A few months ago we went to see the comedian Lee Hurst in Hemel Hempstead. He was very funny but there were two moments when my heart sank. First was when I realised that instead of being a couple of rows back the seating numbers meant that we were actually in the front row. This is the not the place to be in comedy gigs unless you are happy to be part of the act. Up to being dragged on stage, as happened to me last summer in the Reduced Shakespeare’s Company “Complete World of Sports: Abridged” in the West End but that’s another story.
Secondly was when Lee Hurst looked at me and asked:
‘So what do you do then?’
I mumbled something incomprehensible and as a result he declared I was being evasive and therefore I was a secret agent. I wish it was the case. Sadly it is because I cannot really explain what my job is in a way that does not put people to sleep after two or three minutes of earnest description.
I was reminded of this again at the weekend when I found myself making disapproving noises at products in a friend’s bathroom, and later at the fruit juice on the breakfast table. Yes. I am that sad. If you invite me in, you can guarantee that I have passed away a few moments reviewing the labeling compliance of your purchases.
I just cannot stop myself after twenty years of doing it day in, day out.
The art of regulatory affairs, at least in the cosmetics sector, is often about compliance with technical legislation. There are three main tiers – what products can and cannot contain, how they should be labeled and information that needs to be kept, primarily regarding the safety of a product. Here in Europe, this latter point is (rightfully) the main focus.
Part of this is the labeling of the product – warnings and the like, ingredient labels – but in reality there are few warnings required as cosmetic products (and here we are using the word technically so it is shampoos, skin creams, soaps etc and not just mascara) are just not very dangerous products and/or it is pretty obvious how to use them.
Ingredient lists are largely unread by the vast majority of people (they are there so if you have an allergy to an ingredient you can avoid it, but most of us don’t know of any allergies we may have so the usefulness is limited.
So, all those complicated labels are really only for a few people and to meet an expectation that consumers want lots of information that they never knew they needed and have no idea what they want to do with it.
So here are my three favourite bits of ingredient labeling trivia. Go pick up that shampoo bottle and follow along with me if you really have nothing better to do.
1. A tricky descent?
We are used to seeing ingredient labels on foods that have the list of ingredients in descending order so we kind of assume that a similar looking list on our skin cream is the same. It may not be, however. For cosmetic products, only ingredients that are present over 1% in the formulation must be in order. For a lot of products that may only be the first two or three ingredients. So don’t assume that your hero botanical ingredient that appears fourth in a list of twenty ingredients is in the correct place. It may be; just order is no promise of how much of the stuff is in there.
2. The tale of “Aqua”.
With apologies, this is not the story of the creators of “Barbie Girl” but possibly as odd…
When the ingredient labeling rules were being developed here in Europe the question of language arose. Do ingredients need to be translated in the multiple official EU languages?
Sensibly the answer was “no” as otherwise you would need a small book to be given to you each time you buy some toothpaste. So the idea was to have a standard set of name conventions. Indeed this was supposed to be internationally accepted – International Nomenclature for Cosmetic Ingredients (“INCI“).
That meant using simple chemical names that anyone in theory should understand for most substances – and that‘s science, so politically acceptable to effectively use English. But the question arose for those ingredients that have common names – water, honey etc. and botanicals. Since it would be entirely unfair to choose one EU language over another… The EU chose to use a language nobody uses outside of Roman Re-enactment groups – Latin. So we have “Aqua” instead of “Water“, “Mel” instead of “Honey“, and the Linnaean nomenclature (I love that word, just had to use it) for botanicals. Of course the global thing was up the spout right from the start – the USA, the most obvious market to converge with – requires “Water” and shows no sign of improving the Classical Education of the masses.
3. We’ll always have Paris.
I am still not entirely sure what went on when, having decided on Latin, one word that applies to the vast majority of products somehow slipped in… In French…So we have “Parfum” rather than perfume, some Latin thing or the US “Fragrance”. Why? I’ve no idea. France sees itself as the spiritual home of the perfume industry and maybe enough expensive brandy was passed around at the European Institutions one afternoon that it seemed a good idea at the time. Or maybe it was just thought to be more romantic. Even European Institutions have feelings it seems.
Like a lot of EU rules, the heart is actually in the right place; the execution though doesn’t quite survive the proverbial clash with reality.
OK – that’s quite enough. I really should have enthused about what a lovely weekend I had in the sun, wandering around medieval castles and the New Forest but sadly I did feel it was time to talk about what I did. And it is strangely cathartic. And now no one will ask me again.
But I wish I really was a secret agent. But then I’d probably have to kill you all to protect my secret identity so boring you pants off is probably a better option.