Sometime last week, I received an email from a company who had asked me to test their eye product recalling the item because one of the ingredients was slightly over the Singapore Cosmetic Directive limit. I was rather surprised because the product is already sold in the market. This means that it was sold prior to gaining approval from the Health Science Authority (HSA) here as under the cosmetic directive which regulates the manufacture and placing on the market of cosmetic products, sellers will need to send all cosmetic products for specified tests. So was the company at fault?
Products can be sold even without testing
Well, no because companies can sell their products as long as they have notified the authority. According to information listed at the HSA website, “The product can only be marketed after the notification has been sent to HSA and acknowledgement received.” However, notification and acknowledgement of a product “does not constitute, in any way, an agreement that the product meets all the regulatory requirements. The onus is on the company responsible for placing the product in the market to ensure that the product meets the requirements of the Cosmetic Directive. ”
Going by this, it seems to be possible for irresponsible companies to continue selling their products without ever having them tested. And as consumers, how do we know especially if the products are not from the big boys in the industry? An example would be those imported cosmetics you purchase via a spree or from a blog shop.
Product labelling must follow the Cosmetic Directive
If I interprete correctly, it appears that cosmetic companies which have their products approved must also abide by the Cosmetic Directive Labelling Requirements and one of the requirements is to have ingredients and instructions in English. Besides that, the packaging must include country of manufacture, batch number, contents by weight or volume in metric, name and address of company or person responsible for placing the product on the local market. So products without such information may not be following HSA’s directive.
Aligned with the European Cosmetic Directive
These requirements by the way fall under the ASEAN Cosmetic Directive, which must be implemented by all member countries by January 2008 and it is closely aligned with the European Cosmetic Directive. For more information, check out this link.
FDA cosmetic regulation
As for those in US, they’re protected by the FDA but it appears that cosmetic products and ingredients are not subjected to FDA premarket approval authority, with the exception of color additives.
The FD&C Act does not subject cosmetics to FDA premarket approval in order to be marketed legally. However, FDA collects samples for examination and analysis as part of its plant inspections, import inspections, and follow-up to complaints of adverse reactions. FDA may also conduct research on cosmetic products and ingredients to address safety concerns. (source)
Regulations for handmade cosmetics
And when it comes to handmade cosmetics, sellers must also comply with the FDA laws and regulations that the big companies follow. For example, the FDA does not accept natural preservatives in creams and lotions such as essential oils, grapefruit seed extract, rosemary oil extract, Vitamin E or potassium sorbate. In addition, if the product contains a color but the seller did not state it, they are also not complying with the FDA regulation. For more readings, refer to this article.
Your opinions please
At the end of the day, we may not always know if the cosmetics we’re buying are really approved according to the local cosmetics authority. The best way to know is to ask, but of course there are some of us who are not too concerned about knowing. What about you? Do you care and would you only buy products that are tested and approved? Please also share any added information you may know about such cosmetics regulations.
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I do care the product safety very much. I rather trust well-established brand and buy from trusted source. I only know many cosmetic giants actually outsource their production for lower cost, so… putting hope in government regulation. ;p
I presume they would still take care of the marketing aspects and ensure their products are tested and approved since they have a reputation to guard.
Personally, I won’t risk my face to any non-approved product especially it make of chemical that will cost a lifetime regret if anything bad would happen to its.
My only choice would be recognized, approved and tested product will be my choices.
I agree…those with sensitive skin should all the more only use approved and tested products.
i do care but sometimes these labels are so confusing to me. i tend to go for established brands and also trust the gov & regulator to be the stringent gatekeeper.
I know what you mean. I never gave two hoots about them till I started blogging. Before that, I didn’t even care about reading the ingredients. But now, I take an interest because I want to learn more.
Thanks for this very informative post, Sesame. I’m afraid it never did cross my mind, and I’ve always removed that “Imported By” sticker even before reading them (can’t stand price tags and anything sticking on my stuff).
I’ll definitely put more care into this in future. Product safety and regulations are essential. Don’t want to be using faulty products which can potentially harm me.
It hardly crossed my mind too. But I do think about products that are sort of “nameless” and appear slightly dubious in terms of packaging. And I absolutely hate it when I can’t read the instructions and ingredients in English!
I didn’t really think about that. I thought that those stuff which are sold on the shelves of drugstores like watsons and guardian are approved. Now I know that its not necessarily the case!
I read a japanese beauty book and the author does not recommend any skincare below 3,000 Yen (over S$50).
Coincidentally, I have been trying higher end stuff and they’re doing great for me at the moment. I sincerely do hope they are approved!!
In terms of regulator, I think the FDA has rather tight regulations. I should feel more safe if the product is FDA approved. However, not all American stuff works for me.
Rather, I think French skincare works for me. However, like the L’oreal sunscreen which uses Mexoryl, they are not approved by FDA until recently.
So, I guess I shall think more when I purchase stuff to put on my face going forward.
I suppose there’s a logic why established products tend to cost more due to the amount they have to invest. But I don’t agree with the author though. There are some products that don’t cause much but do wonders too.
I agree French products are great. I’ve got good experience using them. The one I told you I’m using now also comes from there.
Actually, this info about not all products being tested came from a cosmetic company here. They told me how some companies are using the gap between notification and approval to exploit the system.
Hmm… normally I get the impression that all products sold here have already gone through the necessary check, except for online sprees.
You’re not alone. We tend to think that way but no, there are gaps in the system. And there are also many small shops selling cosmetics. These products are also likely not approved by HSA.
rather trust the brands in the departmental stores or pharmacies =]
thx for the tip off
rather trust the brands in the departmental stores or pharmacies =]
thx for telling us
i guess its still not enough to read the ingredients without knowing what it really does when mixed together without any tests
Yup, formulations are something tricky and sometimes the ingredient list can’t tell us too much since the companies also don’t always reveal the percentage of each ingredient included.
Thanks for that informative post. And yes, like many others posted above, I too think that products sold here have passed these checks.
I’d definitely only trust brands that actually have got the proper approval, which is why I sometimes prefer to go for the mass market brands because I *know* for certain that these companies follow a set of guidelines that I can check up on their website and such.
This is probably becoming more problematic nowadays in the race for “purest”/”natural”/”organic” that it’s easy to slip chemical preservatives under other labels and still pass these tests.
I’ll also be more careful when I review products in future. This never really came up on my radar cos I never imagine there was a crack in the system. Now, except for those products that are readily available in the mass market, I’ll make an effort to check if the product has been approved (whether FDA or HSA) before posting – especially if they’re just sold online.
Well not entirely true that “continue selling their products without ever having them tested”. For the product to be marketed -> they have file with HSA. And if they tell HSA -> they have to send samples for testing. So we’ll know sooner or later. (thou we all prefer sooner)
What bothers me more is that, more often than not, product recall is done quietly. (eg. elf recalled some products earlier this year and I only CHANCED upon a forum post…at a much later date.)
Oh and another thing that bothers: products which has “use-within” period printed (eg. ’12M’ which is 12 months, printed inside a half open jar) but no manufacture NOR expiry dates. Companies are supposed to at least print either of the dates, either which depends on the products’ minimum durability > or <30M. Now when should I start counting the 12M? When I first open the product? But some products aren't tightly sealed at all…
You’re spot on about the manufacture date. I wish they have it more transparent and not using batch code which is not easy to decode. A simple use by date would also be good but it’s only a requirement for natural/organic products.
As for notification with HSA, it’s true that companies have to file but I understand from one source that some companies wait till they’re reminded to send their samples for testing, which could be a long long time and I also won’t be surprised that some small ones do fall through the crack entirely. Plus considering that there are so many companies, I doubt the authorities have the resources to keep tabs unless there are active watchdogs and policing. The story about the blogshop being told to stop selling colored contact lenses was an example – it only came to the authorities’ attention after their shops were featured on the papers – if the story didn’t appear, would the authorities ever know? But my guess is these small-time sellers probably do not know the procedure and they’re not out to exploit.
Products that are recalled are actually listed on HSA’s website though I’m not too certain if all are listed. Apart from contact lenses solution, I agree with you that I don’t hear much of these recalls. Plus who checks the HSA website anyway except those with personal stakes?
I didn’t start understanding certain ingredients and reading labels until recently. And I wouldn’t want to put anything on my face that isn’t safe. If I found out that a company came out with a product that wasn’t approved, I would stop purchasing their stuff. I completely agree with the above poster. There’s so many products out there that “claim” to be natural/organic and its really not. You just have to try and be more cautious and do your research.
Yup, the awareness will help us to be more vigilant. Afterall, we’re paying for the product and the company that is at the receiving end is expected to be more responsible.
This article really makes you think…thanks!
I’m curious about small sellers of handmade skincare outside of Singapore and US. Do they also need to notify the HSA?
If the products are brought in to sell on the shelves, yes they have to notify HSA. But if online, nobody controls that territory.