Soap: the Chameleon

Posted in: Legislation & Regulation, Soap & Cosmetic Labeling

Soap is a chameleon – it can be many things depending on what you claim it can do. It is the CLAIM that determines what the product is, and that, in turn, determines what REGULATIONS/LAWS apply. Soap can be a drug: if you make claims that it (or any of the ingredients in it) is intended to treat physical issues (eczema, … Read More

Lawsuits Over “Organic” Cosmetics

Posted in: Legislation & Regulation, Soap & Cosmetic Labeling

Babyganics is now the last in a long line of cosmetic companies sued for false advertising over organic-type claims.  Last month 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 shampoo. I wrote a couple of years … Read More

FDA Upping Their Game for Cosmetics

Posted in: Soap & Cosmetic Labeling

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 two issued in 2014 and it’s easy … Read More

Healing Claims for Ingredients

Posted in: Soap & Cosmetic Labeling

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. As a perfect example, the FDA issued a warning letter to Sevani Botanica in mid-July in which most of the cited issues had to do with statements made about the essential oils in the products. … Read More

Claims and Intended Use

Posted in: Soap & Cosmetic Labeling

When describing your product, keep in mind that the whole point of “claims” is that they are providing information to the consumer about the intended use. Technically it’s not the claim, but what the consumer perceives to be the intended use of the product that determines whether it is a drug or cosmetic. If your product description, customer testimonials or … Read More

What’s in a Name?

Posted in: Soap & Cosmetic Labeling

Once again we’re discussing ingredient names, but this time in the name or identity of the product, not in the ingredient declaration. It can get a little tricky because there are different regulations for cosmetics and for soap that is exempt from the definition of a cosmetic.  See Intended Use – Know Before You Go and Melt & Pour Soap: Soap or … Read More

Roaming the Back Roads

Posted in: Life & Travels

In order to not confuse our travel adventures with my posts on Labeling and Good Manufacturing Practices (and in order to give Jere a place to post about our travels), we have started a new blog just covering our travel adventures. Come join us at Roaming the Back Roads (www.roamingthebackroads.com). You can find maps, summaries of our trip, pictures of … Read More

Brexit and Cosmetics

Posted in: Soap & Cosmetic Labeling

If you are following international news, you probably heard that Brexit was approved and Great Britain will be leaving the European Union.  What does that have to do with cosmetics? Well, honestly, I don’t know all the ins-and-outs of how the process of their leaving the EU will work, but I was struck by a couple of lines in an article The Daily … Read More

Toxic Substance Control Act Reform 2016

Posted in: Legislation & Regulation

If you’re following chemical news, you may have heard that reforms of the Toxic Substance Control Act of 1976 were just signed into law by President Obama.  A pretty concise summary of the changes in existing law is available here. In very, very brief summary, the revisions to the TSCA passed in 1976 include giving the EPA authority – and a … Read More