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

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 That Import Alert was withdrawn at the end of … Read More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