All Blog Posts

  • Minimum Risk Pesticides

    Minimum Risk Pesticides

    The EPA website has been updated since the last time I looked at it. It still wasn’t too easy to find the Minimum Risk Pesticides page, but once I found it, I discovered it was much clearer and easier to understand than before the updates. Of course, the information and regulations haven’t changed, but it […]

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  • FTC updates business address requirements

    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

    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

    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”

    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

    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?

    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

    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?

    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: 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

    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

    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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