RECOVERED – My FDA complaint – Ava Anderson NonToxic

Originally Posted in 2012 – here is a link to the Blog Post I wrote about my FDA Complaint against Ava Anderson NonToxic:

The comments to this Blog Post are a big part of this article so instead of republishing it, I am posting a link.

I even had a comment Posted by Anonymous on August 13, 2013 at 12:04 am who claimed to be an “Executive” with Ava Anderson NonToxic!

UPDATE: The USDA investigation confirmed allegations “that AA (Ava Anderson) marketed its Essential Oil product as organic, in violation of the USDA organic regulations“.

I was also quoted in that article:

RECOVERED – “CHAMPION” hides perfume allergens!

Originally Published on: Mar 14, 2012 as Campaign for Safe Cosmetics “CHAMPION” hides perfume allergens!

The Campaign for Safe Cosmetics’ report “Market Shift” highlights the 322 cosmetics companies called “Champions” that meet their GOLD STANDARD goals of their Compact.

These goals include “Comply with the European Union’s Cosmetics Directive” and “Disclose all ingredients, including ingredients in “fragrance,”…”

The 7th Amendment to the Cosmetic Directive of the European Union (EU) stipulates that there are 26 contact allergens found in fragrances (natural and synthetic) that are mandated be listed on the ingredient declaration if they exceed 0.001% in leave-on products and 0.01% in rinse-off products.

The European Union List of 26 Fragrance Allergens Requiring Labeling on Cosmetic and Detergent Products, listed by INCI are as follows:

Alpha-isomethylionone Anise Alcohol Amyl Cinnamal Amylcinnamyl Alcohol Benzyl Alcohol Benzyl Benzoate Benzyl Cinnamate Benzyl Salicylate Butylphenyl Methylpropiona Cinnamyl Alcohol Citral Isoeugenol Citronellol Coumarin Eugenol Evernia Prunastri Extract Evernia Furfuracea Extract Farnesol Geraniol Hexyl Cinnamal Hydroxycitronellal Hydroxyisohexyl 3-Cyclohexene Carboxaldehyd Linalool Limonene Methyl 2-Octynoate

It is a common request to prove that your product does not contain any of the 26 allergens identified by the European cosmetics directive. I looked at favored Market Watch “Champion”, Ava Anderson Non Toxic, who just launched a product they call “essential oil” perfume.

First, this cosmetic does not list any of the ingredients according to INCI naming convention, which is a red flag that the ingredients are likely to be at least in part, Synthetic Fragrance.

After all, if they were actually essential oils, why would a company not list them as such?

We know there is no such thing as Amber musk essential oil.

We know there is no such thing as coconut essential oil.

[Edited to add examples…I could go on and on and on.]

So I looked some of the items listed as “ingredients” that “might” actually be essential oils.

EVERY ONE requires a “Fragrance Allergens” ingredient listing…yet this product does not list a SINGLE one.

Bergamot oil INCI name: Citrus aurantium bergamia (Bergamot) Fruit Oil Cosmetics Directive 7th Amendment: Restrictions may apply. A source of Citral, Limonene and Linalool, listed as sensitisers.

Grapefruit Oil INCI name: Citrus grandis (Grapefruit) Peel Oil Cosmetics Directive 7th Amendment: Restrictions may apply. A source of Citral, Limonene and Linalool, listed as sensitisers.

Lavender Oil INCI name: Lavandula angustifolia (Lavender) Flower Oil Cosmetics Directive 7th Amendment: Restrictions may apply. A source of Geraniol, Limonene and Linalool, listed as sensitisers.

Tangerine Oil INCI name: Citrus reticulata (Tangerine) Peel Oil Cosmetics Directive 7th Amendment: Restrictions may apply. A source of Limonene and Linalool, listed as sensitisers.

Jasmine Absolute INCI name: Jasminum officinale (Jasmine) Flower Leaf Extract Cosmetics Directive 7th Amendment: Restrictions may apply. A source of Benzyl alcohol, Eugenol, Geraniol, Benzyl Benzoate, Farnesol, Linalool listed as sensitisers.

Mandarin Oil INCI name: Citrus nobilis (Mandarin Orange) Peel Oil Cosmetics Directive 7th Amendment: Restrictions may apply. A source of Limonene and Linalool, listed as sensitisers.

Rose Absolute INCI name: Rosa centifolia Flower Extract Cosmetics Directive 7th Amendment: Restrictions may apply. A source of Citral, Eugenol, Geraniol, Citronellol, Farnesol, Limonene and Linalool, listed as sensitisers.

Is it really possible that the cumulative amount of essential oils and extracts in this perfume contain less than 0.001%? I guess it is possible. But considering the company is not legally providing consumers with the mandatory ingredient INCI names…it’s natural to assume they are hiding something – because labeling a product with ingredient names like “Amber Musk” and “White Cranberry” might as well just be labeled as “FRAGRANCE”…because the real chemicals in this product are just as secret.

RECOVERED – Why now?

I am in the process of recovering old articles I wrote about Ava Anderson Nontoxic [later rebranded as Pure Haven Essentials]. Why now? The answer is, freedom of speech.

I used to have a Greenwashing Blog where I would share articles about the companies I reported to the FDA or the USDA, articles exposing Greenwashing in cosmetic company claims (like labeling perfumes as 100% essential oils when they contained synthetic fragrances), marketing products as Organic when the products were in violation of the USDA National Organic Program laws, etc.

I’ve been asked why I deleted these articles and then removed the blog.

The answer is, I was threatened with a law suit by the management of Ava Anderson Nontoxic.

I received urgent contact by the Attorney for NYR Organic who said that my articles exposing the lies and fraud and misinformation being promoted by Ava Anderson Nontoxic, put me in violation of the rules for Members of the Direct Selling Association (DSA). As an Independent Consultant, I alone was responsible for the costs of fighting any law suit in court, the company would not defend me or support me because even though everything I was posting may have been completely true and my intent was to protect consumers from potential harm from believing these false claims, rules are rules. As a person who represented NYRO, I had the responsibility to follow the DSA rules. If I wanted to stay with NYR Organic, I had to remove my blog. I really believed I had a future with the company. I was only half joking when I told the Attorney “My Dream Job would be to move to Concord and work at the Home Office.” That was then, this is now.

Since that time, I have been very disappointed in the direction taken by the US Management. People I respected suddenly left the company. The one person who promised me that they would take my concerns seriously, including concerns about the misinformation about essential oils on our websites (the company still categorizes absolutes as essential oils and their aromatherapy training falls short in many key and basic areas), suddenly left the company prior to the last annual convention. No explanation. The emphasis in the past few months has been on multi-level-marketing and not on aromatherapy education, not on the “why” natural is better, and tips for how to hold a home party and recruiting seem to take center stage. Fellow NYR Organic consultants had been reaching out to me for answers to their questions about essential oil marketing, about safety issues, and about FDA regulations. MY efforts to engage with fellow consultants on the private, consultant-only Company managed Facebook group was disappointing to say the least. Questions I had about the company crossing the line from making cosmetic claims into medical claims were either deleted or never approved. Lively and informative discussions about issues related to the essential oil industry here in the USA were shut down – and the only topics encouraged were about sales figures, recruiting numbers, and consultant incentives for successfully multi-level-marketing.

I got one of those “perhaps we need to speak privately” messages from the new Vice President of Sales and Training. I looked her up on LinkedIN. I found a strong background in “home party” sales and marketing. Pampered Chef, handbags, and – OMG –  she is the former Vice President of Ava Anderson Nontoxic. I was shaking. When we talked, I was direct – “were you the one responsible for threatening me with a law suit, potentially financially ruining my family, when you were with Ava Anderson Nontoxic?” She admitted she was.

I have spent months trying to get past this fact, and I did give her the benefit of the doubt that she would actually care about essential oils and aromatherapy and learn what she did not seem to know about natural cosmetics. But the direction the company is taking is generic – they appear to me to only care about sales – not WHAT they are selling. The mission to me, seems to be the same as if they were selling purses or kitchen equipment or candles.  And that is not the foundation this company was built upon.  Neal’s Yard Remedies foundation was holistic health, natural skincare, herbal medicine, and in the UK they seem to still care about that – while in the USA they adopt pretend “standards” invented by fellow consultants with *connections*.

They jump on the October breast cancer bandwagon and donate a few pennies from the sale of certain products to a “charity” whose own mission is to WARN consumers about many of the very ingredients that are in Neal’s Yard Remedies products!  That lack of homework speaks volumes.

Our websites still list absolutes as essential oils, even though the new VP also promised this would be corrected.

The FDA warns about cosmetic companies making anti-aging claims, and my questions remain unanswered about how NYR Organic is legally able to make structure and function claims for a topical product (which the FDA considers to be medical claims) such as “it works to visibly lift, plump and recontour skin that’s starting to show the second signs of ageing.” (I suspect it is because they throw in words like *appears* and *feels* to attempt to make structural changes to the skin just cosmetic and not actually changing anything)

I have been told more times than I can count, “PERFECT IS THE ENEMY OF GOOD”.  I get it, I really do.  And if NYR Organic was “good enough”, I would still be a consultant.  But it simply isn’t.  Not any more.

So…now that I am not bound by the DSA rules for not disparaging member companies – I am recovering all my old Ava Anderson Nontoxic articles.  And THAT feels good.