Brexit and Cosmetics

If you are following international news, you probably heard that Brexit was approved and Great Britain will be leaving the European Union.  What does that have to do with cosmetics? Well, honestly, I don’t know all the ins-and-outs of how the process of their leaving the EU will work, but I was struck by a couple of lines in an article The Daily … Read More

International Cosmetic Laws

While most of my writing has been on the subject of United States regulations, the truth is that nearly all major countries have very comparable laws when it comes to labeling soap and cosmetics. The US is a bit more lenient when it comes to soap, and to registration and pre-approval. The reason for the similarities in labeling laws is … Read More

Is the Net Content Required in Metric?

Are you required to put the net contents in metric on your soap or cosmetic label? As with most regulatory questions, the answer is … it depends.  The long answer (with references) is explained below.  But if you want the short answer … skip to the bottom. Over-Riding Law The law that applies here is the Fair Packaging and Labeling … Read More

ISO Issues Natural and Organic Cosmetic Guidelines

In February this year, the International Standards Organization issued ISO 16128-1, Guidelines of technical definitions and criteria for natural and organic cosmetic ingredients and products (available to purchase here).  The description of the guidelines says: ISO 16128-1:2016 provides guidelines on definitions for natural and organic cosmetic ingredients. In addition to natural and organic ingredients, other ingredient categories which may be necessary … Read More

What’s the Worst That Could Happen?

I’ve talked in the past about the dangers and pitfalls of making medical claims for soap and cosmetic products. I’ve also covered how claims for the ingredients or consumer testimonials can be interpreted as claims for the product. Over and over, handcrafters have asked me: “What’s the worst that could happen?” An Amish handcrafter named Sam Girod had his products seized (see U.S. … Read More

What Suppliers Will (and Won’t) Tell You

When you make cosmetics, you are required to declare on the label all of the ingredients in descending order of predominance.  In addition, unlike food, you must list all of the components of a blended ingredient individually in correct order in the ingredient declaration.  If you purchase, for example, a preservative that has several component ingredients, they ALL must be … Read More

Melt & Pour Soap: Soap or Cosmetic?

I’m often asked if melt and pour soap is a soap or a cosmetic.  The answer, to quote one of my favorite law blogs1, is “it depends.” Definitions It all comes down to definitions, and the word “soap” has several. Sometimes they overlap, and sometimes they are completely different. General Definition The common or general definition of soap found in … Read More

“Label” vs. “Labeling”

Is there a difference between the “label” and the “labeling” when it comes to soap and cosmetic labels? YES. (Well, mostly.) The FDA defines “label” and “labeling” for food, drugs and cosmetic products. The FTC defines “label” for consumer commodities other than food drugs and cosmetics. Most states have regulations that define “label” and “labeling” for food drugs and cosmetics. The … Read More