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Sharon Trotter RM BSc

Midwife, Breastfeeding Consultant and Neonatal Skincare Advisor

MIDIRS 2007 - skincare

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Baby products: It’s all in the labelling

The full reference for this draft article is Trotter S (2007). Baby products – it’s all in the labelling. MIDIRS Midwifery Digest, 17:2, 263-266


Sharon Trotter recently joined us at MIDIRS to present our second Webinar; ‘Skin deep –neonatal skin/cord care: exploring best practice in skincare and umbilical cord care of the neonate’. The following article will focus on the wider issues surrounding the use and labelling of manufactured baby products and the legislation in place to protect consumers.

Where are we now?
Labelling legislation
What’s in a label?
Sensible precautions for all

What is the cosmetics industry doing to help?


As a passionate advocate of safe skincare for the neonate, the author’s published work on this subject (Trotter 2002, 2003, 2004, 2006) has led to the promotion of a ‘minimal’ approach to skincare in the use of products described as cleansers or for skin nourishment. In the UK, this advice is now supported by the latest Postnatal Care guidelines (NICE 2006).
This article will focus more closely on the information supplied by the manufacturers of skincare products. In today’s commercial world, marketing jargon is awash with claims which attempt to persuade consumers to part with their money. The marketing of baby products is no exception offering even more persuasive arguments where new parents are concerned to do ‘the best’ for their newborn. New parents are bombarded with ever more sophisticated advertising campaigns which can be confusing as well as inconsistent.
The majority of these products carry quite forceful messages of beneficence where it is implied their use will benefit the baby. In most cases, it is now clear that these claims are not really balanced as while there might be potential short term benefit, there might also be longer term harm (Fatter 1997, Kownatzki 2003), Misleading labelling will only improve when manufacturers are forced to review the information they provide as a result of robust legislation globally.
The example of food products is a case in point. Government health initiatives in the UK (Food Standards Agency and Healthy Living) continually highlight the issues of safe and responsible food labelling designed specifically to help consumers make an informed choice on what they are buying and ultimately eating or drinking. Consequently, the quality of the information on the labels of food products has improved. More people now read these labels and are becoming ‘label aware’.
What then of the personal care products we use to clean and beautify ourselves, our babies and our children? Do we read these labels as diligently, and if so, do we understand what they mean? What legislation is in place to protect us, the consumers, and what are the major corporations doing to reassure us on issues of safety? [back to top]

Where are we now?

  • ‘Medela® Purelan 100’ and ‘Lansinoh® Brand Lanolin’ are among only 1% of products that have had all their ingredients tested for safety by the Cosmetics Ingredient Review (CIR 2004).
  • A recent independent survey carried out by the manufacturer of ‘Ocean Pure Cleansing Spray’ (Page & Ridout 2006) found that only 34% of respondents (total of 172 participants canvassed) said they read the labels on baby products. This was in contrast to 90% of respondents who said they read the information labels on food products and 80% of respondents who said they bought their baby products from major supermarkets. It would therefore seem fair to expect these large retailers to provide customers with helpful information to guide them through the confusing data on baby products. This is especially important as babies and young children are among the most vulnerable population groups.
  • Where tests have been undertaken using patch, stability and EpiOcular testing, whilst useful, these cannot guarantee safety. Additionally, these tests are usually carried on adults and bear little relevance to the effect products may have on babies and children.
  • There are no standards or definitions to govern the use of the term ‘hypoallergenic’. The basic ingredients used in the manufacture of ‘hypoallergenic’ products are the same as for standard formulations. The only difference is marketing, both on the packaging and associated literature. The same applies to products labelled ‘sensitive’, ‘natural’ or ‘organic’, which may also contain ingredients potentially harmful to people with a particular sensitivity to certain ingredients. The only way to find out if a product is safe is to read the full list of ingredients on the label and to avoid using products containing ingredients you know to be of concern. [back to top]

Labelling legislation

In America, legislation for labelling is the responsibility of the Food and Drug Administration (FDA) within the Center for Food Safety and Applied Nutrition (CFSAN)/Office of Cosmetics & Colors (1995). This department regulates labelling, but has no authority to require or approve safety testing on raw materials used in cosmetic products. The toxicology of ingredients used in personal care products is largely untested, although the Cosmetic Ingredient Review (CIR) does publish annual reviews (costing $100) and a cosmetic compendium (costing $350) available online from www.cir-safety.org .
The CIR was established by the Cosmetic, Toiletry & Fragrance Association (CTFA) with support from the FDA and the Consumer Federation of America (CFA). Funded by the CTFA, CIR is an independent body charged with reviewing and assessing the safety of ingredients used by the cosmetics industry. The expert panels collate results in an open peer review of scientific literature and the final reports are published in the International Journal of the American College of Toxicology (CIR 2004).
With 89% of ingredients still not being tested for safety, the Environmental Working Group (EWG) decided to carry out its own testing. This project, called ‘Skin Deep’, is now an online rating system to assess the safety of 10,000 personal care products (www.ewg.org ). The Women’s Environmental Network, (WEN) in association with the Swedish Society for Nature Conservation and Healthcare Without Harm, further highlighted the issue of Phthalates in European cosmetic products with their publication ‘Pretty Nasty (DiGangi & Norin 2002).
In Europe, the manufacture and marketing of cosmetics is regulated by the European Cosmetics Directive (76/768/EEC). The Commission of the European Communities established a scientific steering committee to co-ordinate the work of the Scientific Committee on Cosmetics and Non-Foods (SCCNFP 2002). The onus is on the cosmetics industry to self-regulate and approximate related laws to all Member States.
In the UK, the Department of Trade and Industry (DTI) is the responsible body. The DTI publish guidelines through the Cosmetic Product (Safety) Regulations, the most recent of which became law in September 2004. This latest directive adds 75 substances classified as carcinogenic, mutagenic or toxic to reproduction (CMRs), to the list of banned substances now thought to be potentially harmful and sets a deadline for the abolition of animal testing on ingredients used for cosmetic products.
After many years of negotiations, a more precautionary policy has finally been adopted and will become law in June 2007. Registration, Evaluation and Authorisation of Chemicals (REACH) places the responsibility on industry to provide appropriate safety information and replaces 40 existing pieces of legislation with a single system for all chemicals. The day-to-day management of the new requirements will be carried out by the new European Chemicals Agency (ECHA) in Helsinki. [back to top]

What’s in a label?

Labels on cosmetic products destined for home or personal care use must display:

  • A full list of ingredients (in descending order of molecular weight) using the chemical name as defined in the International Nomenclature of Cosmetic Ingredients (INCI). This is a system of names based on the scientific and/or Latin terminology which is accepted as an international standard.
  • The name and address of the manufacturer and/or distributor statement.
  • Material facts and warnings, or cautionary statements – specific warnings are required on bubbles baths, feminine deodorants, coal-tar hair dyes and baby products that have the potential to cause harm (for example, baby powder and the associated risk of asphyxiation from inhaled particles).

Salon products used by professionals and free samples given out in hotels are exempt from full labelling. Labels only need to provide the name and address of the manufacturer and/or distributor and any warnings. [back to top]

Sensible precautions for all:

The cosmetics industry as a whole has a good safety record considering the numbers of ingredients and products on offer. However, there is no room for complacency. Ingredients which may seem innocuous on their own have the potential to irritate sensitive skin (specifically in babies and young children) when added to a cocktail of other chemicals. With this in mind, it is sensible to keep exposure to an absolute minimum and follow these simple rules:

  • Avoid using any manufactured baby skincare products for at least the first month of life. Instead, use plain water and cotton wool (preferably organic and unbleached). Once introduced, opt for baby products that are free from sulphates (SLS and SLES) as such products are less likely to irritate.
  • Read the label of any skin product and if in doubt contact the manufacturer
  • Stick to a few tried and tested products
  • Never mix different preparations
  • Use products before the ‘best before date’
  • Shop around for simple preparations that are ecologically sound and contain as few preservatives as possible
  • Baby products worthy of a mention include; Halos’n’Horns, Weleda Baby, Organic skincare by Beaming Baby, Green Baby, Ocean Pure, SOS Barefoot Doctor, Aromababy and Organic Babies and Children range
  • When washing baby clothes and bedding, try not to overload your washing machine to ensure thorough rinsing
  • Opt for diluted essential oils rather than synthetic fragrances
  • Wear less make-up and stick to products in one range
  • Beware of marketing hype
  • Choose products that are not over packaged from companies that have a specific policy on recycling and are seen to be ethically aware [back to top]

What is the cosmetics industry doing to help?

For their part, it is encouraging to see that manufacturers are working towards a more open and transparent approach to information provision.
Examples of good practice include the Unilever Safety and Environmental Assurance Centre (SEAC) based in Colworth, UK. In that Centre, a group of experts work independently of the marketing and product development teams. They concentrate on consumer safety, occupational safety and environmental care. These experts have forged strong links with professionals in the dermatological community and regularly publish work, including data from research programmes. Ongoing collaboration with other health care professionals, as well as consumer and patient organisations, within the field of skincare, will further help to foster good relationships between industry and the general public.
Another interesting tool used at Colworth has been developed to determine the potential risk of any specific chemical. This unique knowledge base is called DEREK and stands for Deductive Estimation of Risk from Existing Knowledge (Smith Pease et al 2003).
www.viadirekt.nu was launched recently in Sweden. On this website, consumers can check whether specific ingredients they are sensitive to are contained in any Unilever products. This gives people access to information that would otherwise be hard to find.
Likewise, the Proctor & Gamble website www.scienceinthebox.com is a positive way of making a huge resource of key information accessible to a wide ranging audience. Proctor & Gamble’s scientific publications, their methodology to assess human and environmental safety, as well as product and safety data are available on this site.
Consumer Carelines are another innovative way to foster good relationships with the consumers. The speed of feedback they provide is a quick and efficient way of identifying any potential problems as soon as a new product is launched.
Large retailers within the supermarket sector are also devoting time and resources to new websites and store magazines. These give parents access to useful information and product reviews, as well as forums and online communities they can join. [back to top]


Ingredients alone do not tell the whole story and it is the formulation of these ingredients that is important to skin safety. Consequently, potentially harmful chemicals can be mixed in such a way and in specific concentrations as to render them perfectly safe to use. Conversely, seemingly innocuous mixtures (agglomeration or mixed micelles as they are known) could react together causing irritation to the skin surface. It is the responsibility of manufacturers to get this balance right
In this new era of openness, effective communication is vital. Information needs to be open, accurate and in a format that is accessible to all. Secrecy is no longer an option for multinational companies who must be seen to work in collaboration with their customers so that a relationship of trust and understanding can be achieved.
Clearer labelling and better product information must go hand in hand to enable consumers to become ‘label aware’. By providing the public with consistent advice and commonsense precautions, the cosmetics industry can minimise any potential problems associated with the use of everyday personal care products. [back to top]


"A proposed motion to this years RCM Conference to stop the routine supply of baby skincare products within UK maternity units was recently rejected (this does not include the provision of Bounty bags which is a separate issue).
This means that many units will continue to supply baby bath and baby wipes, no longer recommended for neonatal use by the Postnatal Care Guidelines, published in July 2006 by NICE (www.nice.org.uk ). If units are struggling to change policy on this issue it may be worth highlighting this as a potential clinical risk. The author will be re-submitting the motion in 2008. It is no longer relevant to use such products on newborn skin and there exists no data to support its use during this period". [back to top]


Cosmetic Ingredient Review (CIR 2004). Annual review of cosmetic ingredient safety assessment – 2002/3. p37-47. Washington DC: CIR.

Di Gangi J & Norin H (2002). Pretty Nasty – Phthalates in European Cosmetics Products. Published by Healthcare Without Harm, USA and in association with Women’s Environmental Network and Swedish Society for Nature Conservation.

European Directive (76/768/EEC). The rules governing cosmetics in the European Union: Volume 1, Cosmetics Legislation, Commission, 1999 edition with February 2003 update (directive 2003/15/EC).

Fatter G, Hackl P & Braun F (1997). Effects of soap and detergents on skin surface pH, Stratum Corneum Hydration and fat contents in infants. Dermatology, 195:258-62.

Food and Drug Administration (FDA) (1995). FDA Authority over cosmetics. Center for food safety and applied nutrition. Office of Cosmetics and colors fact sheet. February 3rd 1995.

Healthy Living Campaign in association with NHS Health Scotland and The Scottish Executive. Accessed on 22/01/07 at: http://www.healthyliving.gov.uk/

Kownatzki E (2003). Hand hygiene and skin health. Journal of Hospital Infection, 55: 239-45

Page G & Ridout P (2006). Chemicals in personal care products and baby wipes – questionnaire/analysis from short research study. Unpublished report. Ocean Pure Ltd, for more information contact info@oceanpure.co.uk

Scientific Committee on Cosmetics and Non-food Products, SCCNFP/0411/01, 2002.

Smith Pease C K, Basketter D A and Patlewicz G Y (2003). Contact allergy: the role of skin chemistry and metabolism. Experimental dermatology, 28(2):177

Trotter S (2002). Skincare for the newborn: exploring the potential harm of manufactured products. Royal College of Midwives Journal 5(11): 376-8.

Trotter S (2003). Management of the umbilical cord - a guide to best care. RCM Midwives Journal 6(7): 308-11.

Trotter S (2004). Care of the newborn: proposed new guidelines. British Journal of Midwifery 12 (3): 152-7.

Trotter S (2006). Neonatal skincare – why change is vital. RCM Midwives Journal, 9(4):134-8.

UK Food Standards Agency (2000). Independent Government Department set up by an act of parliament to protect the public’s health and consumer issues relating to food. Accessed on 22/01/07 at: http://www.food.gov.uk/ [back to top]

© Sharon Trotter 2013
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