Net Weight … Again

Posted in: Soap & Cosmetic Labeling

As you can probably imagine, I am on a lot of Facebook groups. I see many, many pictures of labeled soap and cosmetics. People send me soap labels to look at; they ask for my advice. I have a label review service. The net result is that I see a HUGE number of labels. Why do I mention that? Because … Read More

Another FDA Warning Letter

Posted in: Legislation & Regulation, Soap & Cosmetic Labeling

The FDA just 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 cure, mitigation, treatment, or prevention of disease … Read More

FDA “Discretionary Enforcement”

Posted in: Legislation & Regulation

Last March, 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 are some labeling regulations that the FDA has apparently decided not to enforce … but they haven’t really said anything publicly.  That may be why we see so many … Read More

Florida Regulations – Changed 2017

Posted in: Legislation & Regulation

After work by a number of people and groups, the Governor of Florida has just signed new legislation that makes it easier for cosmetic manufacturers in Florida. Prior to the changes Up until now, Florida Cosmetic Manufacturers were required to get a Cosmetic Manufacturing Permit at a cost of $800 every 2 years, and register each and every cosmetic product at $20 … Read More

More About “Natural” Claims

Posted in: Legislation & Regulation

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 and Cosmetic Act was updated … Read More

Net Contents Big Enough?

Posted in: Soap & Cosmetic Labeling

I have a wonderful Facebook feed and see an amazing number of soaps.  All sorts of soaps … cold process, hot process, melt & pour, swirled, layered, piped, molded, embossed, stamped – you name it! I also see packaged soaps galore.  While the traditional cigar band label is most common, soapmakers have also put together some different kinds of very creative … Read More

Hybrid Soap Ingredient List

Posted in: Soap & Cosmetic Labeling

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 soap with MP soap embeds (or vice versa)?

What about Glitter?

Posted in: Legislation & Regulation

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.  In fact, the FDA says that glitter is not an approved color additive. BUT, you can see glitter in all sorts of commercial cosmetic products … so what’s … Read More

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