Making Cosmetics in Pennsylvania

Pennsylvania is apparently another state that has specific requirements for cosmetic manufacturers. They’ve been on the books for a number of years (at least partially) but apparently haven’t been enforced much until just recently. The information available online is somewhat contradictory, but it does look like they do expect all cosmetic manufacturers to register. Registrations are under the Pennsylvania Department … Read More

FDA Warning Letters: Products Containing CBD

The FDA sent out 15 warning letters last week to companies that are illegally marketing products containing CBD.  I thought it might be interesting to take a look at what the FDA is going after and why. The FDA’s Position First, let’s review the FDA’s position on the marketing of products containing CBD. The FDA has acknowledged what we all … Read More

Florida Regs – 2019 Recap

[Updated July 11, 2019 to include a section on Inspections and a link to the actual regulations for the requirements that must be met.] Of all the subjects I get asked about, making cosmetic products in Florida is close to the top of the list because they have the most stringent regulations for cosmetic manufacturers. That being the case, I … Read More

FDA & Social Media

NOTE: This post is not specifically about handcrafted soap and cosmetics, but more about FDA enforcement generally. The Food Drug and Cosmetic Act defines the “label” as the written printed or graphic matter on the immediate container of a product and “labeling” as all written, printed, or graphic matter accompanying an article at any time. The FDA has authority over … Read More

FDA Site Update

If you’ve gone to the FDA website in the past week or so, you probably noticed that they site has been updated and now looks completely different. According to their website, they are changing over to a new “more modern” WCMS (Website Content Management System), the biggest benefit of which is that it will be easy to view the site … Read More

FDA Warning Letters Over CBD

Three of the FDA warning letters in the past week have been concerning products containing CBD. Looks like they are starting enforcement activities in this area. All three of the warning letters (to PotNetwork Holdings, Advanced Spine and Pain, and Nutra Pure) cited similar violations. Drug Claims Claims that the product would treat or mitigate various diseases, aches and pains, … Read More

What about CBD Oil?

CBD is short for cannabidiol, one of the many compounds found in the cannibis plant. It is non-intoxicating, but many claim it has significant physical benefits. “Hemp” and “marijuana” have been lumped into the same category since the 1937 Marijuana Tax Act and the 1970 Controlled Substances act. However, last December the 2018 Farm Bill was passed by US Congress, … Read More

Certificate of Free Sale

A Certificate of Free Sale is a document that provides proof that a product is being freely and legally sold without restriction.  It is sometimes also called a “Certificate for Export” or “Certificate to Foreign Governments.” When is a Certificate of Free Sale needed? A Certificate of Free Sale is needed if you are exporting from the US to another … Read More