[Insight & Opinion] Tasks Left for the MFDS Amid the "Dye Shampoo Controversy"

THB (1,2,4-Trihydroxybenzene), an additive used in the new concept dye shampoo Modamoda, is being added to the list of prohibited cosmetic ingredients by the Ministry of Food and Drug Safety (MFDS). The MFDS's stubbornness over the past two years is finally bearing fruit. However, this is not a situation to celebrate. The MFDS's belated action has already become a meaningless case of closing the stable door after the horse has bolted, as new products without THB are already being produced and distributed.

The MFDS has not directly confirmed the human toxicity of THB. The "potential genotoxicity" and "skin sensitization" emphasized by the MFDS are merely "possibilities" pointed out by the European Union (EU) since 2006. It is disappointing that the only so-called "scientific evidence" the MFDS can present is the possibility confirmed in a specific bacterium called Salmonella typhimurium. This is far too weak and insufficient to refute the criticism by KAIST President Kwang-Hyung Lee that "regulations cannot keep up with new technologies."

Not all countries follow the EU's decision. According to a recent report by the U.S. Cosmetic Ingredient Review (CIR) panel, there are currently 18 types of hair dyes and one type of dye shampoo containing THB legally produced and distributed in the United States. There are no regulations on THB in Canada and Japan either. THB is still listed in the International Cosmetic Ingredient Dictionary (ICID) with no restrictions on its concentration. THB is also not found on the International Agency for Research on Cancer (IARC) list of human carcinogens.

Of course, even if there is insufficient scientific evidence of risk, the MFDS can take "precautionary measures" for consumer safety. However, the situation changes if such measures lack sufficient persuasiveness. At the very least, minimal efforts should have been made to avoid accusations of unfairly pushing small venture companies that have painstakingly developed new products out of the market.

The MFDS's decision to leave the verification of THB to consumer groups was an irreversible mistake. The statement by the MFDS official last July that managing the risk assessment and verification of cosmetic ingredients "from the consumer perspective" is the fairest approach is an absurd sophism. The problem is also serious that experts, who could not utter a single rebuttal to the MFDS's ridiculous insistence that completely disregarded their professionalism and ethics, remained silent.

Risk verification of chemical substances is not something just anyone can do. It is a challenging task even for experts with high levels of expertise, knowledge, and experience. The Chemical Substances Control Act clearly states that such tasks should be entrusted to "experts, industry representatives, and public officials" with abundant knowledge and experience in related fields such as chemistry, environment, and health. Naturally, the risk assessment of THB should have followed these principles. What companies fear is not consumer "verification" but "reputation."

It is regrettable that the MFDS has forgotten the heavy responsibility of "verification." The claim that dye shampoos using polyphenols are not "new technology" was also absurd. The consumer groups that reluctantly took on the verification are not free from criticism either. Like the MFDS, they have degenerated into immature groups that cannot distinguish between what they should do and what they cannot do.

Now, the MFDS must begin new efforts to regain the trust of experts. There is little the MFDS can do for the public while ignoring expertise. We earnestly hope that the MFDS will quickly transform into a professional institution for the people.

Deok-Hwan Lee, Professor Emeritus at Sogang University, Chemistry and Science Communication

This content was produced with the assistance of AI translation services.