Aveeno Active Naturals Daily Moisturizing Lotion is the 17th best selling beauty product on Amazon.com. We looked at the label and found something that shocked us…
The last ingredient in the list is water. But lotions are typically mixtures of oil and water so how could they make a lotion with so little H2O? Could the answer have something to do with the fact that this is a drug product? (Note: skin lotions are considered to be “medicated” if they contain a certain level of skin protectant ingredients.)
According to the US Food and Drug Administration, for OTC drugs that are also cosmetics inactive ingredients “must be listed in descending order of predominance.” If J&J are following the letter of the law then there is less water in this product than there is salt. (Which is very hard to believe!)
Is J&J trying to mislead consumers?
So what is happening here? It looks like J&J has followed the WRONG regulation. Once again look at what the FDA says: ”For OTC drug products that are not also cosmetic products, the established name of each inactive ingredient must be listed in alphabetical order.” If you look at the inactive ingredient list you’ll see they are in alphbetical order. That’s why water is last! This would be fine if the product was a “true” drug and not a drug-cosmetic.
Why would they do this? It could be an honest mistake. Or, by interpreting the law to their own favor, J&J could be trying to make it look like their lotion is better than all those other “crappy” moisturizers that have water as the first ingredient.
As always: Let the buyer beware! And shame on J&J if they’re actually trying to mislead us!
Aveeno Active Naturals Daily Moisturizing Lotion ingredients
Active Ingredients:
Dimethicone 1.25% (Skin Protectant)
Inactive Ingredients:
Avena Sativa Kernel Flour (Oat)
Benzyl Alcohol
Cetyl Alcohol
Distearyldimonium Chloride
Glycerin
Isopropyl Palmitate
Petrolatum
Sodium Chloride
Water
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What classifies something as a drug or a cosmetic depends can depend just on what claims are made, not necessarilly the concentration of an ingredient. So it’s possibly to have an mosituriser with a lot more dimethicone thant the Aveeno product that will be still a cosmetic product.
Under the FDA Act a: ‘‘cosmetic’’ means (1) articles intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body or any part thereof for cleansing, beautifying, promoting attractiveness, or altering the appearance…” Thus a cleanser (anti-acne or anti-dandruff shampoo) will be a drug-cosmetic a moisturiser (or sunscreen) will only be a drug-cosmetic if it makes a claim about beautifying, promoting attractiveness, or changing the skin’s appearance.
So if the product is only making claims specific to what is permitted but the OTC Skin Protectant monograph and the product make no beauty claims then it is only a drug product, not a drug-cosmetic product. This is despite that with a different set of product claims it could be a cosmetic product.
@Alchemist: As always, thanks for the excellent comments. One of the featured claims of this product is that it “moisturizes for 24 hours.” I believe that’s a cosmetic claim, is it not? If it is, that would make this product a drug-cosmetic. Am I right?
Bearing in mind I’m interpreting this from the other side of the world and not involved on a day to day basis with US regs, I think this claim sits in a nowhere land. It’s not a claim in the OTC Monograph, but it’s not strictly out of the spirit of it. It’s also not a purely cosmetic claim as per the FDA Act definition of a cosmetic (it would be here (Aus), Europe and many other countries where moisturisers are defined to be cosmetics.
I’ve got a Skin Releif Moisturising Lotion (AUS/NZ/GB/IRL label) on my desk which has the claim “leaves your skin soft, smooth and naturally healthy looking”. If the US product, which I belive is OTC, has a similar claim to this then the product would be a drug-cosmetic. So under my interpretation would have and ingredient list in descending order (except for the active which is listed seperately).
Confusing? Yes.
i have aveeno’s skin relief 24hr moisturizing lotion 2 feet away from me and the first inactive ingredient listed is, in fact, water. maybe just a labeling/packaging mishap?
@Gemmerzz: They certainly could have changed the packaging. For reference I was using an ingredient list I found on Amazon.com so I suppose there could have been a transcription error. If that’s the case they should get it fixed!
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