Yes - total ignorance.
California ignorant political correctness will surely compromise product quality and consumer safety as all convert to eye of newt/toe of frog preservation. Industry got in bed with MoCRA to prevent but has to live with established ignorance. Good luck to consumers."Notwithstanding subsection (a), nothingin this section shall be construed to prevent any State from prohibiting the use or limiting the amount of an ingredient in a cosmeticproduct, or from continuing in effect a requirement of any Statethat is in effect at the time of enactment of the Modernizationof Cosmetics Regulation Act of 2022....
Phil Geis
-----Original Message-----
From: Rick Jakober <[log in to unmask]>
To: [log in to unmask]
Sent: Thu, Apr 6, 2023 3:07 pm
Subject: Re: [PMFLIST] Preservatives - California Toxic-free Cosmetics Act
Short-sighted and un-scientific at best and potentially major microbiological infection and health issues at worst. It will keep us microbiologists in business for years to come.
Rick Jakober
VP Laboratory Services
Perritt Laboratories, Inc.
-----Original Message-----
From: The Pharmaceutical Microbiology Forum Email List <[log in to unmask]> On Behalf Of Donald English
Sent: Thursday, April 6, 2023 2:33 PM
To: [log in to unmask]
Subject: [PMFLIST] Preservatives - California Toxic-free Cosmetics Act
Dear all,
In 2020, California passed and signed into law the Toxic-free Cosmetic Act (Assembly Bill 2762). This law established that beginning on January 1, 2025 that no person or entity shall manufacture, sell, deliver, hold or offer for sale, in commerce any cosmetic product that contains 12 intentionally added ingredients. The following preservatives were included in this prohibited list of 12 ingredients:
Quaternium-15, Isobutylparaben, and Isopropylparaben. After January 1, 2025, these 3 preservatives can no longer be used to preserve cosmetic product formulations in all probably will result in them not being used as preservatives in all of the United States.
Now there is a California Assembly Bill 496 which is an update to the list of prohibited chemicals in which 26 more ingredients are proposed to be added. 2-Chloroacetamide is a preservative on EU Annex VI - List of Preservatives Which Cosmetic Products May Contain and is now listed as one of the 26 added ingredients to this list. No date has been proposed so far in which this newly added preservative can no longer be used in cosmetic product formulations.
The tool box of allowed traditional preservatives in product formulations is getting smaller. Cosmetic industry needs to do a better job in defending the usage of all currently used traditionally preservatives. Because traditional preservatives are not being defended, do not be surprised that multifunctional ingredients that have antimicrobial activity and are being used to preserve product formulations will eventually appear on a prohibited ingredient list in the future.
Don
Donald J. English Microbiological Quality Consulting LLC Florham Park, New Jersey 07932
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