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

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)?

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