656 R. J. L. Allen Codex Alimentarius Commission under the joint sponsorship of the World Health Organisation and the Food & Agriculture Organisation of the United Nations. The aim was the removal of non-tariff trade barriers by harmonisation of food standards worldwide. Fifteen years later many 'recommended international standards' have been elaborated, but I cannot say that the results in terms of freeing international trade have been commensurate with the time, money and effort expended. On the whole, I would advise the international cosmetics industry to seek some other procedure, perhaps with a much stronger industrial orientation, to solve their problems. A word of warning from food industry experience relating to food additives may be timely. The Food & Drugs Act requires the technological need for an additive as well as its safety to be demonstrated. In addition, there is constant pressure to keep the per- mitted lists as short as possible and so restrict the actual number of colourings, for example, that are available for use. I hope that no one is going to try to apply these principles to positive lists of cosmetics ingredients, because I believe that this would not only discourage innovation but would in addition be inappropriate and perhaps harmful. Need should be left to market forces and, by spreading the total toxicological load, having more rather than fewer compounds could be advantageous in terms of safety rather than the reverse. The only aspect of quality I want to discuss is product stability in relation to label expiry dating. Regulations under the Medicines Act require an expiry date to be shown when the shelf life is less than 3 years. Voluntary marking with a 'sell by' or 'use by' date is now quite common with perishable foods, and a 'best before' date will become mandatory under the draft EEC Food Labelling Directive. The requirement under the Cosmetic Products Directive for an expiry date on products with a stability of less than three years is thus nothing new, and should not cause too much trouble so long as it is reasonably interpreted in the UK counterpart regulations. In the field of labelling mandatory declaration of ingredients of cosmetics is, I know, an issue that raises strong feelings. Ingredient declaration was violently opposed by the UK proprietary medicines industry in 1941 and by the UK food industry from 1945 onwards, but both industries have learned to live with it. With these precedents, and consumerist pressure, perhaps it will come here one day as it has in the US. I personally doubt whether it would prove any more disastrous for the cosmetics industry than it has for pharmaceuticals and food. I would myself trade mandatory compositional standards for ingredient labelling any day. As for advertising, I want only to mention that for 40 years the Proprietary Associ- ation of Great Britain has been vetting members' advertisements for proprietary medi- cines. The strength and reputation of this voluntary system has stood the industry in good stead and it looks as if it will gain official recognition by formal association with the regulations on advertising under the Medicines Act that are now being drafted. Thus the industry will retain a substantial measure of independence in this important matter. I am not necessarily advocating a system of this kind for operation by the Toilet Preparations Federation: I just draw attention to its success in a related sector of industry. My last problem is animal experimentation. Criticism of the use of animals in safety and efficacy studies has swung away from pharmaceuticals and towards allegedly non- essential items, including food additives and especially cosmetics, which we must admit has become an emotive word in this context. Whatever one's personal feelings are about the use of animals for any experimental purpose, I see no way in which a manufacturer

Cosmetics and the future 657 can fulfil his legal obligation to market safe products without some recourse to animal testing. I do, however, strongly advocate that alternative in vitro methods should be actively sought, that the industry should be seen to be interested in moving in this direc- tion and that Homo sapiens should be the test species wherever possible. Much, too, can be done by modified test procedures to minimise the discomfort felt by the test animals (9). There is pressure from Continental sources, for example in the draft Dangerous Substances Directive, to impose mandatory test protocols that would include the toxicologically questionable but bureaucratically popular LD50. This trend must be firmly resisted. I think that the industry will have to be ready, more than in the past, to justify its record in regard to animal experimentation to public opinion. In summary, I see an increasingly important role for the cosmetic scientist in the remaining quarter of this century, and no less for your Society as the guardian of scholarly standards and professional excellence within the industry. All the trends I have been talking about can only mean more scientific activity. Some of this activity--perhaps too much--will be unproductive and defensive. Demands for higher standards of safety and efficacy have already added a new dimension to the responsibilities of the scientist in the industry, and much creative work will be undertaken in dealing with the problems associated with these concepts. On the commercial side, I think that the industry as a whole has adapted successfully to externally imposed change. There are still a few dino- saurs around who are unwilling to admit that the Cretaceous epoch came to an end some time ago, but the recently strengthened Toilet Preparations Federation is doing a splendid job in spreading enlightenment. (Are there any other trade associations where 80•o of the senior staff are scientists ?) It is essential that the management of member companies should be, and remain, active and fully involved in the affairs of the Federation, and that they should allow--and indeed insist--that their scientists also contribute their skills. A strong trade association working with the wholehearted support of its members will continue to be a pre-requisite for survival. The dialogue that has been established with government at the national and Community levels will prosper only if the industry representatives have the right status, and the high levels of professional attainment, that will enable them to negotiate as equals. It is up to the industry to show self-confidence in its relations with government and with the consumer protection industry. Provided that we all respond adequately to the challenges of the time that I have touched on, and are ready to learn from the experience of other industries which have already passed through the fires of change, I am reasonably confident that although the cosmetics industry will certainly itself have undergone great changes, it will still in the year 2000 be recognisably the same kind of animal as we now know and, one would hope, still progressive, innovative, varied and profitable. REFERENCES 1 Council Directive of 27 July 1976 on the approximation of the laws of the Member States relating to cosmetic products (76/768/EEC). Off. J. Europ. Commun. 19 (L262) 169 (1976). 2 Williams L. P. Michael Faraday. (1965) (Chapman and Hall, London). 3 Orwell, G. Nineteen Eighty-Four. (1949) (Secker and Warburg, London). 4 Hook, E. B. and Healy, K. M. Consequences of a nationwide ban on spray adhesives alleged to be human teratogens and mutagens. Science, N. ¾. 191 566 (1976). 5 World Medical Assembly. Biomedical research: a revised code of ethics. WHO Chron. 30 360 (1976).