Goldfaden MD response

Last Saturday I posted this review about Goldfaden MD’s Sun Visor product. Understandably a lot of their customers that read the blog were concerned and I started receiving worried messages and comments immediately via my social media channels.

After two of my readers, Sarah and Jaquie, left comments with replies they had received from both Goldfaden and Space NK to their queries, I emailed the UK PR and reiterated my offer of letting Goldfaden use this platform to respond to my review, which I thought was only fair.

Below is Goldfaden’s response (complete with their own capital letters/punctuation) with my further comments below them.

From the blog:

‘Not only that, the titanium dioxide is nano-encapsulated, something which the California senate is so concerned about that Goldfaden MD have to have the proposition 65 warning on their website. The list includes ‘airborne titanium dioxide’ in ‘a list of chemicals known to the state to cause cancer or reproductive toxicity’.’

Nano-encapsulated titanium dioxide is a topic of much discussion in the SPF world, but what everyone pretty much agrees on is that inhaling it is probably not the best idea. And this is a spray.’

Goldfaden MD: 

This is to clarify that the product has NOTHING TO DO WITH NANO PARTICLES (NANO). Micronized is NOT the same as Nano. This is an entirely false accusation and wrongful claim. The Titanium Dioxide that we use is broken up in smaller particles (i.e. Micronized), which are much larger by definition than Nano particles. Nano is an entirely different process defined by size and production procedure, etc. The micronized Titanium Dioxide used in this product is bound to the formula’s ingredients, including water, and therefore is not harmful for its intended use. To summarize: THERE IS NO NANO ENCAPSULATION IN THIS PRODUCT WHICH IS WHAT CALIFORNIA STATE PROP 65 IS REFERRING TO AND ALL CLAIMS ELUDING TO “CANCER-CAUSING” PARTICLES. Out of respect to California state residents and to avoid any customer confusion, the link to the background and explanation of the proposition appears across the entire website.’

CH: 

Happy to clarify. My apologies. Goldfaden have added the term non-nano to their website here, which should comfort their customers that can simply google ‘titanium dioxide micronized’ and see for themselves that industry thinking is generally that the term micronized equates to ‘nano’.

Micronized TD is a particle of an average of 15nm and thus it is considered a nano-sized particle. No confirmation from Goldfaden on the size of their particles.

This is why a lot of ‘green’ brands specify ‘non-nano’ on their packaging. Perhaps something for Goldfaden to consider on their next repackaging to avoid any possible confusion in stores?

Note however, that Proposition 65 refers to ‘airborne titanium dioxide, unbound particles of respirable size’, it makes no mention of nano. And it’s not on the Goldfaden website ‘out of respect to California state residents’. It’s the law.

From the blog:

‘Do not use on or near the eyes.’ It’s a spray. Recommended for the face.’

Goldfaden MD:

The blog writer’s configuration is looking at this in a very different direction than what’s intended to beconveyed on the packaging. This is a simplistic warning label under the guidance of the FDA and safety control about keeping any consumer products away from getting directly in the eye (other than what is intended to go directly into the eye, i.e. drops). It’s not “harmful” to the skin around the eyes, but this is to encourage users to be cautious. Customers are encouraged to use common sense when applying any topical agent on the face.

CH:

Whether it’s clear on the packaging, or it’s ‘intended’, this is the message taken directly from Goldfaden’s YouTube channel. 36 seconds in – two spritzes to the face, two to the neck.

If they think that offers enough protection, so be it. That’s their opinion, it’s their brand and their product.

It’s personally not how I would advise applying SPF, or how much I would suggest using to be fully protected, but it’s only fair to show what they mean.

From the blog:
the box clearly states ‘silicone-free’ like a badge of honour – below:

but it contains two silicones – polydimethylsiloxane and dimethylsiloxane. These ingredients are chemical silicones, any which way you dress them up.’

Goldfaden MD:
These ingredients are sourced from natural sources (ie. apples, raw cabbage and pumpkins) and are used in the development and refining of the final product formulation. These are used in trace amounts and are inactive, however these are disclosed on the label by inci name.

CH:
I know they’re disclosed on the inci. I’m the one that pointed it out. The type of silicone isn’t the issue. I personally like silicones, as regular readers will attest to.
The point is that they’re silicones. Silicones don’t magically appear from fruit. It’s a chemical process.
Read for yourself.
Polydimethylsiloxane
Dimethylsiloxane
My concern was simply that they were in a product claiming to be ‘silicone-free’.
*Net-A-Porter emailed me first thing on Monday morning to say ‘thank you for bringing this erroneous silicone mention’ to their attention and that they have changed the copy on the product page accordingly. I have of course altered the original review to reflect this. Thank you for the kind words NAP.

From the blog:
‘this product contains oxybenzone at 1%, but is not labelled with a warning as required by EU law in products containing oxybenzone at a percentage higher than 0.5: ec.europa.eu/consumers/cosmetics’

Goldfaden MD:
According to the EU, safety data allows up to 10% usage in topical agents. Warning discloser just states the use if above. 5% and/or used as product protection purposes. Benzophenone-3 is the same as oxybenzone and is used as protection purposes. This adheres to the EU requirements as the “warning” label is simply stating that the product contains the ingredient and at what percentage, which LISTED IN THE ACTIVE INGREDIENTS LISTING and ADHERES TO THE EU regulations,
“When a product met this requirement, the warning: Contains oxybenzone was required to appear on the label. While oxybenzone is the drug name for the INCI designation benzophenone-3, a consumer in the EU might look at a product label, see this warning and scan through the ingredient listing only to find no oxybenzone listed there. Regulation No. 1223/2009 changes the phrasing of this warning to now read: Contains benzophenone-3, to match the way it appears in the ingredient disclosure and outlined in the active ingredient listing.”
Furthermore, EU document on compliant percentages:
http://ec.europa.eu/consumers/cosmetics/cosing/index.cfm?fuseaction=search.details&id=28809

CH:

Happy to correct the original review accordingly, the Goldfaden position is correct. There are two amendments at the bottom of my original EU link – if it’s benzephenone-3, used in this way, you don’t have to say ‘contains oxybenzone’. Details here from the EU amendment: Benzephenone-3

From the blog:
‘The packaging description says it contains zinc oxide, but zinc oxide is not listed in the ingredients list. So if it does contain zinc oxide, the ingredients list is misleading, aka unlawful, and if it doesn’t contain zinc oxide, then they are at best, misleading their customer.’

Goldfaden MD: 
Thank you for highlighting. This is a typo. We have addressed in reprinted packaging.

CH:
No explanation on whether the product used to contain zinc oxide and when it was removed, or how long it has claimed to include zinc oxide when it actually doesn’t. Goldfaden aren’t clear on whether or not I received out of date packaging or if the product is about to be repackaged.
Personally? Simply claiming it’s a ‘typo’ would not be good enough for me if I purchased this in good faith because I wanted a product that contained zinc oxide.

The Organic Red Tea mystery
An eagle-eyed reader called ‘prune’ left a comment on the original blog post asking where the red tea was on the inci list. I hadn’t even noticed that. I assume that will also be added on the new packaging, as it has now been added to the ingredients listing on the SpaceNK.com site.

To summarize?
Honestly? This has been the most unpleasant and unprofessional experience of my blog life by far. Suffice to say some people could have handled it a lot better considering that as a direct result of my original review:

From my perspective? This has been a reminder for me that it is not always easy putting your name out there and actually having an opinion.

I have never been, nor will I ever be, a ‘press release’ blogger. I ask questions. That makes some people uncomfortable. Some brands and PRs react brilliantly to that, others get defensive.

I will always say when I am wrong, correct it and apologise if necessary.

I will always be open to constructive criticism.

I teach my kids to OWN IT. FIX IT. MOVE ON.

For my part, I have owned it and fixed it. I am moving on.