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Category: Legislation & Regulation

  • FDA Warning Letters 2021

    FDA Warning Letters 2021

    I’ve been receiving a lot notices of FDA warning letters, so I reviewed the last 106 warning letters (60 days) to see what sort of warnings they have been sending out lately. Here’s the breakdown of the types of products cited (in descending order). Unapproved New Drugs Warning letters concerning cosmetics are usually found under […]

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  • Making Cosmetics in Pennsylvania

    Making Cosmetics in Pennsylvania

    Pennsylvania has requirements for cosmetic manufacturers, including registration.

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  • FDA Warning Letters: Products Containing CBD

    FDA Warning Letters: Products Containing CBD

    The FDA sent out 15 warning letters last week (Nov. 2019) 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. […]

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  • FDA & Social Media

    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, and defines “labeling” as all written, printed, or graphic matter accompanying an article at […]

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  • FDA Site Update

    FDA Site Update

    If you’ve gone to the FDA website in the past week or so, you probably noticed that their website 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 […]

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  • FDA Warning Letters Over CBD

    FDA Warning Letters Over CBD

    Three FDA warning letters issued 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 […]

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  • What about CBD Oil?

    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, in December the 2018 Farm Bill […]

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  • Certificate of Free Sale

    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 […]

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  • Why is Regulatory Compliance Important?

    Why is Regulatory Compliance Important?

    When looking at the minutiae of labeling a soap or cosmetic product, it’s easy to forget the big picture. Why are all these regulations in place? Why is it important to comply with them? Why Are There Regulations At All? In the USA, regulations are the rules that are put in place to implement the […]

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  • California Cosmetic Regulations Updated

    California Cosmetic Regulations Updated

    Two bills concerning cosmetic manufacturing in California have been working their way through the legislative process. California Governor Jerry Brown signed AB 2775 on Sept 14th, 2018, and SB 1249 went to the Governor on September 12th. What does it mean for handcrafted cosmetics? AB 2775 – Professional Cosmetic Labeling California AB-2775 requires that all cosmetics […]

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  • Making Cosmetics in Connecticut

    Making Cosmetics in Connecticut

    Connecticut requires that Cosmetic Manufacturers get licensed. Licensing requires an inspection that is primarily focused on Good Manufacturing Practices.

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  • If One, Then All?

    If One, Then All?

    “If you put one ingredient on your soap label, you have to list them all” is an idea is being bandied 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. […]

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