Potency and Power: Estrogen, Cosmetics, and Labeling in Canadian Regulatory Practices, 1939–1953

Building on a rich body of feminist scholarship on estrogen, this account

interrogates how potent estrogenic cosmetics and consumer product labels

emerged together, through the regulatory practices of scientists and lawyers, in

mid-century Canada. Composed from archival and other primary sources, the

story traces the development of Canada’s first cosmetic regulations – which

applied only to cosmetic products containing estrogens. In 1944, “sex hormones”

had been the first substances for which the Department of National Health and

Welfare adopted labels in lieu of dose or potency standards under the Food and

Drugs Act. With dose-response thresholds thus written out of the Sex Hormone

Regulations, in 1949, regulators devised a new type of consumer product label

that warned women to use estrogenic cosmetic products “with care”. Further

regulatory amendments in 1950 appeared, on their face, to require positive proof

of safety for estrogenic cosmetics. However, through varied administrative and

enforcement practices that hinged upon “directions for use” in product labels,

National Health officials quietly reintroduced dose-response logics back into

estrogen regulation. As legal technologies for disciplining women consumers to

regulate their own exposures, product labels were becoming instrumental. With

labeling, estrogen catalyzed an early example of risk regulation in Canada.