In between garden-greening downpours last week our FreeFrom Skincare Awards judges did manage to sniff the jasmine on their way down to the garden for a quick cup of coffee. But for most of the week I fear they have been locked away sniffing frankincense and lavender and patchouli and neroli – or…. deciphering labels.
You would think that our problem in judging the entries would be deciding between creamy balms and oily balms but in fact, when judging skincare products, one of the major issues is ensuring that everyone is abiding by the mind-bindingly complex regulations.
First there are the medical claims
These are not new. Quite rightly they were put in place to prevent consumers being misled by manufacturers claiming that their products could ‘cure’ this medical condition or ‘heal’ that one when they had no proof, beyond a wish and a prayer, that they could.
While this has certainly helped to protect consumers it has made it extremely difficult to market products which genuinely do help medical conditions such as eczema. The nearest you can legally come to promoting your product is to say that ‘the product can be suitable for those with skin prone to eczema’. Not only convoluted but plenty of ways to get the wording wrong.
Then the more general claims
These are the ones that are currently causing the most trouble – and I am not going to even attempt to explain exactly why. Suffice it to say that there are already regulations in place which require you only to make claims that are ‘honest and truthful’ and which do not ‘denigrate any specific ingredient’ (such as parabens) for which there is extensive scientific proof that it is safe.
But these regulations have been expanded to cover wider ‘freefrom’ and other similar claims – but no one seems sure at this stage whether these are actually regulations or merely ‘guidance’ – nor is anyone really agreed on what they actually do or don’t say.
As a separate issue, it is not always clear that they actually do benefit the consumer which is, theoretically, their intention. Flagging up that there are ‘no preservatives’ in a product may raise technical issues. For example, a product will not need a preservative if it does not contain any water so you should not be labelling an oil based product as preservative free as should not contain any preservatives anyhow. And, since the scientific research says that there is nothing inherently unsafe about preservatives, then you could be seen as ‘denigrating’ preservatives by flagging up that there aren’t any in your product. But for someone who does react to some preservatives (and there are certainly people who do) a front of pack flag saying ‘no preservatives’ will save them fighting their way through the often illegibly small ingredients list on the pack – which they may well not understand anyhow as it is in Latin!
Which brings us to the next problem – the INCI (International Nomenclature of Cosmetic Ingredients) format. This requires that the names of the ‘botanicals’ (the ingredients derived from plants – which means the majority of the ingredients in any skincare product) have to be in their original Latin, while any chemicals used have to be in their full chemical format. As a result ingredients lists are ridiculously long and, because many of the containers are very small, they are printed in such tiny print that even those with 20/20 vision need a magnifying glass to read them. And even you manage to read them, the chances of you understanding them without a degree in classics, botany or chemistry are slim.
All of that said, there have been some excellent products entered and tested during the week by our panels of expert skincare judges – they had already been tested by our consumer panels. For full details see the Skincare Awards Facebook, Twitter and Insta pages and keep an eye on the FFSA site for preliminary results.
We were also amused to note in these Brexit-ing times, that out of the 13 judges who have graced our judging room this week we had only six Brits– joined by a Russian, an Iraqi, a Finn, a Bulgarian, an Iranian, an Italian, an Indian and a judge who hailed from Holland!
We would also like to log the presence of a fourteenth judge who oversaw proceedings without taking too active a part – beyond inspecting the judges, finding a comfortable chair with a towel ready for the judges’ use – and going to sleep.
And finally we would like to note that because judging skincare products is hard, brain-teasing work, we made sure that they were well fed. What Alex calls my ‘ploughed field lentils’ on day one (Puy lentils with lots of ginger and garlic, water chestnuts and spring onions)…..
Butter beans with red peppers, chilli, tomatoes and lots of herbs, on day two; rice ‘n peas – with more ginger, chillis, green beans and broccoli on day three, this slightly strange combination of buckwheat, quinoa and chickpea pasta with potatoes and Cavolo nero on Thursday….
and quinoa tabbouleh on Friday. All, obviously, gluten, milk products and soya free, and, on most days, nut free.
Plus LOTS of dates and delicious strawberries from Suffolk to keep them going in between. Oh to be a FreeFrom Skincare Awards judge!!