About Us

A Centennial History of the Personal Care Products Council

Self-Regulatory Programs Established

As the Association entered the 1970s, consumer and environmental concerns captured the attention of legislators and the media.

CTFA found itself in a decade-long struggle to convince regulatory agencies and consumer groups that the industry's commitment to product safety and self-regulation precluded the need to introduce new legislation.

In 1970, President Nixon's Special Assistant for Consumer Affairs Virginia Knauer urged the cosmetic industry to support a voluntary reporting program. The call for such a program emerged at a time when ingredient labeling of finished products was not yet required and when both consumers and FDA voiced concern over the industry's lack of disclosure of ingredients, registration of manufacturers and reports of adverse reactions to products.

At a December 1970 meeting with CTFA, FDA staff stated that if the industry agreed to voluntarily provide this data, the agency would not seek to legislate such a program.

In 1971, the Association proposed this first-of-its-kind program. At that time, CTFA President Jim Merritt described the program as a "desirable and innovative example of industry cooperation with government to better consumer protection."

In light of the prevailing regulatory climate, CTFA's system of voluntary regulation was designed to demonstrate the industry's willingness to supply information to FDA and to discourage Congressional legislation.

Under the program, both member and nonmember companies voluntarily provide FDA with information concerning their operations. The program entails: (1) registration of manufacturing establishments; (2) submission of data on composition of finished products; and (3) annual filing of consumer product experiences, detailing the number of complaints received by participating companies.

Following closely on the heels of the Voluntary Reporting Program was the publication of the first edition of the Cosmetic Ingredient Dictionary in 1973. The Dictionary was the first authoritative source for commonly accepted names of cosmetic ingredients.

The Dictionary evolved out of an Association effort in 1970 to compile a list of chemicals used in cosmetics and toiletries. Working with representatives from FDA and the medical community, the CTFA Cosmetic Ingredient Nomenclature Committee researched existing nomenclature systems and developed comprehensive guidelines for consistency in name assignment.

The first edition of the Dictionary contained a listing of 5,000 trade and chemical names together with their CTFA adopted names, definitions, structures, Chemical Abstract Service Registry (CAS) Numbers and other information.

The work leading up to the first edition of the Cosmetic Ingredient Dictionary greatly facilitated the industry's compliance with ingredient labeling standards adopted by FDA under the Fair Packaging and Labeling Act in 1975.

FDA soon recognized the Cosmetic Ingredient Dictionary as the source for proper nomenclature for cosmetic ingredient labeling. Each successive edition of the Dictionary reflected the increasingly high demand for more sophisticated information.

In 1994, the fifth edition contained more than 6,000 chemical names and was called the International Cosmetic Ingredient Dictionary. The Dictionary is recognized and sold all over the world, providing uniform names required for ingredient labeling in the United States, the European Union and many other countries.

The Eagleton Bill

In 1973, Missouri Senator Thomas F. Eagleton introduced a landmark bill that proposed sweeping changes to the federal oversight of the cosmetics industry. Eagleton's bill became the focus of CTFA activity for the next four years.

Specifically, the bill mandated: (1) pre-market clearance of cosmetics by FDA and the establishment of specific tests that the industry would be required to perform prior to marketing a product; (2) deletion of both the soap and hair dye exemptions of the 1938 Food, Drug, and Cosmetic Act; (3) mandatory registration of cosmetic products; (4) detailed ingredient labeling requirements; (5) compiling and maintaining consumer complaints; and (6) expanding FDA access to company records.

CTFA strongly opposed this attempt to remove the self-regulatory status of the cosmetic industry.

During hearings held by Senator Edward Kennedy of the Subcommittee on Health, CTFA Chairman Dick Edmondson testified that the bill would cause "a serious misallocation of the nation's scientific resources and disrupt congressionally established priorities for protecting public health—with unusually severe impact on small manufacturers."

The convergence of the Eagleton legislation with the FDA's petition to require cosmetic labeling under the Fair Packaging and Labeling Act presented a dilemma for CTFA.

Not wanting to appear to oppose both the consumer's right to know with regard to ingredient labeling and the perceived pro-consumer provisions of the Eagleton bill, CTFA decided to work with FDA to develop a regulation on ingredient labeling upon which both sides could agree.

The regulation, issued in November 1975, included a provision requiring manufacturers to either substantiate the safety of their product or include a warning statement that the product's safety had not been determined.

Although the Eagleton bill ultimately passed the Senate in 1976, a House version of the bill was not considered.

The Origin of CIR

During the time of the Eagleton bill, the industry planned -another landmark self-regulatory program — the Cosmetic Ingredient Review (CIR).

CIR's origins can be traced to a proposed FDA program for the specification and toxicological examination of cosmetic ingredients. After reviewing it, the CTFA Scientific Advisory Committee drafted its proposal for a CTFA sponsored "Reasonably Expected As Safe" (REAS) ingredient evaluation program. The CTFA Board approved the concept in 1975, and the following year the program was named the Cosmetic Ingredient Review.

CIR was launched with the goal of bringing together worldwide published and unpublished data on the safety of cosmetic ingredients for review by an independent expert panel. Within five years of its founding, CIR reviewed 216 commonly used ingredients.

An elaborate set of procedures to govern CIR was developed to satisfy CTFA members, FDA and Congress. To achieve credibility, it was designed to be an open program.

The seven member Expert Panel consists of distinguished scientists from the disciplines of dermatology, pharmacology, chemistry and toxicology. The members are selected by a steering committee and publicly nominated by government agencies, industry and consumers.

CIR continues to be one of CTFA's success stories, winning praise from regulators as well as consumer groups for its efforts to ensure product safety. The industry recognizes that by participating in CIR and pooling safety information on cosmetic raw materials, it can minimize the enormous expense and inefficiency of duplicate safety testing.

CTFA's International Program

The emergence of a true global marketplace in the 1970s ushered in an entirely new area of concern for CTFA.

As early as 1974, CTFA participated in the launch of the International Information Center for Cosmetics, an international clearinghouse for the collection and exchange of information. This center gave industry the opportunity to access valuable information concerning regulations, technical and scientific documentation, advertising and regulation of competition.

In the 1980s, CTFA's involvement in international issues expanded significantly, with major initiatives undertaken in Europe, Japan and Latin America. CTFA's International Committee, formed in 1977, nearly tripled in size by 1982. In addition, CTFA formed an International Department in 1984.

In Europe, CTFA established close working ties with COLIPA, the federation of cosmetic trade associations within the European Economic Community (EEC). CTFA worked with them on ensuring that ingredients used or manufactured by U.S. companies were included on the EEC's list of substantiated products.

In 1980, CTFA formed two EEC task forces to assure that cosmetic sunscreen and preservative ingredients used in the United States also were permitted in the EEC.

In 1989, CTFA enhanced its ability to closely monitor events in Europe by working with its outside counsel, Covington & Burling, to establish an office in Brussels to keep members informed about industry concerns and to convey members' views.

The relationship with COLIPA allowed CTFA to work with the Europeans to develop a common position on new cosmetic regulations.

For the Japanese market, CTFA formed a task force in 1980, whose primary objective was to eliminate non-tariff trade barriers. These efforts included publishing a consolidated list of approximately 2,400 ingredients approved for use in Japan in 1984.

After four years of working closely with the Japanese Cosmetic Industry Association to open the Japanese market, CTFA achieved a significant milestone when President Ed Kavanaugh met with Prime Minister Nakasone in April 1985. During the meeting, the Japanese leader instructed an aide to direct Japan's Ministry of Health and Welfare to "loosen restrictions on cosmetics," which subsequently led to the elimination of individual product approval for many cosmetics.

The following year, CTFA co-sponsored the first International Conference on Cosmetic Regulation in Japan. CTFA's efforts in Japan were described as a model for other industries to follow.

In later years, CTFA's international efforts continued to press for opening new markets for members.

In May 1986, CTFA received an invitation from China's Ministry of Light Industry to visit Beijing and Shanghai to learn firsthand the opportunities and potential pitfalls of the Chinese market. A 25-person delegation completed a successful trip the following October. Other initiatives were launched in Korea and Hungary.

In the mid-1980s, CTFA also undertook an aggressive campaign directed at U.S. Customs and other law enforcement officials around the world to curb the import of counterfeit products. From these efforts, CTFA produced a "Product Identification Book" for customs agents and an anti-counterfeiting video highlighting how to spot counterfeit products.

In the early 1990s, CTFA's testimony in support of the North American Free Trade Agreement (NAFTA) pointed to the industry's successful initiatives to reduce market restrictions in Mexico.

The Animal Rights Movement

The animal testing issue first emerged as a major concern for the cosmetics industry in the late 1970s. Animal welfare and animal rights groups focused their criticism on the industry's use of the Draize eye irritancy test to substantiate the safety of ingredients and products.

Picketing of CTFA headquarters and CTFA member companies in 1979 thrust the issue to the forefront. In the summer of that year, CTFA prepared an official position paper on animal testing entitled "Animal Testing: What Are the Choices?"

As pressure continued to mount, the Executive Committee ordered CTFA's science committees to continue exploring the issue and directed the drafting of a detailed legal position.

In April 1980, CTFA's Pharmacology and Toxicology Committee established a task force that would review the Draize test, explore alternative testing procedures, and recommend research programs for the development and/or validation of alternative testing procedures.

In October 1980, CTFA sponsored a symposium on animal testing, bringing together both sides of the issue for an open exchange of opinions and ideas. At the meeting, CTFA stated that it was "ready, willing, and able to consider modification of procedures to address alternative procedures."

In 1981, the CTFA Board approved a program for the industry to fund a national center for the development of alternatives to animal testing. It awarded The Johns Hopkins School of Hygiene and Public Health a $1 million three-year grant. This initial grant was supplemented with an additional $700,000 in 1984 and continued funding in subsequent years.

In cooperation with the Battelle Memorial Institute, CTFA has conducted since 1988 an evaluation of the alternatives program. Although the industry was able to greatly reduce the number of animals used in safety testing, animal rights groups continued their offensive throughout the 1980s.

CTFA's Board decided to concentrate resources on defeating legislation that would ban animal testing at the state level, rather than conduct a general educational campaign.

Californiabecame a critical test ground for this issue and became the only state to actually pass legislation banning animal testing. In 1990, California Governor Deukmejian vetoed the legislation.

After this legislation again passed both the California Senate and General Assembly in 1991, CTFA orchestrated a state-wide editorial campaign in more than 50 California newspapers. CTFA also gained the support of former Surgeon General Dr. C. Everett Koop, who helped convince decision makers.

These efforts resulted in the veto of the legislation by California Governor Wilson.