groups with the GHTF. Group 4 issued: ‘Guidelines for Regulatory Auditing of Quality Management Systems of Medical Device Manufacturers.’ None of the findings, guidances, or audits constitute mandatory regulations or laws.”

Shortly after starting this search, one of my guild members pointed me to this link talking about a hearing regarding new FDA Regulations. While the article does not say so explicitly it does seem to be related to this Harmonization Act, and also related to addressing the chronically understaffed and underresourced issues of the FDA. It also mentions that should the legislation pass as it is all cosmetics businesses would be required to pay a fee of $2000 in order to sell their products. This, much like IFRA’s attempt to ban nearly all naturals in perfumery last year, is nothing more and nothing less than an attempt to weed out micro-competitors like myself in order to protect their failing corporate profit models. Instead of addressing their internal problems by spanking greedy board members as needed, they are trying to shut down businesses that ultimately have no bearing on their own customer base – the people that buy from the small sellers wouldn’t buy from the big names to begin with, something they’d know if they did any genuine market research.

Some large corporations taking advantage of another big problem that the US in particular has, and trying to ride out a need cut to competition under the guise of law – unless the smaller sellers get it across that this is actually a violation of anti-trust regulations in the U.S. I’m certainly not opposed to regulated consumer safety, but this recommended fee is very clearly not about that.

I fully intend to write all my legislators about this, but before I do, I need the full information. If anyone can point me to it, please do!

If someone knows where I could find it, please, point me to it!

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I just found out for sure that I’m moving and since I’d like the process to be as painless as possible, I thought I’d start now by trying to get as much stock as I can out the door.

The prices are already marked down on my site – all you need to do is place an order!

Minty Fresh Soaking Salts

Lurid Soaking Salts

dirty jasmine, pomegranate and lavender

Dip Me in Chocolate

cocoa absolute and anise, a classic women’s aphrodisiac blend

Lavender Soaking Salts

Citrus Soaking Salts

Patchouli Soaking Salts

Lavender and Spikenard Vegan Sugar Cane Scrub

Comes out very earthy, but sweet

Apricot Kernel and Vanilla Sugar Cane Scrub

Unscented Olive Oil and Vegan Sugar Cane Scrub

Rosemary for Your Hair Hair Conditioning Oil

Relaxababy Massage Oil

Bliss Massage Oil

Rub Me All Over Massage Oil

Olive Oil and Refined Sugar Scrub, Unscented

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Customer education is an uphill battle at best, but sometimes I think moreso for natural perfumers. Because of the prevalence of mislabeling and using “natural” as a marketing term only, those new to true all-natural perfumes bring their expectations based on their experience with purely synthetic and synthetic/natural fragrance blends.

So, for those who don’t already know, here’s the news:

Naturals don’t behave like synthetics at all. The differences in behaviors between synthesized molecules and natural ones is dramatic, and this inconsistency is what has led to schisms in practice and philosophy between naturalist and syntheticists.

As a basic key, here is what to expect from your natural perfume:

• As it evaporates, it will reveal layers – sometimes layers from the same plant note. Verbena is especially complex in this manner.
• Citrus will last for a very short time.
• The scent will not be strong the way we typically think of strong perfumes. It will have an opening note and quickly change nature.
• Natural perfumes are usually subtle and cleave to the skin – they are not designed to take over a room, but are instead intended to alter the character of your personal space in a way only perceptible to you and to those with whom you are intimate.

It is frequently the case that what you find at first sniff will not resemble what you smell on your skin an hour later. There are a lot of components involved in this, especially your own biology.

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There are two ways of viewing “naturals” in perfume.

The first is that it smells like something natural. So a synthetically created eugenol that happens to smell like vanilla might be classed by some perfumers as “natural” in that it mimics something more molecularly complex.

The second is that it is or came from the natural. The assumption here is that at the beginning of processing a given chemical, there was a real live plant (or in some cases animal) involved. This is also the area where questions are raised because of what happens in order to distill that chemical or scent. For example, some argue absolutes are not natural because of the hexane used in processing – while it still starts with a plant, it is rendered “unnatural” because of any solvent residue. I disagree with this, personally, although I understand and can follow the reasoning: to me an absolute is still natural, although it may not be quite so environmentally friendly or safe to use as a result of the use of hexane. I expect to see some of these arguments subside as C02 extraction becomes continuously more applicable to delicate botanic sources.

These differing approaches to the meaning of “natural” is in part where the marketing melee originates. Industry marketers may well know the meaning of “natural” coming from a modern traditional perfumer, but will also know that a typical western consumer operates on the belief that the definition of natural falls into the second category; all too few are aware of the difference and that the only guarantee is the USDA certified organic label or the EU equivalent.¹

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1. I am unversed in any organic certification available beyond EU and US. [↩]

In the latest communication from Cropwatch, there was mention of a Global Harmonization Act of 2008. This piqued my interest – I’m not exactly thrilled with the decisions about perfumery materials IFRA has been making, since they are founded on next to no data, and harmonizing the FDA standards with EU standards – standards that IFRA has far too much say in thanks to the chronically overburdened nature of such agencies – I am a bit concerned. My concern may be for no other reason than because I like my over the counter headache medicine to have an effect without having to take half the bottle. It could also be because yet more legislation will impact my life and livelihood while I have little or no say in the matter.

Certainly, the overarching goals of the Global Harmonization Task Force are noble: making sure every country is on the same page about pacemakers and prosthetics is pretty darned important to the people that have them and to the medical systems that support them. It says on their website,

“The purpose of the GHTF is to encourage convergence in regulatory practices related to ensuring the safety, effectiveness / performance and quality of medical devices, promoting technological innovation and facilitating international trade, and the primary way in which this is accomplished is via the publication and dissemination of harmonized guidance documents on basic regulatory practices. These documents, which are developed by five (5) different GHTF Study Groups, can then be adopted/implemented by member national regulatory authorities. The relationships between the work of each Study Group can be represented schematically.”

Reasonable goals, to be sure.

Yet there is intimation that some of those goals will have a resounding impact on the cosmetics and fragrance industries.

Such regulation would have a huge impact on all our lives. Yet on a surface search, I could only find this reference on the FDA website to anything regarding the act. In the electronic access form, it sends me back to the Global Harmonization Task force page – where I can’t find a complete copy of the act or guidance referred to. I’m going to give a try to the writing or faxing method – I really want to see the data, in full detail.

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