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

Our Trip So Far (August 2015)

After 3 1/2 months on the road, I figure it’s time I post an update on what we’ve been doing and where we’ve been. (I’ll try to post more frequently … my goal is once a week, if there is anything interesting to report.) We left home on August 10th, first to drop stuff off at storage and then to … Read More

Soap Ingredient Declarations Revisited

I’ve covered this in earlier posts, but there are still questions. Does soap need an ingredient declaration? Does it have to meet the FDA regulations for cosmetic ingredient declarations? In this post I am addressing “true soap” that is EXEMPT from the FDA definition of a cosmetic.  That means: The bulk of the non-volatile portion consists of the alkali salt of fatty acids. … Read More

Blended Fragrances in the Ingredient Declaration

One of the options available for your cosmetic ingredient list is to use the term “fragrance” to cover any ingredient(s), blended or not, that are used to scent your product. But what if you use a blend of plant-based essential oils to provide scent, not synthetic “fragrance oils”? The rule still applies, but you have some additional options. The Regulations … Read More

Cosmetic Regulations – Ohio

A woman recently contacted me and told me that a representative of the Ohio Department of Agriculture had told her that cosmetics couldn’t be made “at home” and she’d need to be licensed in order to make or sell cosmetics. Is that correct? Umm, no, not at all. The Ohio Small business Development Center has a page about starting a business in … Read More

Book Availability

As you may have heard, I announced that Jere and I are planning to “run away from home” in our new (to us) RV.  It’s actually happening! All goes well, we’ll be heading out next Monday, August 10th. Obviously, I can’t be stocking and shipping books while we’re on the road (not enough storage space, for one thing!).  So, I’ve made arrangements … Read More

Mary’s Monkey

As one of my personal projects, I am scanning and correctly, archivally storing the family collection of papers and documents.  Yesterday I scanned a collection of 400 post cards dating from 1908 to 1920. One little series mentioned soap, so I read it carefully … and I just have to share: Mary has a little Monkey Just as cute as it … Read More

Myth: Soap Labels Aren’t Regulated

One of the myths that I still frequently hear is that “I can put whatever I want on my soap labels because they aren’t regulated.”  I believe that particular myth got started because of the “soap exemption” in the FDA’s definition of “cosmetic”: A product, except soap, intended to be applied to the human body for cleansing, beautifying, promoting attractiveness or … Read More

Bittersweet Weekend Trip

As a sort of pre-Memorial Day Weekend trip, Jere and I, accompanied by dogs Duke and Xena, went on a short jaunt north and then back down the coast.  It was a trial run with the dogs in the RV, to see if they (and we) would be able to do it.

It’s harder than you think

Running away from home in our new RV is turning out to be a little more complicated than one would think. So many things to consider and take care of. The biggest issue is getting rid of all our STUFF, since it won’t fit in the RV!  The good news is that we’re making progress.  The bad news … lots … Read More

FDA Warning Letters – Drug Claims for Cosmetics

I get notices when the FDA sends out warning letters and it seemed like there has been an increase in warnings to cosmetic companies for drug claims. So I checked. Yes – there definitely has been an increase. One would guess that the FDA is looking a little more carefully at the claims being made. So far in 2015, there … Read More