Helping soap and cosmetic handcrafters navigate the rules and regs.
Blog posts that deal with soap and cosmetic labeling; addition information, questions asked and answered and updates as new information becomes known.
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 […]
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.
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, which determines whether it is a drug or cosmetic. If your […]
Once again we’re discussing ingredient names, but this time in the name or identity of the product, not in the ingredient declaration.
It is the intended use of a 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? This is a very important concept to understand: the intended use […]
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 […]
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 […]
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 just skip to the bottom. Overriding Law The law that applies here is the Fair […]
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 […]
I’ve talked in the past about the dangers and pitfalls of making medical claims for soap and cosmetic products. Over and over, handcrafters have asked me: “What’s the worst that could happen?”
When you make and label your own cosmetics, you are required to declare on the label all of the ingredients in descending order of predominance. In addition (and unlike food) you must list all of the components of any blended ingredient individually, in correct order in the ingredient declaration. If you purchase, for example, a […]
Whether a melt & Pour soap is a cosmetic or not depends on the ingredients and how it is marketed.