Skin lightening products display in a grocery store in Beijing, China.
Living in China is beginning to open my eyes to the different way that the Chinese seem to regard lotions, creams, lip balms, soaps and other similar cosmetic products as more than just cosmetics. I’ve worked with these products and ingredients for so long that I have to consciously remind myself that not everyone looks at these things the same way! When I was sharing my perspectives with Tina, she pointed out that even in the USA there are some ways that cosmetics are perceived to be more than cosmetics.
Thanks to clever marketing teams around the world, the line between cosmetics and drugs is a little (ok, very) hazy. This is very true for someone who hasn’t studied, worked with or made cosmetics. There are many examples of this in both China and the USA. I’ve compiled a list of examples from both countries to share how marketing and placement in stores has effected the perception of cosmetics.
Sunscreen and SPF:
I’m going to use this as a brief example because I don’t want to reiterate previous blog posts and bore you! Any lotions, creams, gels or lip balms claiming an SPF and/or sunscreen properties are technically drugs. These must be tested by approved labs and follow FDA guidelines for the manufacture and sale of drugs. We often receive requests for help formulating products that work to give cosmetics a SPF. Since these are drugs and require LOTS of lab testing, we recommend to our customers that they work on making great cosmetic products for themselves and/or their customers. Then purchase the necessary SPF products from reputable companies that have done the testing to receive that SPF rating from an independent lab.
Skin Lightening Products:
Here in China, women want to have pale skin. It is very odd as a foreigner to be complimented for having a skin color that in the USA would be considered too pale and in need of a tan. The stores that are dedicated to women’s cosmetics often have full sections dedicated to products that are either claimed or implied to lighten skin color. These products may or may not actually lighten skin. I believe that in the USA, these products would firmly fall under the category of drugs if they are claimed to lighten skin color as that causes a skin alteration.
Belly Balms, Creams and Scar Reducing Treatments:
This seems to be an international desire to have scars and stretch marks fade away. This is actually a genetic issue that can’t be fixed by a topical product. People are either prone or not to stretch marks and more obvious scars. Stretch marks come from quick weight gain and changing skin. If a person is prone to stretch marks, then they can get them at any time if the body changes quickly. Sadly, cosmetics can’t fix these deep dermal scars. While it doesn’t mean these scars and stretch marks will go away, you can still apply that body cream and pamper your body because it deserves it!
There are people all around the world that only want to buy lotions, creams, lip balms, soaps and other similar cosmetic products if these products can “heal” or “cure”. As these words fall under drug claims, it can risky for any cosmetic maker to use these words. Instead, use words like “indulgent”, “invigorating”, “calming” or “pampering” as these words will keep you from making drug claims for your products and still encourage sales!
I hope this has been a bit of food for thought. What do you think? What words can you come up with that prevent you from making drug claims?
Great post! It’s very important that we keep in mind that marketing claims may help sell a product but can also lead to legal troubles here in the U.S. Not only can we be held liable for what we print on our products – but also for our verbal statements regarding benefits, claims and warranties.
Even “balm” & “salve” falls into the drug category — I’ve noticed many of us have switched to “lip butter” and “herbal butter” and “belly butter” for that reason. BTW… from my own experience, I found that using a belly balm during pregnancy does help reduce stretch marks. But I agree, it doesn’t help much after the stretch marks have already formed.
My understanding of SPF is that, as you said, you can’t claim “SPF 15” (or whatever) unless it is certified by a company licensed to do the certification. However, if you add TD or ZO or a combo to a product for colorant, you can say “contains sunscreen”.
Balm and salve do fall into the OTC category due to claims of healing and expected meaning from these words.
As far as sunscreen goes, this is just one that is best avoided in making any claim.
The cultural differences in the definition of “beauty” are really interesting–thank you for sharing your adventures in China with us!
Is there a separation there between what is a “cosmetic” and what is a “drug”?
And–are different or special formulas required there to combat the air quality issues?
thanks!
In the USA, the difference between a cosmetic and a drug is if the product is been claimed to protect, heal, repair or fix our skin or bodies, then it is a drug. If it makes no claims and is for use on the body, then it is a cosmetic.
For example:
Sunscreen lotion is claimed to help protect the body from the UVA & UVB when outdoors. This makes it a drug and an Over The Counter drug (OTC).
Lotion (regular) is applied to the skin as an indulgence and pamper the senses for scent, texture, or feel-good emotions. This product doesn’t claim that it will protect, heal, repair or fix. Therefore, it is a cosmetic.
Does this help?
As far as combating the air quality issues, there aren’t cosmetics that help. I use a face mask when out in public and have an air filter like the IQ Air Health Pro Plus in my apartment to help deal with the pollution. I’m still coughing due to the bad pollution. Right now, the best ways to combat it are to have an air purifier and reduce expose outside.
It does help, sort of–what I’m wondering, though, is whether that difference applies in China?
I understand the U.S. regulations are to “protect” the consumer–I’m wondering whether China has similar consumer protection rules in place?
Have you noticed any “air quality impact” on your skin–do you need more moisturizer, or different cleansers?
At this time, no, China does not have such regulations to protect the consumer. Since there are not such regulations, claims like “healing”, “natural”, “organic”, and “cure” are on many products we would consider cosmetics. The preference of the Chinese people is to use traditional medicine for health rather than Westernized medicine, so the cosmetics market reflects that. There are shampoos on the market that use Black Sesame Seed Powder because it is believed to help keep the hair black. There are lotions that are made with pearl powder because it is believed to keep women’s skin young and healthy looking. Companies make these claims and yet these claims would categorize these very products as drugs in the USA.
The Chinese people are hesitant to believe manufacturers here and it leads to a big mistrust of things “Made in China.” Not everything made here is bad, but the companies that cut corners have hurt the people. The way things are sold try to prove to the consumers that the product isn’t bad.
Eggs come directly from the farms in crates and you pick your own eggs at the food markets (think daily farmer’s market in the USA). These eggs haven’t been cleaned and scrubbed like the eggs you could buy at any supermarket in the USA as the Chinese don’t trust eggs that look too clean. That comes down to a problem that was about 7-10 years ago of fake eggs being made and sold at markets.
The baby formula that was tainted due to the milk scandals of 2008, has had new parents either deciding to breast feed or have baby formula brought in from countries that have stricter testing of formula. (USA, Australia, and France) There is still quite the black market for baby formula from these countries and almost every person visiting friends or family in China brings formula if a baby is expected in the near future.
As far as the air quality impact, I’ve noticed it has impacted my lungs most. 🙁 It has also impacted my hair, but I haven’t noticed as far as my skin. We have hard water here in Beijing and it has definitely affected my hair care routine. I can’t get my normal hair care products here and I have naturally oily hair, which is hard to deal with when the local population has a problem with very dry hair! I’ve learned to skip using a conditioner and use a vinegar or other acidic hair rinse (a citic acid solution has also been a good alternative) to help my hair not look greasy. I use the same amount of moisturizers that I used back in the USA and I haven’t noticed a major difference to my skin.
I hope this helps more!