I represent Neutrogena Corporation, and I would like to present the comments, along with substantiation and source information, below for your consideration as more clear and accurate description of Helioplex®. Thank you:

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Helioplex® is a proprietary technology for a formulation of stabilized broad spectrum UVA/UVB sun protection containing Avobenzone and Oxybenzone.

Avobenzone containing products that are not properly formulated and stabilized have decreasing efficacy after a few hours of sun exposure, but the addition of Oxybenzone and a photostabilizer block the degradation that occurs. providing higher levels of UVA protection.

Substantiation: There are no preclinical or clinical studies showing association of the ingredient oxybenzone with increased skin cancer risk. Sunscreen use has been shown to lower the rate of skin cancer (1,2), and a study using a sunscreen containing oxybenzone (3) was shown to prevent skin cancer. Oxybenzone has been extensively reviewed by European Health Authorities (SCCP), the US Cosmetics Ingredient Review, and the FDA and found to be safe for use as used in sunscreen products at the prescribed approved use levels.

Sources: 1: Point: sunscreen use is a safe and effective approach to skin cancer prevention. Author:Green AC,Williams GM, Volume:16 Issue:10, Page:1921-2 Year:2007 Source:Cancer Epidemiol Biomarkers Prev, ID:17932337

2: Prolonged prevention of squamous cell carcinoma of the skin by regular sunscreen use. Author:van der Pols JC,Williams GM,Pandeya N,Logan V,Green AC, Volume:15 Issue:12, Page:2546-8 Year:2006

3. Sunscreens prevent ultraviolet photocarcinogenesis. Author:Kligman LH,Akin FJ,Kligman AM, Volume:3 Issue:1, Page:30-5 Year:1980 Source:J Am Acad Dermatol,

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