ingredient labels

Not All Labels Are Equal

Do you know what you’re putting on your body?

This is the second post in a series on understanding ingredients in body care products in Australia.  You can read the first part here.

If you’re anything like me, you carefully read the ingredients of a new product before you buy it. You want to make sure it wont irritate your sensitive skin, or be harmful in other ways.  And how do you decide which products contain undesirable ingredients and which don’t?

Some people say the fewer ingredients the better. Others won’t buy products without ingredient names they can clearly recognise.  And in Australia we are lucky to have regulatory oversight to keep consumers safe.  But is that the whole story?

When I moved to Australia, the childhood eczema I thought was gone forever, suddenly returned. I couldn’t understand why.  Living in the UK I’d carefully read labels and selected the ones that seemed least likely to irritate my skin.  This method was largely successful.  Following the same strategy here didn’t seem to be working. I couldn’t figure out why…

It turned out I was using a sunscreen that included an ingredient I already knew irritated my skin.  I just didn’t realise it – because it was not listed on the label!

Ingredient Labels and Regulation

In Australia the regulation in place to protect us also confuses things.

Cosmetic products and therapeutic products have different ingredient labelling standards.  Depending on how a product is regulated, the same ingredients may have different names, or not be included on the label at all.  It makes it hard to compare products and make an informed choice.

Several factors are taken into account when determining whether a product is considered cosmetic or therapeutic. These include:

  • the purpose of the product
  • the ingredients used in the product and their effects on the body
  • how the product is used
  • how the product is labeled and promoted

This difference between cosmetic and therapeutic goods means that products such as shampoos, deodorants and SPF15 lip balms are considered cosmetics, but medicated or anti-dandruff shampoos, anti-perspirants and SPF 30 lip balms are considered therapeutic – and labelled differently.


In Australia, cosmetics are used externally on the body (or in the mouth).  They change appearance, smell, clean, perfume, protect or otherwise keep your body in good condition.

The Australian Government’s National Industrial Chemicals Notification and Identification Scheme (NICNAS) regulates cosmetics.  NICNAS assesses all ingredients in cosmetics for risks to human or environmental health and ensures they are listed on the Australian Inventory of Chemical Substances (AICS).

The Australian Competition and Consumer Commission (ACCC) sets the standard for labelling cosmetic products and it is fairly straightforward.  Businesses need to list ALL ingredients on cosmetic labels in descending order of quantity.

Where it starts to become confusing is that they can use

  1. the common English name or
  2. the International Nomenclature of Cosmetic Ingredients (INCI) name or
  3. both the INCI and common name

Right there, the same ingredient can be represented in three different ways.


Therapeutic goods in Australia prevent, diagnose or treat diseases, or otherwise affect the structure or functions of the human body.

These include

  • prescribed medicines
  • over the counter medicines
  • vitamin supplements
  • primary sunscreens and products claiming to provide SPF over 15
  • cosmetic products that make therapeutic claims

The Therapeutic Goods Administration (TGA) is responsible for regulating therapeutic goods.  Products must be registered and approved as a medicine, or listed as a non-medical therapeutic product, on the Australian Register of Therapeutic Goods (ARTG).

They use the standard for labels of non-prescription medicines as set down in law.  This only requires ACTIVE ingredients and ingredients that ‘could cause irritation’ to be listed.  The label must use the approved name (AAN) from the Australian List of Approved Names for Therapeutic Substances.

Additionally therapeutic products are not required to list excipient ingredients.

Excipient Ingredients?  What are they?

What is an excipient ingredient? According to the Oxford Dictionary Online

“An inactive substance that serves as the vehicle or medium for a drug or other active substance”.

Excipient ingredients may have many uses in a formulation.  They may be a preservative, fragrance or solvent for example.  An excipient mix therefore, is a proprietary mix of such ingredients.

Only restricted excipient ingredients must be disclosed.  They are listed on the Theraputic Goods Register for the product, but not necessarily on the label.  There is no requirement to list any other ingredients at all.

That means body care products regulated by the TGA (for having therapeutic claims) do not need to list ingredients such as colourants, non-known-irritant preservatives and fillers on the label.

They also don’t need to list excipient ingredients used with active ingredients.  For example the chemical used to preserve the active ingredient before it was used in the formulation.

How To Tell If A Product is Cosmetic or Therapeutic?

You can tell a product is governed by TGA regulations because it has “AUST L or AUST R” printed on the product somewhere.

Listed products

  • use the code AUST L
  • are considered low risk
  • include over the counter medicines, vitamins, sunscreen and most complementary medicines.

While companies must be able to show the product works, is good quality and safe to use, the TGA conducts spot checks rather than review the evidence for every product.

Registered products

  • use the code AUST R
  • are considered high risk for use
  • are individually assessed by the TGA for quality/safety/evidence the product works.  This assessment is typically results of clinical trials. The TGA doesn’t actually test products themselves.

Better Transparency in the Future

New legislation came into effect in 2016 for TGA regulated products.  It requires additional ingredients to be on the label.  These include potential allergens such as nuts, soy, benzoates, sorbates and sulphites.  Businesses have until the end of August 2020 to bring their labeling up to the new standard.  However the label still does not need to list other excipient ingredients.

Until September 2020 some labels will comply with the old legislation, and some with the new.  You won’t necessarily be able to tell which is which.


Body care products in Australia are regulated and labeled differently, depending on whether they are considered cosmetic or therapeutic goods. While cosmetic products must list all their ingredients, the same is not true for therapeutic products.  Additionally cosmetic and therapeutic products use different naming standards for the same ingredients.  Therefore it can be difficult to compare products and understand exactly what ingredients they contain.

The next post in this series will be about ingredients names, greenwashing and how to find out what an ingredient actually is.  Follow us on Facebook or Instagram or join our email newsletter to make sure you don’t miss it.

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