Commentators often cite legislation such as REACH and the EU Cosmetics Directive to illustrate how the regulatory system over the pond is tighter and therefore provides consumers with better protection. Europe no better than US However, the chief scientist at the PCPC, John Bailey, Ph.D, told CosmeticsDesign.com that he strongly disagreed with this analysis. The trade association representative said that in some cases American regulations are stricter citing for illustration products that would be considered drugs in the US but are sold as cosmetics in Europe. Concerning the much publicized use of phthalates in cosmetics, Bailey said politicians in Europe had bowed to public pressure by banning them. He said the scientific evidence supports the decision not too remove them from cosmetics in the US as both the Cosmetics Ingredients Review (CIR) and Scientific Committee on Consumer Products (SCCP) have concluded that the current use of phthalates in personal care is safe. Criticism of US system Other industry insiders do not however share Bailey's confidence in the US regulatory system. YG Laboratories president and UC Berkley lecturer, Rebecca Gadberry told CosmeticsDesign.com that regulatory system in the US is out of date and ill suited to cope with modern consumer demands. Gadberry said the system is defined by the 1938 Food, Drug and Cosmetic Act which was not set up to accommodate the 'precautionary principle.' She said consumers demand that responsibility for health and safety should lie with manufacturers but greater investment in the FDA, more information sharing and an overhaul of the 1938 Act are required to effectively implement this principle.