Two bills concerning cosmetic manufacturing in California have been working their way through the legislative process. California Governor Jerry Brown just signed AB 2775 on Sept 14th, 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 that are “for professional use … Read More
Are Your Product Claims Fake News?
You may have heard that Google, Facebook and other social media sites are trying to figure ways to weed out fake news before it makes its way into the wild. That they are using a combination of artificial intelligence, computer algorithms and live human reviews to decide what’s real and what’s fake. That they have started banning the sites and … Read More
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
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
