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Sunless Tanning: What's Behind the Label

By Alex Schechter
Posted: April 28, 2008, from the August 2007 issue of Skin Inc. magazine.

Labeling is an important and essential component of any spa product. Listing everything from ingredients to directions to warnings, the label conveys a great deal, especially when it comes to products like sunless tanners. There’s so much information, in fact, that it’s easy to get lost. Once you can see the meaning behind the product’s label, however, you can figure out what the best fit is for your spa.

Basic industry terminology
Before delving into labeling and what it means specifically for sunless tanning products, it is important to cover basic industry terminology, keeping in mind that this article will only provide a brief overview, as the cosmetics industry regulations can be rather involved and complex.

     What’s the difference between cosmetics, drugs and cosmeceuticals? According to the U.S. Food and Drug Administration (FDA), the Food, Drug, and Cosmetic Act (FD&C Act) defines cosmetics as “articles intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body ... for cleansing, beautifying, promoting attractiveness, or altering the appearance.” Cosmetics include items that are typically thought of as makeup, perfumes and moisturizing creams.1
Conversely, drugs, as defined by the FDA, include products that “cure, treat, mitigate or prevent disease or that affect the structure or function of the human body.”1 So, a moisturizer that claims to eliminate wrinkles—a medical claim—would need to be treated as a drug.
To further clarify terminology, cosmeceuticals is not a term recognized by the FD&C Act, so these products may be classified as either cosmetic or drug, depending on the claims made by their manufacturers and their ingredients. While drugs are subject to a review and approval process by the FDA before to sale, cosmetics are not. Labeling requirements also are somewhat different for drugs and cosmetics. For example, drug labels are required to list active and inactive ingredients separately.
     Most sunless tanning products are designed only to enhance one’s appearance and therefore fall squarely into the cosmetics category. There are, however, ingredient-labeling rules and regulations that apply to any cosmetic product regardless of its classification.

     What are the labeling rules for cosmetic products? Labels for cosmetic products must contain the following information

  • the common name or function of the product
  • the net quantity of contents in terms of weight or measure
  • appropriate warnings
  • the company name and business address of the firm manufacturing or distributing the product  

     The label must also include the list of ingredients given in descending order from most to least prevalent. Ingredients with a concentration of 1% or less can be listed in any order.
     Often ingredients are given using the International Nomenclature for Cosmetic Ingredients, or INCI, name. The INCI system is a multinational set of terms for ingredients, using the Latin, scientific or English terminology. For example, calciferol is the INCI name for
vitamin D, and it is often seen on product labels that include the ingredient listed both ways so that consumers can easily understand what is in the product.

      Will sunless tanning products protect me from the sun? Because a sunless tan does not offer UV protection, the FDA requires that sunless tanning products sold without sunscreen include the following statement on the label: “Warning—This product does not contain a sunscreen and does not protect against sunburn. Repeated exposure of unprotected skin while tanning may increase the risk of skin aging, skin cancer and other harmful effects to the skin even if you do not burn.”2

Understanding ingredients
     Armed with a basic understanding of what a sunless tanning product’s label should convey, now it is time to look into what’s really going on behind those words.