ATA 54th Annual Conference, San Antonio, Texas, November 6-9, 2013
Session ST-11 “Beautiful Translations: Foundations for the Personal Care and Cosmetics Industry” presented by Karen Tkaczyk on November 8, 2013
Reviewed by Mery Molenaar
Reviewed by Mery Molenaar
It is late Friday afternoon in San Antonio, Texas, and I am attending the ATA conference session on Beautiful Translations. This is probably one of the most difficult timeslots of the entire conference as people are about to wind down after two full days of networking and conference sessions. Nevertheless, the room is packed and Karen starts with full enthusiasm, determined to teach us a thing or two about the beauty and personal care industry.
Karen is a French to English translator and has previously worked in the pharmaceutical and cosmetics industry, so I am looking forward to spending an hour with an expert in the field.
Karen’s goal is to provide us with a basic understanding of the industry. After a short overview of today’s topics—regulatory framework, scientific and technical assessment, ingredients, and marketing—we jump right into the first topic of national and international regulations. Karen uses a nicely organized PowerPoint presentation and lets us know that she will be sending us the slides by email on request after the conference, so we can all sit back and listen.
The most influential markets for personal care products and cosmetics are the US and Canada, the EU, Japan, and Korea, and it is not surprising that there are regulatory differences from one country to another. Labeling requirements differ between regions, and certain hazardous ingredients and testing methods used in one region may not be allowed in another. Although people are working on alignment, there is currently very little harmonization. Areas where there is no harmonization include the listing of forbidden or restricted ingredients, animal testing and even the definition of a cosmetic product.
In the US, cosmetic products are defined by intended use: “articles intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body… for cleansing, beautifying, promoting attractiveness, or altering the appearance.” Karen points out that the definition does not include the word treat, and that cosmetics therefore are not considered drugs. When you buy a moisturizer you do not find the words treat or cure on the product, although marketing makes us believe that they do.
So what about fluoride toothpastes, antidandruff shampoos, and antiperspirant deodorants? Are these products cosmetics or are they drugs? Actually, they are both. While the cosmetics industry uses the word ‘cosmeceutical’ to refer to cosmetic products that are also drugs, the Food, Drug, and Cosmetics Act does not recognize this term. In the US, the FDA has published over-the-counter (OTC) monographs for these kinds of nonprescription drugs. Monographs are detailed product descriptions, including drug indications, dosing, contraindications, adverse reactions, etc., and as long as the active ingredients in cosmetics that also have medicinal benefits fall within one of the drug monographs, an FDA new drug application is not required. Karen stated that soap is a special regulatory case in the US, based on its specific chemical make-up, and pointed us to a reference for finding out more about that.
In the EU, the assessment of whether a product is a cosmetic product is made on a case-by-case assessment. Just this year, the EU Regulation replaced the Cosmetics Directive, but even with this new Regulation in place, rules vary for some countries, such as for the French pharmacy system. The EU definition of a cosmetic product is too long for a slide and Karen directs us to the handout she provided at the start of the session. This handout also lists a wealth of other useful resources and is included on the Proceedings & Handouts CD-ROM provided by ATA at the beginning of this year’s conference.
It is becoming clear to me that translators working for the cosmetics industry need to be well informed about international regulations and make sure they stay up-to-date.
We now move on to product testing. How well does a product stand up against contamination? Will a lipstick melt when left in a hot car? Animal testing is controversial and now banned in many countries, but what are the alternatives? Do your toiletries make it through TSA on your way to the conference? As some ingredients and techniques become controversial or are banned, the cosmetics industry is forced to constantly develop new techniques and alternatives.
Karen explains several mechanical and physical techniques used to test products. We learn that pumps are safer than jars as no germs are introduced to the content and that the term ‘air-free’ is often a misnomer. ‘Air-free’ in this context generally means that no air can get back into the product. An example of this would be a pump action bottle where the internal container volume shrinks as product is dispensed.
Next are ingredients. Again, we are dealing with differences between the United Statesand Europe. What makes this session especially interesting is the wealth of real-life examples Karen provides us with. Take sunscreen for example. In the US, active ingredients are defined in monographs by name and percentage (%) and are listed first on labels. In the EU, no such requirement exists. Karen emphasizes that when translating labels, you always need to take the target audience into account.
Another example is the use of parabens, a class of chemicals used as preservatives in cosmetics. About 10 years ago, parabens were a hot media topic and the use of parabens as a preservative to control bacteria, molds, and yeast became highly controversial. Unfortunately, it has proven to be very hard to find cheap alternatives and the industry has moved to reducing the need for preservatives by changing the way their products are packaged—using pumps instead of open jars, and adding solutes, such as glycols and salts, thereby reducing the amount of “free water” in the product, as water provides a medium for harmful bacteria, mold, and yeast to grow over time.
We end the session on the topic of marketing. Pointing out that translating marketing and advertising texts requires different writing skills, Karen recommends an article by fellow translator and marketing expert Agnes Meilhac on this topic. The article was published in The ATA Chronicle in April of 2010. A link to this article can be found on the session handout.
I am leaving this session impressed with Karen’s expertise and her commitment to the challenges of translating for the personal care and cosmetics business. The most profound takeaway for me is a point made by Karen that when you do this kind of work, you really need to know your chemistry and physics. Thank you, Karen, for a Friday afternoon well spent.
Mery Molenaar is an English to Dutch translator specializing in technical and scientific translations. She holds an undergraduate degree in mathematics and physics education and an MS in physics. Mery is originally from the Netherlands and currently lives in Longmont, Colorado. https://www.merymolenaar.com