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 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

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

What about Glitter?

Oooh, pretty! Shiny! Sparkles! Glitter! But can you put it in soap or cosmetics? The FDA regulates color additives that may be used in cosmetics, and “glitter” is not on the list.  In fact, the FDA says that glitter is not an approved color additive. BUT, you can see glitter in all sorts of commercial cosmetic products … so what’s … Read More

Soap: the Chameleon

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