One tiny European issue- nano or not.
Europe we have a problem, you see you know that new law that your Europollies passed about compulsory labelling of nanoparticles that comes into effect pretty much NOW? Well, that law is lacking in practical detail and when I say lacking what I mean is the measurement tools that one needs to use to work out if a particle is nano or not are very hard to come by – totally impractical – exist only in crusty old research institutions – under lock and rusty key. Oh and even if you do have a suitable measuring device little are many different ways in which to use it resulting in many different results. What is nano one way is massive another. Hmmmm.
And this is a problem because the confusion filters down from ingredient manufacturer to ingredient distributor and on to ingredient user/ formulator. That’s me, right there, the last stop on the R&D food chain and the hand that reaches out of the lab and touches the brand owner. It is us who get asked ‘does my product contain nanoparticles?’ and it is us who have to make sense of the technical info and relay it to an over-enthusiastic marketing team who feint at the slightest whiff of controversy before spending every last inch of energy trying to think up ways of making whatever ‘problem’ exists go away.
Clear as mud.
And that marketing issue leads to this which is why I’m worried.
My dear Europeland, you really really don’t like it when brands market themselves using ‘free from’ claims but then you go and play right into their hands by calling out nano particles on the ingredients label. Now I know that just adding the word ‘nano’ after an ingredient shouldn’t spell doom and gloom, after all everything from smarties and cappochinos to boxer shorts and T-Shirts come in small, medium and large without any controversy but this is different. You see (and I’m sure that a part of your brain realises this) that nano is different from other sized objects. Nano is tiny, really tiny. It is so small that scientists all over the world are being paid good money to find out if, nano-sized particles change personality (and chemical and physical reactivity) when shrunken into virtual obscurity (so we can no longer see them). Humans have never been too good at rationalising things that they can’t see. Take God, fairies, ghosts, wind, microwaves and electricity for example. When the eyes can’t see the brain runs free (or something like that) and before you know it people are prepared to fight wars, join political demonstrations, sacrifice their first-born, chant and spend thousands trying to re-define their life purpose. See the similarities with nano? I do and I also see that less than one year from here there will be products claiming ‘my product is nano free’ and yes you may be able to lock them up in big Euro-sized cells and feed them lasagne and trashy pop music through the iron bars but is that really going to solve anything? Non.
And all of this is going on Europollie in an industry that isn’t celebrated for its scientific credibility. In fact I’d go so far as to say that we are often referred to as the ‘used car salesmen and women’ of the science industry which is a subject for another post but in the meantime leaves me wondering what we actually wanted to achieve by all this?
It’s about choice, transparency and freedom of information.
Don’t get me wrong Europeland, while I may be a formulator or scientist if you wish I do wash, wear make-up and enjoy a good massage from time to time. This is because being a formulator is just a job, an act if you will. For the vast majority of hours in my life I am just another person, a customer, a mother. Through these ‘normal’ eyes I can appreciate that transparency of labelling including labelling nano has its place in life, is interesting and potentially empowering as it may enable me to make a choice:
Nano containing product OR nano-free!
However, what I don’t understand at this point is what I am supposed to do with this newly gleaned information given the lack of consensus and evidence about these things. Does my nano containing cosmetic product pose more or less risk to me than my product containing regular sized particles either in the short, medium or long-term?
So what do we do now Europe?
What do I do as a formulator?
What do I do as one of your great wannabe washed?
Well what is clear after visiting the hub of Euro-Cosmetic land that is In-Cosmetics is that this is one subject that is still ‘open for comment’ and as such it will keep on my research radar. Not only because I feel the law requires a little tweaking in terms of how it is applied but most importantly because we have to remember that this actually isn’t about measuring stuff in a laboratory, it is about our short, medium and long-term health and safety. For the record I am not convinced that calling out ingredients JUST because they fit a certain size parameter is of any use at all as size has never been the only thing that matters in life.