Pregnancy, Birth and Beyond

Baby products: It is all in the labelling

As a passionate advocate of safe skincare for the neonate, the author’s published work on this subject has led to the promotion of a ‘minimal’ approach to skincare in the use of products described as cleansers or for skin nourishment.


The full reference for this 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.


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?

Where are we now?

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 .

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 ( ). 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.

What’s in a label?

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

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.

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:

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). [link no longer active] 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 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.


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.


"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 ( ). 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".