The Cosmetic Ingredient List & How Ingredients Get Their Names with Dr. Mindy Goldstein

[Intro] Hey, everyone. Welcome back to Facially Conscious with myself, Trina Renea, esthetician, Dr. Vicki Rapaport, dermatologist, Rebecca Gadberry, the cosmetic ingredient guru, and our fabulous, overly-educated consumer, Julie Falls. We are gathered here together with you to talk about this crazy world of esthetics. It's confusing out there in this big wide world. 

That's why we are here to help explain it to you all, subject by subject. We will be your go-to girls, and from our perspective without giving medical advice, we will keep things facially conscious.

Let's get started. 

01:03 Trina Renea: Good morning, everyone, and welcome back to Facially Conscious. Happy New Year!

01:07 Rebecca Gadberry: Happy New Year!

01:09 Trina Renea: Wooh, 2023! So exciting.

01:13 Rebecca Gadberry: I can't believe I've lived that long. 

01:16 Trina Renea: Rebecca Gadberry speaking there. Rebecca, how old are you? Just kidding.

01:23 Rebecca Gadberry: I'm 70. Can you believe that? 

01:25 Trina Renea: What?

01:26 Rebecca Gadberry: Yes, I am proud of my age. 

01:29 Trina Renea: Well, you look amazing. You have no wrinkles.

01:35 Rebecca Gadberry: Don't trust anything else she says. 

01:40 Trina Renea: You know, she is behind the scenes in the cosmetic industry, so she has some secrets we don't all know. 

01:48 Rebecca Gadberry: One of the secrets we're going to talk about today is how to read an ingredient list, and even why it's on the container. 

01:56 Trina Renea: That's a confusing thing for even me as an esthetician, because I feel like things change or maybe it's just me changing.

02:05 Rebecca Gadberry: Maybe it's your memories changing.

02:06 Trina Renea: Yeah, maybe my memory. So we have an awesome guest with us today that is going to explain to us about the ingredient list on your bottles. Rebecca, would you like to introduce your lovely friend?

02:19 Rebecca Gadberry: I would. We have been friends since the late ‘80s, to show you how old we both are. She actually got into the industry in I think 1987. Her name is Dr. Mindy Goldstein and she holds a Bachelor's in Biochemistry, a Master's in Pathology and has a PhD in just basic medical sciences, but she specializes in DNA and DNA repair. I would love to ask her during some interview that we do with her this year, because she'll be a returning guest at some other points, how she went from pathology and DNA into the cosmetic industry. But we'll hold that for another time.

She is also a patent holder. She holds patents in raw materials encapsulations, controlled-release ingredients. Those are your time-released ingredients. 

She is a consultant in the cosmetic industry. I know her this way from the Society of Cosmetic Chemists. She's our former president. She was president twice at a national level. She has written articles, chapters and books. I think if we go on and on and on about Mindy, we’ll take up the whole time.

If you want to learn more about Mindy and her background, just go to faciallyconscious.com, the About page. Her picture is there, so you can see how lovely she is, and also her full bio. 

I did want to mention, Trina, she's on the nomenclature, the naming committee that names ingredients. And we're going to be talking about how ingredients get their names today as well as what the regulations are that govern that area of real estate on the container, the ingredient list.

Mindy also consults with raw material companies, ingredient companies as well as brand names. So she does so much in this industry. Some of the biggest products in the industry would not be here without Mindy. 

I am absolutely delighted to talk with you.

04:40 Trina Renea: I love these deep dives because we find out information that nobody even knew existed. It's so cool, because this is something I'm going to learn today for the first time. I'm so excited.

04:53 Rebecca Gadberry: I think I'm going to learn some things too, even though I teach this at UCLA. Mindy is incredible. So, Mindy, would you like to say hello?

05:02 Dr. Mindy Goldstein: Hello, everybody. I'm very excited to be here.

05:05 Trina Renea: Welcome.

05:06 Dr. Mindy Goldstein: Thank you.

05:08 Rebecca Gadberry: As you could tell, we're excited to have you here. We've been really looking forward to this part of the year coming up, because this is going to be an incredible year at Facially Conscious.

Before we jump into all of this, Mindy, I want to make something really clear with our audience because there's so much misinformation out there. One of our missions here at Facially Conscious is to correct the myths and the misinformation. One of the things that I want to clarify is that ingredients are chemicals. Another word for ingredient is chemical. Feel free to say chemical, Mindy, when we're talking rather than just ingredients. 

People need to understand that you can't have a chemical-free product. Everything is a chemical but light and electricity. So when we talk about chemicals in products, we're talking about ingredients. When we talk about ingredients, we're talking about chemicals.

06:13 Trina Renea: I think that the people who are concerned with chemicals and wanting chemical-free products, they're more naturalists and they want as natural as they can get and not using synthetic ingredients is what they mean, but they use the word chemical freely in the market.

06:30 Dr. Mindy Goldstein: Right, but the problem is everything is a chemical, including water, which of course is natural.

06:37 Trina Renea: So you're on the committee that names these ingredients.

06:41 Dr. Mindy Goldstein: Yes.

06:42 Trina Renea: How do you guys come up with that?

06:44 Dr. Mindy Goldstein: Okay. So the committee is the International Nomenclature Committee and it's part of the Personal Care Products Council, which we call PCPC.

06:56 Rebecca Gadberry: Which is our largest industry organization. Is this part of the FDA, Mindy?

07:04 Dr. Mindy Goldstein: No, it's not part of the FDA. The Personal Care Products Council, PCPC is a standalone organization that serves the cosmetic industry. Companies join it, both finished goods companies, such as Estee Lauder or L'Oreal, and many raw material companies that supply the ingredients to these, the finished goods companies, are members as well.

The committee, which is called the INC, the International Nomenclature Committee…

07:40 Rebecca Gadberry: Nomenclature meaning naming.

07:41 Dr. Mindy Goldstein: Naming, we meet approximately five times a year for a two-day session. PCPC gets applications from usually raw material companies that want names for new ingredients. We have a form that gets filled out, depending upon what the compound is and how it's manufactured. And then those applications come to the committee for review.

There are quite a few people on the committee. We're about 20 people on the basic committee and then we have liaison members.

08:17 Rebecca Gadberry: What's that?

08:18 Dr. Mindy Goldstein: Liaison members are not really part of the committee but they sit in on the committee and they do participate. We have two people from the FDA, we have one person from Health Canada, we have someone from the Japan Cosmetic Industry Association, we have somebody from the US Adopted Names Council.

08:39 Rebecca Gadberry: What’s that?

08:42 Dr. Mindy Goldstein: That's, I guess, they give the US adopted names, which is usually used in drugs. 

We have someone from the European Commission and we have somebody from the Cosmetic Ingredient Review, the CIR, and a couple of other people as well. The basic members come from both raw material suppliers, finished goods houses and universities. 

People are asked to join this committee. It's a different committee than most PCPC committees, which are made up of member companies and they can recommend somebody for the committee. They tend to stay for a short time and then cycle off and somebody else comes on.

Our committee typically is long term. I've been on this committee for over, I want to say over 27 years. And you meet five times a year, about five times a year, typically in February, either the end of January, beginning of February, in April, in June, in September and November. We review applications that come in between our meetings.

10:04 Rebecca Gadberry: For new ingredients. Are there that many new ingredients?

10:07 Dr. Mindy Goldstein: Oh, my God. Well, when the dictionary was first published, 1973 was the first edition, I think there were about 3,500 names in that dictionary.

10:21 Rebecca Gadberry: Yeah, I remember that.

10:23 Dr. Mindy Goldstein: Now, we're over 16,000. Yeah, we give a lot of names. Yes. And there are over 60 trade names associated with those 16,000 or so INCI names. INCI stands for ingredient for International Nomenclature Cosmetic Ingredient.

10:53 Rebecca Gadberry: INCI.

10:54 Dr. Mindy Goldstein: INCI.

10:55 Rebecca Gadberry: And those are the names, those are the actual names of the ingredients.

11:00 Dr. Mindy Goldstein: That go on the back of the label.

11:02 Rebecca Gadberry: Got it. So those are known as the INCI names, right?

11:06 Dr. Mindy Goldstein: Right. Only the FDA mandates that there be disclosure on the back of every bottle that's sold. We're talking about retail or anything that's being sold to the consumer.

11:22 Rebecca Gadberry: Right. Professional doesn't have to have, professional use only, like the products that you would use in the facial room, Trina. And they're not being sold to consumers then you don't have to have the ingredient list on there. 

A lot of companies are voluntarily putting the ingredient list on and the FDA has said you can put them on alphabetically, in alphabetical order, but a lot of companies, if you ask, they'll tell you what it is. Did you have something you wanted to add to that, Trina?

11:58 Trina Renea: I just was wondering sometimes, with me, I'll ask the clients to bring in their products and I'll look on the back of it and it won't have an ingredient list because it was on a box that they threw away. So that's legal?

12:13 Rebecca Gadberry: The actual law is from the Fair Packaging and Labeling Act that went into effect in 1977. It's an act of Congress that FDA was charged with regulating. So it has to do with the outer package so that consumers, this particular law, so that consumers can see if there's any allergens in them.

12:34 Dr. Mindy Goldstein: Right. If they can recognize any allergens in the product.

12:37 Rebecca Gadberry: Right. The problem I have with that is when you have an allergy after you've started using a product a lot of times and then you've thrown the box away. But these days, you can also look online on a lot of companies and the ingredients will be listed there.

12:54 Dr. Mindy Goldstein: Or you can request an ingredient disclosure from the company that you bought the product from. They will gladly send you the ingredient deck if you explain…

13:03 Trina Renea: If they bring me a product that doesn't have ingredients on the back, I mean, we have the internet, so I just look it up. And I can always find the ingredient list. It's always on their website under ingredients, under that specific product. So if somebody does throw away their box, you can always find it or call the company.

13:19 Dr. Mindy Goldstein: Usually you can. Yes, call the company is better because sometimes on the website, they don't include the full ingredient deck.

13:27 Trina Renea: Oh, really?

13:28 Dr. Mindy Goldstein: I have seen where they say only the primary ingredients and they don't really have everything that's on there. 

13:37 Trina Renea: That is a good point to know. So if somebody is…

13:39 Rebecca Gadberry: And that’s another point. Go ahead.

13:42 Trina Renea: I was just going to say if somebody is having an allergy to an ingredient and they've thrown away their box, a better move would be to call the company and ask them for a full…

13:53 Dr. Mindy Goldstein: Yeah. The whole idea behind the ingredient list was so that the consumer could check the list against what they know are allergens for themselves. And when we give names, we try to keep the product, the ingredients that could possibly cause allergy, we try to keep some semblance of a common name with it. 

For instance, soy, which can be an allergen for some people, or peanuts, or wheat, we try to keep— because by nomenclature convention, we have to use the genus and species of the plant. But in parentheses next to it, the common name. So if we had the genus and species of the wheat, we’d put wheat in parenthesis. The same thing for peanut and other nuts as well, which are common allergens in the population. 

So we try to make it as friendly as possible, and that was the whole reason behind the ingredient list. Of course, a lot of the chemical names a consumer would not understand or recognize, but that's what their physician is for. So if they have a reaction, the physician can actually get the information on that one ingredient, if necessary, if it's not any of the common allergens.

15:23 Rebecca Gadberry: In the spirit of our mission here at Facially Conscious, there's a myth going around that the ingredient list is there to reveal the toxins in the product, which is not true.

15:35 Dr. Mindy Goldstein: No.

15:35 Rebecca Gadberry: Allergens are not toxins.

15:36 Dr. Mindy Goldstein: Right, allergens are not toxins. That in the US, if there's a fragrance in the product, we don't have to reveal on a US label any of the allergens in the fragrance. But in the EU, you must put those allergens on the label.

15:55 Rebecca Gadberry: In Europe.

15:57 Dr. Mindy Goldstein: In Europe. The European Union requires those to be listed as part of the ingredient list.

16:01 Rebecca Gadberry: And I think there's what? 26 different…

16:04 Dr. Mindy Goldstein: Right now, but it's expanding. It's going up now. I forgot how many, but much more. Much more.

16:12 Rebecca Gadberry: We actually will do a list of the allergens that are part of this podcast, so I will put them up on our blog. And you'll be able to click on that in the Show Notes, everybody. So I will list the common allergens in fragrances.

16:34 Trina Renea: Go ahead.

16:36 Dr. Mindy Goldstein: According to the FDA, because of the labeling act, the names for the ingredients must appear in certain documents. Number one is the INCI dictionary, the compendium that has all of these names. 

The second choice is the United States Pharmacopeia. Third choice is the National Formulary. And then there's the Food Chemicals Codex. And then there's United States Adopted Names, USAN, and the USP Dictionary of Drug Names. 

17:19 Rebecca Gadberry: The US Pharmacopeia is USP. The National Formulary is NF. And you might see those listed behind an ingredient, for instance stearic acid NF. The NF legally shouldn't be there, or the USP shouldn't be there in a cosmetic, but it needs to be there in a drug. Is that right?

17:43 Dr. Mindy Goldstein: Right.

17:44 Rebecca Gadberry: Like an over-the-counter drug that you don't have a prescription for.

17:48 Dr. Mindy Goldstein: In an OTC, you have to have a Drug Facts label on the product.

17:55 Rebecca Gadberry: And it'll say Drug Facts on the label. It's in like a box, right?

17:58 Dr. Mindy Goldstein: It's in a box, a specific box. There's a standard that the FDA requires. The top part of the box has the active ingredients, so what is considered the drug, the over-the-counter drug and you have to have the percentage content of that.

For instance, in an acne product, you have to have the active ingredient. In many cases it's salicylic acid. And you have to have the percentage that's in that bottle. So for instance, the OTCs over-the-counter drugs have monographs specified by the FDA and they list the levels that you can use active ingredients in an over-the-counter product.

Salicylic acid in an acne product can have anywhere from 0.5% to 2% salicylic acid. So whatever the percentage is in that bottle has to be listed. Typically, we do not list percentages on a label…

19:01 Rebecca Gadberry: For cosmetics.

19:02 Dr. Mindy Goldstein: For a cosmetic. It's only in OTC. Then you’ll also see on an OTC label is, under the active ingredients, you'll see additional ingredients that are not considered actives. They’re the base ingredients. And depending upon what claims are being made on that product, if there are cosmetic claims then the ingredient list has to be in descending order as on a cosmetic. 

If there are no cosmetic claims, it can be in alphabetical order, like a drug.

19:35 Trina Renea: Oh, interesting.

19:38 Rebecca Gadberry: So let me ask a question here. There's several things that come to mind, actually. An over-the-counter drug, you'll know it's an over-the-counter drug because it'll have the Drug Facts label on it.

19:51 Dr. Mindy Goldstein: On the outer packaging.

19:52 Rebecca Gadberry: On the outer packaging. You'll know it's a cosmetic if the Drug Facts label is not present, right?

20:00 Dr. Mindy Goldstein: Typically, unless they're making drug claims on the product that are not allowed by the FDA.

20:06 Rebecca Gadberry: Right, but that would be a cosmetic making illegal drug claims.

20:10 Dr. Mindy Goldstein: Right, illegal drug claims.

20:12 Rebecca Gadberry: So the difference between a drug and a cosmetic, do you want to share with us what that is?

20:20 Dr. Mindy Goldstein: Based on the FDA definition of a cosmetic, it's meant to beautify, and a drug is meant to treat. That's the simplest way to put it. A drug is meant to mitigate a problem, such as acne, such as anything else that you may have issues with.

20:44 Rebecca Gadberry: Sunscreens are drugs.

20:45 Dr. Mindy Goldstein: Sunscreens are OTCs, so they're over-the-counter drugs, as is an acne product an over-the-counter drug.

20:53 Rebecca Gadberry: The other thing I have an issue with, and this is me from a marketing standpoint, and you kind of touched on this earlier, there's active ingredients, which are drug ingredients, and inactive ingredients, which are cosmetic ingredients. If you say active ingredient when you're describing a product's ingredients and it's a cosmetic, you're implying an illegal drug claim. So we like to say performance ingredients. That's what Trina and I and most of the other people in the industry now say. 

The thing I don't like about over-the-counter sunscreens, like moisturizers and lipsticks and foundations, is that when you look at the label, it's a Drug Facts label because the sunscreen in it is going to take precedence as far as the labeling.

So when you say active ingredients at the top of a moisturizer with sunscreen, all of your goodie ingredients that are doing your performance for more moisturizing and maybe fighting signs of age or lightening or brightening the skin, those are going to be under inactive ingredients. It's very easy to get confused as a consumer that why am I using this product if the ingredients aren't active except for the sunscreen. Any ideas on that?

22:17 Dr. Mindy Goldstein: Yeah. That's a hard one. Yes, legally, in a drug scenario such as the sunscreen, such as the dandruff ingredient and a few others. Take acne, because it's very simple and everybody talks about acne products or sunscreen. In order to make a sunscreen or an acne claim, you have to have one of the specified active ingredients in the drug monograph.

22:48 Rebecca Gadberry: And the drug monograph is kind of like when you manufacture a drug or you market a drug, you have to get permission from the FDA before you market it. But the monograph has been put together with all of the specific processes and ingredients and claims that you can make…

23:07 Dr. Mindy Goldstein: And the labeling.

23:08 Rebecca Gadberry: And the labeling prior to going to market if you make it according— and that monograph was okayed by the FDA.

23:16 Dr. Mindy Goldstein: Yeah, it was issued by the FDA.

23:18 Rebecca Gadberry: Right. So as long as you conform to the requirements set out in the monograph for the particular category of cosmetic drug it is, you don't have to get preapproval because they've already approved it.

23:33 Dr. Mindy Goldstein: But you have to register it with the FDA.

23:36 Rebecca Gadberry: Right, and you have to do the tests and everything according to the monograph. And monograph-covered categories are skin lightening. Not brighteners but lighteners.

23:47 Dr. Mindy Goldstein: Right. There are no longer any lighteners that are allowed under the monograph.

23:50 Rebecca Gadberry: Oh, that’s right, because hydroquinone…

23:57 Dr. Mindy Goldstein: Hydroquinone has been removed as a Category 1 ingredient.

24:04 Rebecca Gadberry: Category 1 meaning that it's okay.

24:07 Dr. Mindy Goldstein: It was safe and effective. GRAS, as we call it, generally regarded as safe and effective. And hydroquinone has its own issues with safety. It's still allowable under prescription, but it can't be sold under the OTC guidelines.

24:26 Rebecca Gadberry: In other words, you can't walk up to a shelf and grab a skin lightener.

24:30 Dr. Mindy Goldstein: Grab a hydroquinone skin lightener. So you can't really legally make skin lightening claims because it's considered a drug now. So you could talk about brightening, you could talk about evenness of skin color, but you can't talk about, literally, skin lightning.

24:51 Rebecca Gadberry: Right. There's also acne preparations, there's the sunscreens, there's the skin protectants, antifungals. All of those things are over-the-counter drugs. There's no anti-aging monograph, by the way.

25:07 Dr. Mindy Goldstein: No. No, it's not a— cosmeceutical is not a valid name. The FDA does not recognize that as a separate category.

25:15 Rebecca Gadberry: Okay, so you just tossed a whole new word into there. And cosmeceuticals by market definition, not by FDA definition because, as Mindy said, there's no such thing as a cosmeceutical according to the FDA, a cosmeceutical has been defined in the past as a drug making cosmetic claims, which is also known as an over-the-counter drug that we've been talking about or a cosmetic making drug claims, which is illegal. There's no such thing as a cosmeceutical. That's a real problem.

25:50 Dr. Mindy Goldstein: Right. It's a madeup name.

25:52 Rebecca Gadberry: Well, Dr. Kligman, Dr. Albert Kligman…

25:54 Trina Renea: Like a medical esthetician.

25:55 Rebecca Gadberry: Yes. We just talked about medical estheticians, so, yeah, like a medical esthetician. There's no such thing as far as the state licensing agencies are concerned.

You were going through, you went through five different sources…

26:14 Dr. Mindy Goldstein: Right. Of names. 

26:16 Rebecca Gadberry: Or references to pick a name. It's my understanding that the first choice is the PCPC dictionary or the INCI dictionary.

26:25 Dr. Mindy Goldstein: Right. 

26:27 Rebecca Gadberry: And that's one that you okay all the names to go into, is that right? You and your group?

26:33 Dr. Mindy Goldstein: Right. The committee works on those names and only the INCI, the committee can give a legal name to an ingredient, and the name is…

26:44 Rebecca Gadberry: That the FDA recognizes.

26:46 Dr. Mindy Goldstein: That the FDA would recognize. And the name is based on what the material is. If it's a synthetic chemical, it's named by typical chemical nomenclature. If it's a natural ingredient, so if it's isolated from licorice roots, it will get a name based on ‘glabra’, which is the genus of licorice. It will have the genus, the species and then the plant part and whether it's an extract or just ground-up plant or whatever. It depends on what it is. But it's based on what the material is and how it's processed as to what the name is.

Let's take one step back. The committee is split into three subcommittees. 

27:42 Rebecca Gadberry: Okay. The naming committee.

27:44 Dr. Mindy Goldstein: The naming committee, so there's a group that does organic and inorganic chemicals. There's a group that does polymers and silicones.

27:56 Rebecca Gadberry: Those would be polymers. They're not plastics. They're actually long-chain molecules.

27:58 Dr. Mindy Goldstein: Right. Chain molecules that are synthetically made. And then there's the group that I chair, because I actually chair this group, is the subcommittee on biotech, botanicals and fermentation. 

28:13 Rebecca Gadberry: That sounds like it's the busiest committee of all.

28:15 Dr. Mindy Goldstein: Yes, it is. It is the busiest group. We just had a meeting in November and our group had 750-some odd pages of application.

28:27 Trina Renea: Oh, jeez. 

28:28 Rebecca Gadberry: How many ingredients was that?

28:32 Dr. Mindy Goldstein: I never count the ingredients. I just look at how many pages I have to review.

28:35 Rebecca Gadberry: Do you ever reject? Do you ever reject an ingredient application?

28:39 Dr. Mindy Goldstein: Yes, we do.

28:41 Rebecca Gadberry: At this point, dear listener, we went off into the weeds of deep chemistry, so we've decided to spare you the pain of listening to all that. We pick back up by explaining the order in which ingredients are listed on the package.

28:56 Dr. Mindy Goldstein: The ingredients are listed in descending order. The highest level goes first and then follows down in descending order of percentage, up until 1%. Under 1%, you can list the ingredients in any order that you want, the exceptions are colorants, which are at the end of the list, and preservatives which are always under 1%. Very rarely will you see a preservative over 1%, a true preservative.

29:29 Rebecca Gadberry: Now, that 1%, where does it usually— if you know about the 1% rule, Mindy, and I want to buy a skincare product, I want to buy a moisturizer, where might I see that 1% fall? 

29:42 Dr. Mindy Goldstein: There's no way to know. Looking at an ingredient list, you need a cosmetic chemist to say, “Okay, this ingredient is typically used at greater than 1%.” And you know that everything under that would be under 1%, but there's no way for a consumer looking at a list to know where that 1% break is.

30:05 Rebecca Gadberry: Here's another one that keeps coming up. This is about fragrance. There's all this mythology that the FDA has colluded with the cosmetic industry to hide toxic ingredients in fragrance and that's where you're going to find the ingredient. It's a way to mislead the consumer.

30:26 Dr. Mindy Goldstein: The only thing that, for fragrance, especially for the European Union, is any allergens that are in that fragrance over a certain percentage or certain level must be listed on the label.

30:37 Rebecca Gadberry: They need to be listed separately from the fragrance?

30:39 Dr. Mindy Goldstein: Separately. Separately from the fragrance.

30:42 Rebecca Gadberry: Okay. And in the United States, we don't have to do that, but some companies are doing it because they sell in Europe.

30:48 Dr. Mindy Goldstein: Especially if they're marketing in Europe.

30:52 Trina Renea: What about vitamins and plant extracts? Sometimes you'll see like Vitamin A or Vitamin E or sometimes it's listed as a different ingredient.

31:01 Dr. Mindy Goldstein: Right. The nomenclature, the official nomenclature for Vitamin E is tocopherol. And if it's modified, it would have an additional chemical modifier…

31:13 Rebecca Gadberry: Like acetate.

31:14 Dr. Mindy Goldstein: Tocopherol acetate or ascorbyl palmitate. Ascorbic acid is Vitamin C, tocopherol is Vitamin E and retinol is Vitamin A, or retinyl palmitate, etc. They're forms of Vitamin A.

You're not supposed to put that Vitamin A or Vitamin C or E behind the INCI name in the ingredient deck. So it could be your romance copy on the package. 

31:47 Rebecca Gadberry: We call it cell copy or information.

31:50 Dr. Mindy Goldstein: We call it romance copy. 

31:54 Rebecca Gadberry: I'm a romance writer.

31:57 Dr. Mindy Goldstein: Right. It could be anywhere in your romance copy but should not appear in the ingredient list. Nothing that's not an INCI name should appear as part of the ingredient list.

32:07 Rebecca Gadberry: I think that's important to remember. That piece of real estate, like I said at the beginning, is owned by the FDA, basically. We cannot…

32:17 Dr. Mindy Goldstein: It's mandated by the FDA.

32:17 Rebecca Gadberry: It's mandated by the FDA and we cannot change it no matter what we want to do. We can't put the source of an ingredient in parentheses, we can't put the chemical or the common name in parenthesis.

32:32 Dr. Mindy Goldstein: If it's not part of the INCI name given by the FDA.

32:35 Rebecca Gadberry: That's found in the dictionary. Is there any way for consumers to see that dictionary?

32:42 Dr. Mindy Goldstein: A consumer would not have access to the dictionary. That is a subscription from Personal Care Product Council. They just have to buy into it in order to see it.

32:57 Rebecca Gadberry: Okay. So you'd have to— well, I think there's a website with a podcast called the INCIDecoder. 

33:09 Dr. Mindy Goldstein: Right, but it's not official from the Personal Care Product Council.

33:16 Rebecca Gadberry: Right, but I don't know if they have listed all of the INCI names.

33:22 Dr. Mindy Goldstein: You can find, you can search the web by the name on the back of the bottle and see what comes up. In many cases you'll find it somewhere, but it's not the official listing from the dictionary necessarily.

33:39 Rebecca Gadberry: Another way I find it is I just enter the name of the ingredient that I see with INCI name, I-N-C-I all caps name on Google and a lot of times it'll come up.

33:51 Dr. Mindy Goldstein: Sometimes it comes up.

33:53 Rebecca Gadberry: Okay. Trina, you wanted to ask something?

33:57 Trina Renea: Yeah. So if a consumer sees a product that she's using or she buys a product and she sees that there's all kinds of— after listening to this, she's like, “This company is making all kinds of lies.” Do they just stop using the product or is there someone that they can call? They can't call the FDA. Who are they supposed to report them to?

34:18 Dr. Mindy Goldstein: The National Advertising Council, the NAD.

34:24 Rebecca Gadberry: They're part of the Better Business Bureau.

34:27 Dr. Mindy Goldstein: Yeah, you can report it. Usually, things on labels are challenged by advertising associations when a competitor brings it up to the advertising association. So if L'Oreal says, “Lauder is lying on their label,” and they can go to the NAD, the National Advertising Division, and say, “Look, this is a lie. Make them prove it.” 

NAD may take on that case and challenge Lauder and Lauder will have to prove what they're saying. 

Usually, that's the way these kinds of things happen. There's only a couple of cases where ingredients change name. We do update our conventions for naming based on scientific literature and new technology. 

For instance, ceramides. Ceramides are popular lipids that are used in cosmetic products. Years ago, it was listed on the label as Ceramide 1, 2, 3, 4, 5, 6. The name has changed, so the scientific literature has changed the name of how ceramides are named. And so we have reformed based on the scientific literature to stay current with what the science is.

And we always try to stay current with the science. So, names for plants, the genus and species of a plant may change.

36:08 Rebecca Gadberry: Well, we want to thank you for taking so much time to explain all of this. I would love to have you back later this year to talk about some of the new ingredients that you're seeing in your committee and where you think the industry is going as far as ingredients are concerned. 

But we like to do takeaways at the end of our podcast. So if we could just do maybe three or four takeaways for our listeners because they've gotten a lot of information, a lot of technical good stuff. This is meeting those behind the scenes.

36:41 Trina Renea: Yeah, like what should people be looking for on an ingredient list.

36:46 Rebecca Gadberry: I think one of the things is that ceramides, the product that you may use with ceramides that you've used for years, the ingredient name may change for ceramides, so not to be concerned about it because the ingredient itself has not changed. 

37:01 Dr. Mindy Goldstein: Usually, like for key ingredients, which are the ingredients that really give the product their efficacy, its efficacy on your skin, it doesn't have to be very high up on the list because some of these ingredients are very effective at low levels. For instance, peptides are really effective at exceedingly low levels. And so they will never even approach 1%. They'll never approach 0.5% on the list.

Don't always look at where the ingredient is on the ingredient list, because it's not always representative of how much efficacy it has in your product.

37:43 Rebecca Gadberry: Right. More is not better.

37:45 Dr. Mindy Goldstein: Right. More is not better in many cases.

37:46 Rebecca Gadberry: As a matter of fact, more can be worse.

37:49 Dr. Mindy Goldstein: Right. For tocopherol, Vitamin E, the higher the tocopherol, you can actually be oxidizing instead of antioxidant.

37:59 Rebecca Gadberry: We also want to know that if an ingredient has common names in parentheses, for a plant, that's okay, but for a vitamin, that's not okay.

38:11 Dr. Mindy Goldstein: It's only okay in a plant if that is the actual INCI name that was given to that ingredient. 

38:18 Rebecca Gadberry: And we may not know that.

38:19 Dr. Mindy Goldstein: Right. You can't just put corn. If it's not part of the original given name from PCPC, it doesn't appear in parentheses. The ones that tend to be allergenic, such as nuts, peanuts, we try to put common names in parentheses so the consumer can recognize it.

38:41 Rebecca Gadberry: Peanut, soy, wheat, I think, were the examples.

Dr. Mindy, we are so happy to have had this time with you.

38:49 Dr. Mindy Goldstein: Thank you.

38:50 Rebecca Gadberry: I look forward to talking with you again.

38:54 Trina Renea: Yes, that was so fascinating, Mindy. Thank you so much.

38:57 Dr. Mindy Goldstein: Oh, you're welcome. It was my pleasure.

38:59 Trina Renea: You gave such an insight to people, so this is awesome. We look forward to having you back.

39:04 Rebecca Gadberry: Yes, we do.

39:05 Dr. Mindy Goldstein: Anytime.

39:07 Rebecca Gadberry: So, everybody, have a good rest of your day, no matter what time you're listening to us. Take a look at the Show Notes for some nice references, as well as links to our blog on our website, and of course Dr. Mindy's background bio and a way to reach her, if you would like to know more about her services in the way of her consultancy.

Everybody, take care.

39:36 Trina Renea: You too.

39:38 Dr. Mindy Goldstein: Take care. 

39:38 Trina Renea: Bye.

39:38 Dr. Mindy Goldstein: Bye-bye 

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