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

New FDA Webpage for Handcrafters

The FDA has published a new webpage that is directed to cosmetic handcrafters. It’s the Small Businesses & Homemade Cosmetics: Fact Sheet, which can currently be found in the Cosmetics section of the FDA website, under “Resources for You” > “Industry“. Just to clarify, nothing has changed; there are no new regulations.  This is just a new page on their … Read More

Our Trip So Far (September 2015)

Update April 2016: See our blog, Roaming the Back Roads, for further stories of our travel adventures. From Bend we worked our way (slowly) down to Pahrump, Nevada, where we had reservations in an RV park for 3 weeks.  Once we got a ways east, we were in what seemed like endless desert. Flat, hot, and going on and on … 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

Our Trip So Far (August 2015)

Update April 2016: See our blog, Roaming the Back Roads, for further stories of our travel adventures. After 3 1/2 months on the road, I figure it’s time I post an update on what we’ve been doing and where we’ve been. (I’ll try to post more frequently … my goal is once a week, if there is anything interesting to … Read More

Soap Ingredient Declarations Revisited

I’ve covered this in earlier posts, but there are still questions. Does soap need an ingredient declaration? Does it have to meet the FDA regulations for cosmetic ingredient declarations? In this post I am addressing “true soap” that is EXEMPT from the FDA definition of a cosmetic.  That means: The bulk of the non-volatile portion consists of the alkali salt of fatty acids. … Read More