Tell them not to lye (Minimum Labeling Requirements under the Consumer Act)

By Siesta-friendly

Organic and natural soaps are getting to be more and more common nowadays. Though not exactly a dime a dozen, unfortunately. But what do sellers mean exactly when they say their product is ‘organic’ or ‘natural’?

Lye (a.k.a. caustic soda or Sodium Hydroxide) is a necessary ingredient in soap-making. It would be rare, if not impossible, to find soap made nowadays without lye. Thus, at best, soap may only be ‘mostly organic’ or ‘mostly natural’ soap. But that doesn’t sound catchy does it?

Did you know that papaya does not really whiten your skin? Papaya enzymes exfoliate the skin (i.e, remove dead skin cells). Using loofah or pumice stone produce the same result. But saying papaya removes dead skin is apparently not as enticing as saying it is a skin whitener.

It is really up to the consumer to know better or at least step up their inquisitive (or investigative) powers to find out the truth in sellers’ advertising claims.

But let us tell you what product advertising regulated by and pursuant to law should be. The law being the Consumer Act of the Philippines.[1]

False, Deceptive or Misleading Advertisement[2]

Don’t you just hate it when the burger on the poster is twice the size of what you actually get? Or the dish is positively scrumptious on the menu but absolutely bland once you see it?

Under the Consumer Act, it is unlawful for any one to disseminate or to cause the dissemination of any false, deceptive or misleading advertisement by mail, print, radio, television, outdoor advertisement or other medium for the purpose of inducing or which is likely to induce directly or indirectly the purchase of consumer products or services.

An advertisement is false, deceptive or misleading if it is not in conformity with the Consumer Act or if it is misleading in a material respect. In determining whether any advertisement is false, deceptive or misleading, the following are taken into account, among other things,

1) the representations made or any combination thereof,

2) the extent to which the advertisement fails to reveal material facts in the light of representations, or materials with respect to consequences which may result from the use or application of consumer products or services to which the advertisement relates under the conditions prescribed in the advertisement, or under such conditions as are customary or usual. (Just so you know, we find this phrase convoluted as well.)

Minimum Labeling Requirements[3]

All consumer products domestically sold whether manufactured locally or imported are required to indicate the following in their packaging:

b) its correct and registered trade name or brand name;

c) its duly registered trademark;

d) its duly registered business name;

e) the Philippine address of the manufacturer, importer, repacker;

f) its general make or active ingredients;

g) the net quality of contents, in terms of weight, measure or numerical count rounded of to at least the nearest tenths in the metric system;

h) country of manufacture, if imported; and

i) if a consumer product is manufactured, refilled or repacked under license from a principal, the label shall so state the fact.

In addition, the following may be required when necessary:

a) whether it is flammable or inflammable;

b) directions for use, if necessary;

c) warning of toxicity;

d) wattage, voltage or amperes; or

e) process of manufacture used.

Any word, statement or other information required by or under authority of the preceding paragraph shall appear on the label with such conspicuousness as compared with other words, statements, designs or devices therein, and in such terms as to render it likely to be read and understood by the ordinary individual under customary conditions of purchase or use. The above requirements shall form an integral part of the label without danger of being erased or detached under ordinary handling of the product.

The Consumer Act is replete with more detailed advertising requirements for food, drugs, cosmetics, devices, and hazardous substances. Best to check which ones are applicable for a particular type of product as regards their pricing, branding, packaging, promotion, sales, etc.

Back to soap: ingredients to avoid

Now, before we go, and in keeping with the ‘truth in advertising’ theme, let us give you a little more truth about soaps (and shampoos, detergents, lotions, and the like). Although, at very small quantities, they may be safe, remember that the following common commercial cleaning ingredients have been reported as toxicants or irritants and may therefore cause serious damage (if not cancer) due to prolonged or excessive use:

1. Sodium Lauryl Sulfate (SLS) - irritant
2. Sodium Laureth Sulfate (SLES) – toxicant/carcinogenic
3. Cocamide DEA or Cocamide Diethanolamine (CDEA) – toxicant/carcinogenic
4. DMDM Hydantoin - irritant
5. Sodium Sulfite - toxicant/carcinogenic
6. Carboxymethylcellulose (cellulose gum) - toxicant/carcinogenic
7. Sodium Carbonate – toxicant and irritant

Check the ingredients of your bathroom products. You may be surprised at what you’ve been consuming on a daily basis. Perhaps you’ll find that having a ‘mostly organic’ or ‘mostly natural’ soap is the best you can have even if the makers do lye.

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[1] R.A. 7394, April 13, 1992.

[2] Art. 110, supra.

[3] Art. 7, supra.

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