That's not a "does." That's an "is." My point was that "is" does not matter for GRAS products, for anything other than ideological reasons; only "does" matters.
Unless you've got an allergy. Or any other reason to care what chemicals go into the products you consume.
Reasons which I'm sure you're able to completely and unambiguously enumerate for all people everywhere?
Either way your distinction between "does" and "is" is fundamentally incompatible with how the world works. It's a fiction. Things are what they do, and what they do is determined by what they are.
Furthermore, you're basically stating that the problem of changing the label is (for no good reason) significantly more important to avoid than the problem of degrading the trust across your whole customer base and handling every possible ethical conundrum that could result from this confusion. And that's just plain stupidity.
If something contains any chemical that anyone can be allergic (or sensitive, or etc.) to, the FDA gets involved and issues labelling mandates. The FDA is still sort of "distantly" monitoring the non-food, non-drug product category, to make sure products don't use any chemicals that would require them to become classified as food or drugs.
Which, if you think about it, means that everything that isn't FDA-controlled is still FDA-controlled (in a vague, gets-in-trouble-after-the-fact sense) such that it won't have anything in it that would causes trouble, health-wise, for some random subset of people; anything, in other words, that would be useful to know the existence of on an ingredients label.
Think about this carefully: products that aren't FDA-regulated don't require ingredients labels. Most of those products don't have ingredients labels. (No, seriously, go look if you don't believe me! You want to know what's in your shampoo? Too bad! You think you get to at least know what the "medicinal ingredient" is in your toothpaste? Nah, they could say whatever they wanted there, that bit is just advertising!)
Thus, if someone is sensitive to some substance, and the product has that substance, it's not required to disclose that fact at all. It can, in fact, be completely silent about it, and about everything else it contains.
The world you're imagining, where people get in trouble because they have no idea what's in cosmetics that can hurt them? It's already the world we live in, and yet people aren't being rushed to hospital left and right. People are, in fact, not getting in much trouble due to cosmetics at all. Because—once you have a blacklist of chemicals people could possibly be sensitive to, and require that non-food-non-drug products don't use those chemicals—it turns out that they can get away with just throwing in whatever else, and everyone is fine.
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P.S. I am getting the sense, here, that I'm being pursued for taking the "practical discussion on how to cope with making a sacred tradeoff" stance that seems to always get people in trouble. You know, the stance where you e.g. tell people how to better avoid sexual predators, and then get yelled at because "people shouldn't have to avoid sexual predators, we should get rid of sexual predators." There always seems to be a contextual chasm, there, between the person with that stance assuming that the point of the discussion is "how do we best cope with the world we live in", and everyone else assuming the point of the discussion is "there is an out-group and we should hate them!"
I don't have time in my life to hate on any out-groups. I'm only really here to talk about how to cope. (My whole point here was just "you don't need to be anxious about how to cope with this new problem, because it's not much of a problem at all for you personally.") Maybe HN is not for me.
Don't forget that we use a gazillion languages here. They'd have to either produce separate packaging for each country / language region or attach a brochure to each tube of toothpaste. These Latin/English-based names are the lingua franca of the ingredient lists on this kind of products specifically. I'd say it's better than having absolutely no idea if the shampoo you bought on vacation contains stuff you're allergic to.
