Policy purpose and claim clarification
- BFAD issues guidance to clarify and guide concerned personnel and clients on the use of specific words and cosmetic claims.
- BFAD focuses the clarification on the evaluation of cosmetic labelling that uses “Exfoliate” and “Exfoliant.”
- BFAD provides the functional basis of the terms to guide whether a claim is acceptable for cosmetic products.
Meaning of exfoliants and intent
- “Exfoliants” are fundamentally described as astringents intended to encourage desquamation of the stratum corneum of the skin.
- Examples of ingredients cited as applicable to exfoliants include witch hazel, salicylic acid, and alpha hydroxy acids.
- Exfoliants are described as being prepared for oily skin.
- Exfoliants are described as being intended in place of astringents in cleansing regimens for acne-prone persons.
Acceptable cosmetic claims for exfoliating products
- BFAD declares the following claims acceptable for cosmetics labelling when substantive evidence is submitted and/or when the formulation itself supports the claim:
- “Exfoliants”
- “Exfoliate”
- “Remove or shed-off adeada skin surface cells”
- “Uncover anewa skin that looks cleaner, fresher and finer”
- “Accelerate the natural renewal of skin cells”
- “Aid in the treatment of acne by alleviating comedones”
- BFAD states that the acceptable claims above include those similar to these.
Evidence and formulation requirements
- BFAD requires submission of substantive evidence for acceptable claims under the circular.
- BFAD also accepts support through the cosmetic formulation itself.
- BFAD allows these acceptable claims to be evaluated favorably when the product formulation and evidence substantiate the claimed action, benefit, or advantage.
Evaluation of other words and phrases
- BFAD directs that words and phrases not included in the enumerated acceptable list will be evaluated based on technical evidence submitted.
- Technical evidence must substantiate the action, benefit, or advantage that the other words or phrases depict.
- The evaluation approach applies to alternative wording that is intended to communicate effects related to exfoliating.
Adoption and effect in guidance
- The circular is adopted on 24 Nov. 1999.
- BFAD adopts the clarified claim standards for purposes of evaluation of cosmetic labelling involving exfoliating terminology.