Although a few years ago it would have seemed strange to even discuss tea as a cosmetic, it is now increasingly common to see lotions, moisturizers, and shower products containing tea, usually green tea. One need only go to their local pharmacy or specialty store to find a wide variety of tea cosmetics. Tea is of course only one of many ingredients, but the name of the product often includes the word ¡°tea.¡± The most recent example is from the well-known manufacturer, Origins, who now markets a line of white tea products including lotions. Although the ancient uses of tea do include applying it to the skin for certain health conditions, the science of these claims is much newer and much more tenuous.
The statutory requirements for cosmetics are more lenient that food or dietary supplements. The label must still not be misleading, but there is not the same risk of adulteration or misbranding. The definition of
adulterated cosmetics does not include non-GRAS additives whereas adulterated food does, and a cosmetic can make puffery claims about its effectiveness without substantiating them. However, cosmetics may not make ¡°therapeutic claims that they may affect the structure or function of the body¡± or they will be considered drugs. Tea used as a cosmetic may sometimes cross the line between cosmetic and drug, especially because the manufacturer may only be adding tea to the product in order to make some kind of health claim. If the manufacturer just claims that the tea gives you ¡°radiant skin,¡± then they are likely in compliance with the FDCA. |
