Complete Story?

As moisturisers go, Olay Complete Defence does as good a job as any other. Like many moisturisers sold in Australia it contains a broad spectrum sunscreen giving it an SPF (Sun Protection Factor) of 30+. I wanted to know what else was in the product but unfortunately, a complete ingredient list was missing. There is a reason for this.

Australia, like most other countries, makes a distinction between a cosmetics and therapeutic goods. Cosmetics are applied to the skin and their chief function is to affect its appearance – they are not expected to affect the physiology of the person using them. Products shown to have physiological effects are classified as therapeutic goods (under the Federal Therapeutics Goods Act) and treated more rigorously as drugs.

Cosmetic product:
A substance or preparation which is intended for use on the surface of the body with a view to altering body odour, change its appearance, cleanse it, maintain it in good condition, perfume or protect it.
Therapeutic good:
A product that has an affect on body functions below the surface of the skin. These substances could also be referred to as drugs.

In Australia, manufacturers are required to list the ingredients for cosmetics (except for samplers and testers) on the product or packaging, whereas, therapeutic goods only need to state the ‘active ingredients’.

Australian law recognises sunscreens as active ingredients and their inclusion makes the moisturiser a therapeutic good rather than a cosmetic. Olay is therefore only required to list the active ingredients on the product or packaging, which they do. They have also listed the preservatives used, along with an appropriate warning, as they can irritate the eyes.

Active Ingredients:
Homosalate 8% w/w
Butyl Methoxydibenzoylmethane 3% w/w
Octocrylene 2.25% w/w
Phenylbenzimidazole Sulphonic Acid 2% w/w

Ethyl Hydroxybenzoate 0.2% w/w
Methyl Hydroxybenzoate 0.2% w/w
Propyl Hydroxybenzoate 0.2% w/w
Benzyl Alcohol 0.5% w/w

(Ingredient list from Olay Complete Defence package, 2013)

This has reduced the information provided to the consumer. Olay does include a full ingredients list on one of their websites but only for the American product, which differs in formulation from the one sold in Australia.

Olay makes two main claims for Complete Defence.

An SPF 30+ broad spectrum to help prevent sun damage to skin to stay younger and healthy looking. It may help reduce the risk of some skin cancers with daily use of the product.

Non-greasy formula with Vitamin E, Aloe, and Green Tea Extract replenishes moisture and absorbs quickly into the skin. Light enough to wear every day.

(Packaging extract, 2013)

The product also contains Vitamin E, Aloe and Green Tea extract, presumably for their reputed soothing, moisturising and anti-ageing properties. These ingredients are not active ingredients in the therapeutic goods sense. Their inclusion enables Olay to suggest that they provide moisturising and anti-ageing effects without directly attributing them with these properties.

The inclusion of these ingredients in Olay Complete Defence makes this product a ‘cosmeceutical’. The term is an invention of the cosmetics industry and includes products that could have effects normally associated with drugs but which tend to fall below the regulatory radar. Common cosmeceutical active ingredients include vitamins, essential oils, enzymes, and phytochemicals. Complete Defence contains a vitamin (Vitamin E) and two phytochemicals (Aloe and Green Tea).

Cosmeceuticals are not recognised as a category by regulatory authorities in Australia, the USA or the EU. If they were scientifically shown to have effects that go below the skin surface then, by law, they should be classified as therapeutic active ingredients and regulated as drugs. It is therefore unwise of a company to make specific physiological claims for them when they are included in a product.

In Australia Complete Defence is legally classified as a therapeutic good and the inclusion of a sunscreen means that Olay can claim anti-ageing properties for Complete Defence as the regulatory authorities accept that sunscreens help prevent sun damage and reduce photoageing. The claims inferred by Olay for the cosmeceutical active ingredients (Aloe, Vitamin E and Green Tea) piggy-back on these claims. The inferences are not included on the packaging, relying instead on the consumer to fill in the gaps or read about them on the company’s website.

Tocopheryl Acetate
Vitamin E is known for its antioxidant and moisturizing properties. It is also thought to diminish the effects of environmental pollutants.
Aloe Barbadensis
A tree-like form of the aloe vera plant used for its possible skin healing, refreshing and anti-irritant properties.
Camellia Sinensis (Green Tea)
Found in the leaves of green tea, it is a strong antioxidant that is often used in anti-aging formulas as well as a soothing toner.

(Information from the Olay website, 2013).

Olay is not alone in this practice and are doing what they can to inform their customers given the current regulations. It is just a pity they don’t include a full ingredient list.

Updated: 10th March 2017