What Is ActiWashing™?
ActiWashing™ — a trademarked term coined at By Valenti® — refers to the marketing practice of implying the presence of a specific, clinically relevant or trending bioactive ingredient in skincare, when the formulation either contains only trace amounts insufficient for efficacy or relies on a crude extract, oil, or derivative that does not deliver that molecule in standardized or functional concentrations.
The distinction is molecular.
In the case of bakuchiol, the bioactive compound is a purified, oil-soluble meroterpene isolated from the seeds of Psoralea corylifolia. Clinical studies demonstrating retinol-like benefits are based on the isolated compound, not on unstandardized seed oils or water extracts.
When a product contains:
- Raw babchi seed oil
- A water-based seed extract
- A non-standardized botanical fraction
— but is marketed as containing “bakuchiol” in the functional sense demonstrated in published studies, the claim becomes scientifically misleading, as the isolated molecule may be absent or present only in negligible, non-efficacious amounts.
The same applies to other active ingredients such as retinol, ascorbic acid, and ceramides, which may be included at trace levels sufficient to appear on an ingredient list, but not at concentrations capable of delivering measurable results.
When a formulation is diluted beyond the point at which any measurable molecules of the original substance remain, it cannot exert any pharmacological effect consistent with established principles of chemistry and biology. Any perceived benefit is therefore unlikely to be attributable to the active ingredient itself, but to the placebo effect of the companion or supporting ingredients. We call these "homeopathic level formulas."
Example of ActiWashing™ in Real Life
A widely discussed case in the skincare industry involved a product marketed as a bakuchiol-based alternative to retinol. The Bakuchiol Retinol Alternative Serum from HERBIVORE Botanicals was presented as containing bakuchiol as a key active ingredient on the front of the label and everywhere on their website and marketing material, aligning its positioning with published research on the molecule’s efficacy. At least in principle.
However, publicly available independent third-party testing commissioned by Sytheon, the manufacturers of the real and original bakuchiol isolate released in 2020, reported that the product contained bakuchiol at trace levels — approximately 2.27 ppm (0.000227%) — significantly below the concentrations typically associated with its documented performance which range from 0.5% to 2%. For comparison, By Valenti Bakuchiol Smoothing Serum and Bakuchiol Night Repair Cream contain 1% bakuchiol each from Sytheon, the original manufacturers of this revolutionary ingredient.
The same analysis noted that bakuchiol, being a lipophilic compound with a characteristic yellow hue, is difficult to incorporate at meaningful levels into a fully water-based, visually clear or purple formulation without the use of substantial solubilization systems (emulsifiers which are compounds that bind water and oil molecules to create a milky solution, lotion or cream).
A review of the ingredient list further indicated that, rather than clearly identifying bakuchiol as a primary component, the formulation referenced Psoralea corylifolia seed extract, a botanical source that may contain variable and often minimal amounts of the compound depending on extraction and standardization, and high levels of contaminants, which we have banned at By Valenti.
The discrepancy between:
- the ingredient’s marketed role
- the reported concentration
- and the formulation’s physical characteristics
led to industry scrutiny, widespread criticism and consumer backlash at the time, (here, and here) with many questioning whether the product’s performance claims were supported by its composition. The company's explanation after and the fact many consumers reported the deletion of bad reviews on the company's website didn't help.
This case illustrates a core feature of ActiWashing™ in the beauty industry: the alignment of marketing language with a well-studied bioactive or active ingredient, without a corresponding alignment in formulation, concentration, or functional contribution. This boils down to ethical formulations, transparency and ingredient disclosure. We have being upfront since our founding that you the consumer has the right to know what we put in the products you use, but that is a position sadly many do not share nor practice.
It is important to note that ingredient presence alone does not guarantee efficacy. The performance of a bioactive/active ingredient depends on its concentration, stability, and integration within the formulation. When these factors are not consistent with how the ingredient is positioned, the result can create a misleading impression of equivalence.
ActiWashing™ does not depend on whether an ingredient is present, but on whether it is present in a way that justifies how it is being marketed.
Example of ActiWashing™ Through “Trace-Level Actives”
A more subtle form of ActiWashing™ occurs when a formulation does contain a recognized active ingredient, but only at levels insufficient to produce a meaningful effect.
In these cases, the ingredient is legitimately present and therefore appears on the ingredient list, yet its concentration falls below the threshold required to influence skin physiology or deliver measurable results.
This practice is sometimes informally referred to within formulation circles as the use of “marketing levels actives” — where an ingredient is included primarily to support a label claim for marketing purposes only rather than to contribute to product performance.
A common example involves well-known actives such as:
- niacinamide
- peptides
- ceramides
- ascorbic acid and its derivatives
- retinol and its derivatives
When used at sub-therapeutic or trace concentrations, these ingredients:
- do not follow established dose–response relationships
- are unlikely to replicate the effects observed in clinical studies
- may not remain stable or bioavailable within the formulation
Despite this, the presence of the ingredient allows the product to be marketed in alignment with its recognized benefits, creating an impression of efficacy that is not supported by its functional contribution.
Importantly, the baseline performance perceived by the user is often driven instead by the supporting also known as inactive ingredients:
- humectants (e.g., glycerin, aloe vera)
- emollients and occlusives
- film-forming agents
which improve skin feel and hydration independently of the featured active.
This results in a placebo effect formulation that:
- appears effective at a superficial level,
- aligns with current ingredient trends,
- but does not deliver the specific benefits associated with the highlighted bioactive.
In this form of ActiWashing™, the ingredient is present — but not present in a way that matters to the skin, but functions as a marketing anchor and for PR.
Why It Matters
Bioactive performance depends on:
- Molecular identity
- Standardization
- Concentration
- Stability within the formulation
The inclusion of an active ingredient at negligible levels, or the substitution of a purified compound with a crude botanical extract containing only trace amounts of the relevant molecule, is not functionally equivalent to a quantified ingredient used at clinically supported concentrations. Such practices disrupt dose–response relationships and create a misleading perception of efficacy. In many cases, perceived improvements are attributable not to the featured active, but to the baseline moisturizing or emollient components of the formulation. This approach allows products to align with ingredient trends while avoiding the cost and formulation constraints associated with using bioactives at effective levels.
This issue extends beyond bakuchiol. It applies to:
- Peptides replaced with protein hydrolysates
- Ceramides replaced with plant oils claimed to be “ceramide-like”
- Resveratrol replaced with grape extracts lacking standardized content
In each case, the molecule studied in vitro or in clinical trials is not equivalent to the substitute ingredient used.
A Matter of Ethics, Transparency & Legality
ActiWashing™ is not a critique of botanical ingredients themselves. Botanical extracts can be valuable when properly characterized and standardized. The issue arises when marketing implies equivalence to a defined bioactive compound that has not been used in the formulation in a meaningful way.
From a formulation standpoint, clarity requires:
- Accurate INCI identification
- Disclosure of standardized content where relevant
- Avoidance of implied molecular equivalence without analytical confirmation
As cosmetic science advances, molecular specificity becomes increasingly important. Consumers are entitled to understand the difference between a plant and its active compound.
1. FDA Authority – Misbranding Under the FD&C Act
Under the Federal Food, Drug, and Cosmetic Act (FD&C Act) (21 U.S.C. § 362), a cosmetic is considered misbranded if its labeling is false or misleading in any particular.
If a product:
- States or implies the presence of a specific bioactive (e.g., bakuchiol, ascorbic acid),
- Does not contain that molecule in meaningful quantity, or
- Uses a crude extract that is not compositionally equivalent,
the product may be deemed misbranded.
Under 21 U.S.C. § 321(n), labeling may also be misleading by omission. Failure to disclose material facts necessary to prevent a claim from being misleading can render a product misbranded. This includes situations where the overall presentation implies the presence of a defined compound that is not present in meaningful or standardized amounts.
The FDA does not require pre-approval of cosmetics, but it can take enforcement action when labeling is misleading. The central question remains:
Would a reasonable consumer be misled about what the product contains?
For example, a product marketed as a “Bakuchiol Serum” that relies on Psoralea corylifolia extracts, which may not contain bakuchiol in standardized or clinically relevant concentrations, may constitute misleading labeling.
Under FDA interpretation, “labeling” is not limited to the physical label. It includes packaging, inserts, and materials that accompany the product. Ingredient-related claims presented in these contexts fall within FDA jurisdiction when determining whether a product is misleading.
FDA labeling requirements also rely on accurate ingredient identity through INCI nomenclature. When marketing implies the presence of a specific compound that is not reflected in the ingredient declaration, this creates a disconnect between composition and representation, contributing to a misleading presentation.
FDA evaluation is not limited to explicit statements. The overall context, presentation, and implied meaning of claims are considered in determining whether labeling is misleading.
FDA enforcement actions may include warning letters, product seizures, and injunctions where cosmetic labeling is found to be false or misleading.
In practice, ingredient-related claims often fall under both FDA and FTC oversight: the FDA evaluates whether labeling is misleading, while the FTC evaluates whether the advertising used to promote the product is deceptive.
2. FTC Authority – Deceptive Advertising
The Federal Trade Commission regulates advertising claims across all consumer products, including cosmetics.
Under Section 5 of the FTC Act (15 U.S.C. § 45(a)(1)):
“Unfair or deceptive acts or practices in or affecting commerce are hereby declared unlawful.”
Advertising must be:
- Truthful
- Not misleading
- Substantiated
If a product implies equivalence to clinically studied bakuchiol while using a non-standardized extract lacking that molecule, this may constitute:
- Misleading representation of ingredient identity
- Lack of substantiation
- Deceptive advertising
Under Section 5, advertising that is likely to mislead consumers about the presence or function of an ingredient may be considered deceptive, including when such claims are implied rather than explicitly stated.
Definition for publication:
ActiWashing™ — a term coined by By Valenti® — refers to the marketing practice of misrepresenting bioactive value in skincare, either by implying the presence of a defined active through a non-equivalent plant derivative, or by adding that active at negligible levels insufficient to deliver meaningful efficacy.
