Our Trip So Far (October 2015)

Yes, I realize that it is already May 2016, but I promised that I would post updates on our trip and so I shall. October started out with us leaving Pahrump, NV on October 2nd and heading off to Las Vegas (just about an hour down the road).  We pulled up by the Allure Wedding Chapel and proceeded to GET … Read More

Is the Net Content Required in Metric?

Are you required to put the net contents in metric on your soap or cosmetic label? As with most regulatory questions, the answer is … it depends.  The long answer (with references) is explained below.  But if you want the short answer … skip to the bottom. Over-Riding Law The law that applies here is the Fair Packaging and Labeling … Read More

Cosmetic Regulations – Louisiana

Louisiana is another state that has some regulations for cosmetic manufacturers over and above what the FDA requires. I recently did some looking into the laws and regulations for Louisiana. Dept of Health and Hospitals The Food and Drug Unit in the Office of Public Health under the Louisiana Department of Health and Hospitals seems to have jurisdiction over not … Read More

ISO Issues Natural and Organic Cosmetic Guidelines

In February this year, the International Standards Organization issued ISO 16128-1, Guidelines of technical definitions and criteria for natural and organic cosmetic ingredients and products (available to purchase here).  The description of the guidelines says: ISO 16128-1:2016 provides guidelines on definitions for natural and organic cosmetic ingredients. In addition to natural and organic ingredients, other ingredient categories which may be necessary … Read More

What’s the Worst That Could Happen?

I’ve talked in the past about the dangers and pitfalls of making medical claims for soap and cosmetic products. I’ve also covered how claims for the ingredients or consumer testimonials can be interpreted as claims for the product. Over and over, handcrafters have asked me: “What’s the worst that could happen?” An Amish handcrafter named Sam Girod had his products seized (see U.S. … Read More

What Suppliers Will (and Won’t) Tell You

When you make cosmetics, you are required to declare on the label all of the ingredients in descending order of predominance.  In addition, unlike food, you must list all of the components of a blended ingredient individually in correct order in the ingredient declaration.  If you purchase, for example, a preservative that has several component ingredients, they ALL must be … Read More

Melt & Pour Soap: Soap or Cosmetic?

I’m often asked if melt and pour soap is a soap or a cosmetic.  The answer, to quote one of my favorite law blogs1, is “it depends.” Definitions It all comes down to definitions, and the word “soap” has several. Sometimes they overlap, and sometimes they are completely different. General Definition The common or general definition of soap found in … Read More

New FDA Webpage for Handcrafters

The FDA has published a new webpage that is directed to cosmetic handcrafters. It’s the Small Businesses & Homemade Cosmetics: Fact Sheet, which can currently be found in the Cosmetics section of the FDA website, under “Resources for You” > “Industry“. Just to clarify, nothing has changed; there are no new regulations.  This is just a new page on their … Read More

Our Trip So Far (September 2015)

From Bend we worked our way (slowly) down to Pahrump, Nevada, where we had reservations in an RV park for 3 weeks.  Once we got a ways east, we were in what seemed like endless desert. Flat, hot, and going on and on and on and on. When we were looking for our first stop, I found Crystal Crane Hot … Read More

“Label” vs. “Labeling”

Is there a difference between the “label” and the “labeling” when it comes to soap and cosmetic labels? YES. (Well, mostly.) The FDA defines “label” and “labeling” for food, drugs and cosmetic products. The FTC defines “label” for consumer commodities other than food drugs and cosmetics. Most states have regulations that define “label” and “labeling” for food drugs and cosmetics. The … Read More