Some stunning hybrid soap can be made by combining two different types of soaps into one artistic bar. The problem is, how do you figure out the ingredient declaration when you have a CP soap with MP soap embeds (or vice versa)?
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
Babyganics is now the last in a long line of cosmetic companies sued for false advertising over organic-type claims. Last month there were two suits filed against Babyganics, one for falsely advertising and implying their products are organic and one by a mom who alleged that her toddler sustained chemical burns from Babyganics tear-free shampoo. I wrote a couple of years … Read More
The FDA just updated their Warning Letters Address Drug Claims Made for Products Marketing as Cosmetics Claims page with yet more warning letters. That makes twenty-five warning letters issued so far in 2016 (and of those 18 were issued in just the last 3 months!). Compare that to nine warning letters in 2015 and only two issued in 2014 and it’s easy … Read More
When you say that an product ingredient can heal, you are making the same claim for the product itself, so it becomes an unapproved new drug. As a perfect example, the FDA issued a warning letter to Sevani Botanica in mid-July in which most of the cited issues had to do with statements made about the essential oils in the products. … Read More
When describing your product, keep in mind that the whole point of “claims” is that they are providing information to the consumer about the intended use. Technically it’s not the claim, but what the consumer perceives to be the intended use of the product that determines whether it is a drug or cosmetic. If your product description, customer testimonials or … Read More
Once again we’re discussing ingredient names, but this time in the name or identity of the product, not in the ingredient declaration. It can get a little tricky because there are different regulations for cosmetics and for soap that is exempt from the definition of a cosmetic. See Intended Use – Know Before You Go and Melt & Pour Soap: Soap or … Read More
It is the intended use of the product that determines what it is. Oddly enough, it can be the exact same product formulation, but it could be classed as different types of products depending on what you say is its intended use. What is it? If the intended use is… To cleanse and it is marketed only as “soap” It … Read More