A proposed document is currently working its way through the European system that will enforce cosmetics manufacturers to label ingredients in the nano form.
Although applauded by a number of consumer and interest groups as a move towards transparency, the proposals are not foolproof and particular controversy surrounds the definition of a nanoparticle.
“There is a definition within the proposals but it isn’t water tight,” explained Chris Flower from the UK trade body the CTPA.
According to Flower, one of the problems with the definition is that it doesn’t recognise that ingredients do not have a uniform size. In other words the percentage of an ingredient that has to be in the nano degree before it becomes a nanoparticles is not clear.
In addition, there are questions over how many dimensions of a particle must be in the nano size. At present the definition states one or more dimensions which would include very thin plates, that many people feel should not be included in the definition.
Global industry needs global definition
A further problem surrounds the global nature of the industry. The proposed labelling regulations will cover Europe only but the industry’s major players work globally.
The US currently has no labelling system proposed, although a number of consumer and environmental groups are pushing for more transparency.
However, transparency, if not well managed, can bring confusion, according to Sonya Lender, from the US consumer group the Environmental Working Group (EWG).
The group historically pushes for transparency in consumer products labelling but the nanoparticles in sunscreen poses a more complicated case, she said.
“EWG is one among many consumer groups to have called for more transparency when it comes to product labelling and the notification of nano ingredients,” she told CosmeticsDesign.com.
However, for Lender the lack of a clear definition poses problems and clarification would be needed before labelling could be insisted upon.
In addition, transparency is positive only if it communicates something meaningful to the consumer, she said.
She highlighted a number of products in the US that are claiming to be ‘nano-free’. Aside from questioning whether this claim could actually be backed up, she said it was unclear how this form of marketing was useful for consumers.
“PABA [a UV filter now rarely used] free claims are big, but the ingredient is hardly used and the claim engenders fear in the consumer,” she explained.
Such thoughts are echoed by Chris Flower, who is not a fan of ‘free from’ claims.
“In general I think ‘free from’ claims are unhelpful. If people are advertising ‘nano-free’ there is the possibility they are trading on people’s fears,” he said.
“What we need to remember is that there is no safety issue with nanoparticles. Labelling nanoparticles is a case of transparency and the industry has nothing to hide. If a product is unsafe it should not be on the market, regardless of whether it contains nanoparticles” he added.