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

Anti-Aging, Rejuvenating, and Repairing Claims

In 1988, the FDA issued Import Alert 66-38 titled “Skin Care Products Labeled as Anti-Aging Creams” which clearly stated that exaggerated ‘anti aging’ claims could cause a product to be an unapproved new drug.  Import Alert 66-38 was the basis for understanding restrictions on cosmetic claims like anti-aging, rejuvenating and repairing. That Import Alert was withdrawn at the end of … Read More

Color Additives for In-Bath Products

The FDA regulates color additives and their use. For cosmetics, the FDA has a list of color additives permitted for use in cosmetics and each color additive has specifications on how it may be used: “Eye Area” means the area around the eyes. Which is the area from the brow to eyelids, lashes, eyeball and area just under the eye. Color additives … Read More

Street Address – Your Choices

Even though the requirements for the street address on the label are pretty clear cut, it still seems to be an issue for those working out of their homes. The street address IS required on the product label, but may be omitted under certain circumstances (the city, state and zip code are always required).  The regulations that define those “certain … Read More

“Love” Isn’t an Ingredient

The FDA has finally stated, clearly and definitely, that “love” isn’t an ingredient … at least in granola. Recently the news and social media have been filled with articles about the FDA’s recent warning letter to a bakery in Concord, Massachusetts, in which they were cited for (amongst other things), including “love” which is “not a common or usual name … Read More

Minimum Risk Pesticides

The EPA website has been updated since the last time I looked at it. It still wasn’t too easy to find the Minimum Risk Pesticides page, but once I found it, I discovered it was much clearer and easier to understand than before the updates. Of course, the information and regulations haven’t changed – but it is a little easier … Read More

FTC updates business address requirements

The FTC has issued the final rule for updating some aspects of their labeling regulations, including the requirements for the business name and address. Note that these revised regulations will apply to non-cosmetic items, including to soap that is exempt from the definition of a cosmetic (see Soap, the Chameleon). The updated regulation concering the business name and address is updated … Read More

Net Weight … Again

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

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”

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

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

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