An Almond Doesn’t Lactate

Last month, pointing out that “almonds don’t lactate,” FDA Commissioner Scott Gottlieb announced that the FDA will soon issue a new guidance on the use of the term “milk.” Currently milk is defined as “the lacteal secretion, practically free from colostrum, obtained by the complete milking of one or more healthy cows” or goats.1 Let’s put that all together. Since … Read More

Are Your Color Additives Legal?

As I’ve discussed in previous posts (here,  here and here) color additives are a major concern for the FDA. Certain color additives are subject to certification by the FDA before they can be used. Using one of those colors that is NOT certified causes your product to become “adulterated” (and therefore illegal to sell). So how do you know if … Read More

If One, Then All?

“If you put one ingredient on your soap label, you have to list them all” is an idea is being bantied around a lot lately.  But is it true? As with most questions about legal stuff and regulations … yes … and no. Cosmetics If the product is a cosmetic, then the answer is a resounding YES. Not only do … Read More

Natural Colorants, More

Since my last post about natural colorants I’ve gotten some questions about using ingredients that change the color of the soap or cosmetic but that really wasn’t the point of the ingredient. Lets review the definitions.  I’m just including the important bits, and bolding the really important bits. Color Additive Any material that is capable of imparting a color to … Read More

Natural Colorants for Soap & Cosmetics

For most people making and selling handcrafted soap and/or cosmetics “natural colorants” means ingredients such as herbs and spices that will change the color of your product.  If you do a Google search for “natural colorants” you will find articles, posts, messages, books, webinars and more detailing the many ways you can make beautiful and colorful products without the use of … Read More

Trade Secrets

You’ve developed the perfect product and you want to keep the formulation secret. Can you hide some of the ingredients? Well, yes and no. Trade Secret Any formula, pattern, device or compilation of information which is used in one’s business and which gives him an opportunity to obtain an advantage of competitors who do not know or use it. The … Read More

Looking for Product Drug Claims

When we talk about “drug claims” we are actually talking about the statements that tell the consumer that product is intended to be used to diagnose, mitigate, treat or prevent disease or to change the structure or function of the body. How does the FDA determine the intended use of a product? Where do they look? Recent Warning Letter Sometimes examples … Read More

10 Ways to Improve Your Quality Control

“Quality control” is all about finding each little thing you can do to maintain control over the quality of your products. Let’s take a look at some of the things you can do to improve your quality control. 1. A good formulation First and foremost, you need to have a good formulation that results in a high-quality product.  Product formulation … Read More