Yes and my product cures Eczema!!!!!

If there is one phrase that is over-used in the hobby/ market stall/ small brand end of town it is the above.  Their products or product CURE(S) Eczema.

Usually (and I sympathise) the brand owner has a family member close to them that suffers terribly with their skin. Maybe they feel that they can’t trust what rubbish commercial brands use in their products  (their sentiments, not mine) OR they have tried everything and have found a cure for them and now have turned it lose onto the world!  That is great in one way but not so great in another.

Eczema is a skin condition and cosmetics are not legally allowed to ‘cure’ or treat a known skin condition, that falls to the TGA here in Australia – it is very similar in the EU.  It is highly unlikely that any small market stall brand or slightly larger brand has gone through the hoops required to test their product to see if it does indeed help relieve eczema. There is no single cure for eczema just like there is never going to be a single cure for cancer as these two words are more pathology than causal (eczema is a word to describe skin that is flaky, dry, itchy, weeping etc. Those symptoms could be caused by any number of things including things going on inside the body).

I’ll just stop for a minute now and say that I am aware that small acorns do produce large oak trees and other such metaphors and yes, some of these small brands may well be onto something – innovation often comes from outside of the large cosmetic houses as the big guys are generally very conservative BUT this is a huge call and one that needs testing.

I try not to roll my eyes and groan when I see this as anything that helps people to feel better and feel more in control of their itching is a great thing. I know as I’ve suffered on and off my whole life.  However, I do get a bit of a knot in my stomach when I think of all of the weeping and open skin people who might try this anecdotal cure when I know that it is unlikely to have been made to the standards the TGA require. This does make a difference and I’ll explain why and how.

1. Micro Testing is something that small brands can barely afford.  It costs a few hundred dollars to run a micro count and much more for a preservative efficacy test.  Without these it is difficult to know if your product is clean enough to put onto broken or vulnerable skin.
2. Safety testing is not a requirement here in Australia but I would recommend it for products aiming to be used on vulnerable skin – babies, those over 70, sun damaged, eczema, psoriasis, cuts and abrasions, around the eye area etc.  Safety testing evaluates the whole formula to make sure it is ‘safe’ based on what we know about each ingredient.  Due to the fact that many smaller brands won’t have formal training in cosmetic formulation (I didn’t say all) there is usually little understanding of how much emulsifier to use, how much preservative is OK, how many actives are suitable, what purity ingredients should have, how much active to pop in and so on.   Yes there are help groups and forums online but it can be difficult to discern fact from fiction and to get accurate and specific information from these places as they are general by nature and the best advice is usually more personal (and often paid for).
3. Stability wise again it is often the case that smaller brands won’t have done stability testing on their formulations and this can also affect performance and safety over time.  Generally I’ll find a few brands who have been trading for a couple of years with the same formula and tell me that the formula doesn’t seem to change over time.  That is great but if you are selling a cure based on active materials you really should assay the actives to make sure they are still in the formula at appropriate levels for the duration of your shelf life.
4. Claim substantiation is another area where small brands often extrapolate from a very small base.  Just because you or your daughter saw improvements doesn’t mean everyone would and sadly this anecdotal evidence doesn’t count for much when questioned in court.  Not that it needs to come to that.  If you are wanting to sell or market a treatment for something a full and controlled efficacy experiment should be carried out.  This means that a strict use protocol is designed,  a panel of people are recruited and regular evaluations are conducted to measure the results in an organised fashion.  This is essential for a therapeutic good and is very costly if you want to claim many things.

If you are one of the above and you now want to poke my eyes out and tell me that ‘of course I would say that because I get paid to give advice’ or whatever that is fine but it isn’t really helpful.  I am not the only chemist in the world that can help, indeed if you have formulated what you think is a winning product there is no law saying that you even have to pay a cosmetic chemist to do anything for you.  You could go through and tick the above boxes yourself!   I am mostly concerned about the potential for this mis-guided enthusiasm to backfire on the individual brand owner, the customers and the cosmetics industry as a whole.

My advice would be that if you are a brand owner with an un-tested cure for eczema take a step back and think about these things as if your product really is that good maybe it is time to sit back and do it properly, one step at a time. But in the meantime you do need to comply with the laws of the cosmetic land or your dream career might come to an abrupt end.

By the way I am not in the habit of telling the TGA/ ACCC about non-compliant brands as that is not my job but as a brand owner it is your job to understand and at least attempt to play by the rules.  The definition of a cosmetic is found here.

Good Luck

Amanda