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 circumstances” are different for cosmetics and other products (including soap when it is exempt from the definition of a cosmetic).
NOTE: A PO Box does NOT qualify as a street address.
The FDA regulations still say the street address may be omitted if it is included in a “city or phone directory”. In their 2015 response to the HSCG’s petition to allow a PO box, they clarified that it may not be a PO box, but did say that it could be an online or print directory and gave some examples. See my blog post FDA Responds to HSCG PO Box Petition for more details.
For products that are not cosmetics (including soap that is exempt from the definition of a cosmetic), the FTC regulations apply. The FTC recently updated their regulations defining what standards must be met in order to omit the street address from the label. Basically, the address must be published in a readily accessible, widely published, and publicly available resource, which most likely includes a publicly accessible website or an online database (such as a state business listing).
In deciding how to handle the issue of your street address and your label, you have a couple of possibilities:
a. Use the street address on the label.
This always works.
b. List your business – with the street address – in an online phone or city directory.
This meets the requirements to leave the street address off the label for both cosmetic and non-cosmetic products.
c. List your street address on your “readily-findable, publicly accessible” website ot directory.
This meets the requirements to leave the street address off the label for non-cosmetic products.
This does NOT meet the requirements for cosmetic products. However, if you do this and it comes to the FDA’s attention, you have the potential justification and explanation that the regulations from the FTC were likely vetted by their attorney and do comply with the Fair Packaging and Labeling Act.
You will need to decide what is the best course of action for your business and your situation.
[Update – April 27, 2021]
In 2019, the Handcrafted Soap and Cosmetic Guild (HSCG) filed a Citizen Petition with the FDA to update their regulations to match the wording from the FTC. No answer or action has been taken on it as yet. You can read about the petition here.
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