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HSA Response: The Story of Cosmetics (Singapore context) Part 2

May 10, 2012

To ensure am barking on the right tree, and that when I bark, I have good enough reason to do so. I started emailing HSA (Singapore version of FDA), using an email template drafted by the Environmental Working Group, to champion the cause of safe cosmetics in Singapore.

My email to HSA, dated 8th May:

We would like to request for regulations on sunscreens being sold in Singapore. We need regulations that:

:: Do not leave families like mine out to burn — we want sunscreen’s SPF ratings to mean something.

:: Make sure the sunscreen industry doesn’t stock store shelves with bottles listing misleading, sky-high SPF ratings that protect against UVB-caused sunburn but leave skin at risk for UVA damage.

:: Keep misleading marketing claims off of labels.

:: Ensure that sunscreens actually protect consumers and does not contain even minute amount of Oxybenzone, Vitamin A (retinyl palmitate), insect repellent specially those that are sold as sprays, powders and claims to provide SPF above 50+

Response from HSA, was a bit lengthy, so I cut a portion that is relevant to my request above:

As part of these safety measures, HSA requires all cosmetic companies to:
Notify HSA of the products they intend to sell before making them available for sale.
Ensure that products sold are manufactured, prepared, packed, and stored under conditions which meet international standards.
Ensure that their products do not contain any prohibited substances which cause health risks, and that only permitted colorants, preservatives and UV filters are used.
Label their products clearly. The label must reflect key information such as the product name, ingredients, country of manufacturer and expiry date.
Appropriate actions will be taken against persons and companies who violate the legislation on cosmetic products.

You may wish to know that you are able to check whether your cosmetic products are notified at the following website:

here is another relevant response:

In general, product claims on sunscreen products should not imply the following:
100% protection against UVA and UVB
Reapplication of the product is unnecessary and that product can offer a whole day protection.

Some examples of the warnings recommended to be labelled on sunscreen products include:
Do not stay too long in the sun while using a sunscreen product;
Re-apply frequently to maintain protection, especially after sweating, swimming or towelling;
The use of sunscreens is one way to reduce the dangers from sun exposure;
Instruction for use to ensure that sufficient quantity is applied, e.g. pictogram, illustration, etc;
Over-exposure to the sun is a serious health threat

You may wish to provide us with the brand and product name of the sunscreen that has been found to be non-compliant to the regulations. Please also include clear pictures of the product packaging and the name and address of the company responsible for placing the products in the market in order to aid in our investigations.

We hope the above clarifies. You may contact myself or the Cosmetics Control Unit at 6866 3474 or 6866 3475 should you require further clarification.

Here is my response:

Thank you for your speedy and thoughtful response. In view of limited time, let me just be more specific.

Probably, I was not clear enough in specifying my requests. Here are 2 of the bullet points in my original email.

:: Keep misleading marketing claims off of labels.

:: Ensure that sunscreens actually protect consumers and does not contain even minute amount of Oxybenzone, Vitamin A (retinyl palmitate), insect repellent specially those that are sold as sprays, powders and claims to provide SPF above 50+

Recently, I purchased 3 tubes of Neutrogena Ultra Sheer Dry-Touch Sunblock SPf50++ (dermatologist tested). Since the label says it was dermatologist tested, I really thought it was relatively safe.
Notification No: CCPN0808258

I believe the label “dermatologist tested” is misleading, as being dermatologist tested does not mean anything, unless the governance set by dermatologists are not flawed. For example, why would dermatologists agree to include Oxybenzone and Vitamin A (retinyl palmitate).

My request is that HSA tighten regulations not only on newly launched products but also recall products that have already been released in the market which contains even “minute amounts: of Oxybenzone and Vitamin A, parituclary the product in question above.

This product contains unknown concentrations of Oxybenzone and Retinyl palmitate.

MAY CAUSE Developmental/reproductive toxicity, Endocrine disruption, Allergies/immunotoxicity, Persistence and bioaccumulation, Organ system toxicity (non-reproductive), Enhanced skin absorption, Biochemical or cellular level changes
Data source:

Cancer, Developmental/reproductive toxicity, Organ system toxicity (non-reproductive), Biochemical or cellular level changes, Use restrictions
Data source:

Please see the attached word document for my concerns and proposed changes, surrounding these 2 specific chemicals on sunscreens.

To see the bigger perspective, please view this video:

Here is my recommendations to ammend the Health Products Act (2007):

In its current state, this is what Section 5 of reflects

This particular product seemed to violate the fifth column, as the label does not explicitly say that “it contains Oxybenzone”. Can you follow-up with distributor on why is this so?
I am also requesting that this regulation be revised so as not to allow oxybenzone, whether it is 10% or 0.0009%, just completely ban this ingredient from any sunscreen being sold in Singapore.
The same goes for retinyl palmitate, please revise the regulation so that it explicitly bans retinyl palmitate

One Comment leave one →
  1. Cassie permalink
    May 10, 2012 7:23 pm

    Their answer for you seems very generic and not much though put into it. After your second email to them, I would like to see their response.

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