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FTC updates business address requirements
The Federal Trade Commission (“FTC”) has issued the final rule for updating some aspects of their labeling regulations, including the requirements for the business name and address. Note that these revised regulations will apply to non-cosmetic items, including to soap that is exempt from the definition of a cosmetic (see Soap, the Chameleon). The updated regulation […]
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Understanding the Net Contents
Close to HALF of the labels I see don’t include the net weight. The net weight of the product isn’t just a good idea. It is a key piece of information that is required on every product.
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Another FDA Warning Letter
The FDA just (July 2017) published a warning letter to a cosmetic manufacturer in St. Louis. Once again, the FDA reviewed the website and cited drug claims: “…the claims on your website establish that the products are drugs under the … Food Drug and Cosmetic Act … because they are intended for use in the […]
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FDA “Discretionary Enforcement”
Last March (2017), I sent a Freedom of Information Request to the FDA, asking for details on any decisions they had made to use “discretionary enforcement” on some regulations. It seems that there are some labeling regulations which the FDA has apparently decided not to enforce, but they haven’t really said anything publicly. That may […]
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More About “Natural” Claims
The FDA doesn’t regulate the term “natural” for cosmetics, but the FTC has taken action against deceptive claims of “all natural” cosmetics under their authority over “deceptive practices.” Who Has Authority? When it comes to cosmetic products, their safety and labeling, the FDA has authority. But as an interesting historical note, when the Food Drug […]
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Net Contents Big Enough?
Most of the recent packaging I’ve seen DOES have the net contents on it. However, on almost all, it is way too small. Way. Too. Small.
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Hybrid Soap Ingredient List
Some stunning hybrid soap can be made by combining two different types of soaps into one artistic bar. The problem is, how do you figure out the ingredient declaration when you have a CP (cold process) soap with MP (melt & pour) soap embeds, or vice versa?
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What About Glitter?
Oooh, pretty! Shiny! Sparkles! Glitter! But can you put it in soap or cosmetics? The FDA regulates color additives that may be used in cosmetics, and “glitter” is not on the list of approved color additives. In fact, the FDA says that glitter is not an approved color additive. BUT, you can see glitter in all […]
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Soap: Cosmetic or Not?
Soap is a chameleon; it can be a cosmetic or something else, depending on what it is made of, what it’s used for, and what you claim it can do. In many cases, it is the CLAIM that determines what the product is, and that in turn determines which REGULATIONS or LAWS apply. Soap Can […]
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Lawsuits Over “Organic” Cosmetics
Babyganics is now the last in a long line of cosmetic companies sued for false advertising over organic-type claims. Last month (Sept 2016) there were two suits filed against Babyganics, one for falsely advertising and implying their products are organic and one by a mom who alleged that her toddler sustained chemical burns from Babyganics tear-free […]
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FDA Upping Their Game for Cosmetics
The FDA just updated their Warning Letters Address Drug Claims Made for Products Marketing as Cosmetics Claims page with yet more warning letters. That makes twenty-five warning letters issued so far in 2016. And of those, 18 were issued in just the last 3 months! Compare that to nine warning letters in 2015 and only […]
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Healing Claims for Ingredients
When you say that an product ingredient can heal, you are making the same claim for the product itself, so it becomes an unapproved new drug.
Helping you undersand soap and cosmetic regulations — in plain English.
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