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Insect Repelling Soap and Cosmetics

mosquitoSeveral people have asked me recently about soaps and cosmetics that repel insects. What are the regulations and how do they get labeled? Once there’s a “pesticide” claim (i.e. that the product repels insects), the product falls under the jurisdiction of the EPA, under the authority of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). The EPA are the ones that protect us from unsafe, toxic and mis-used poisons. Generally, insecticides quite understandably require safety substantiation, registration and pre-market approval. However, there are provisions for “minimum risk” pesticides (think citronella candles, for example).

What About “Natural”?

calendulaCan you call a cosmetic product “natural”? And what does that really mean, anyway?

Nowadays, there are so many products of all types being marketed as “natural” it’s getting crazy!  I recently saw some piece of furniture marketed as “natural” because it was made (mostly) of wood.  Where does it end?

The first thing to know is that, when it comes to soap and cosmetics, there is no regulatory definition of “natural”.

Ingredient Names From 1977 Still Good?

Second Edition (1977)

Second Edition (1977)

The Code of Federal Regulations specifies where to find the names by which cosmetic ingredients should be identified in the ingredient declaration on a cosmetic. First are any names “established by the Commissioner” (there are a few) and then the CTFA Cosmetic Ingredient Dictionary, Second Ed., 1977.

After some searching, I was finally able to locate a copy of this elusive book ($200 from an online used book distributor). Now I’ll share what I found in the book.

Using an Ingredient Name in a Product Name

2014-03-14-choose-cosmeticOver the years, one small section in my book, Soap and Cosmetic Labeling, has probably generated the most question and online discussion than any other.  That section covers “Using an Ingredient in the Name” and discusses the FDA regulations that prohibit the use of the name of one ingredient in the name of the product (if it has two or more ingredients).

What about “Goat Milk Soap” or “Oatmeal Soap” or “Luxe Lotion with Shea Butter”? On the one hand, those product names seem reasonable.  But first, let’s take a look at why the regulation might be there in the first place.

Getting Back in the Groove

dreamstime_xl_30323641They say that when you fall off a horse, the best thing is to get right back on. The rationale is that the longer you delay, the harder it is to overcome any fear you have from falling off in the first place. In other words, you lose your groove.

Well, I can tell you from recent personal experience, the longer your out of the groove, the harder it is to get it back.

More on “Lip Balm”

http://www.dreamstime.com/stock-images-homemade-lip-balm-image18359584Last year I wrote a post, “Drug Claims and Lip Balm” which discussed the use of the phrase “lip balm” as the identity of a product.  Unlike “lipstick” or “lip gloss,” the specific term “lip balm” is cited in the over-the-counter drug monograph for “skin protectants” as one of the approved ways to identify a skin protectant (which is a drug). The issue came up again recently on a newly updated FDA webpage, Cosmetic Export Certificates.  On that page, which is essentially a FAQ about how to get a cosmetic export certificate, lip balm was mentioned in one of the questions, “Is my product really a cosmetic under the law?”

FDA Issues New Draft of Cosmetic Good Manufacturing Practices Guidelines

FDA.jgpThe FDA recently announced that they have issued a new draft guidance on good manufacturing practices for cosmetic products. This new draft is an update to the existing “Cosmetic Good Manufacturing Guidelines/Inspection Checklist“. According to the Introduction:
“This document provides guidance to industry and other stakeholders on the FDA’s current thinking concerning what constitutes Good Manufacturing Practices (GMPs) for cosmetics.”

What About “Organic” Cosmetics?

2013-06-10-organicSeveral people lately have asked me about using the term “organic” when it comes to cosmetics.  Can cosmetics be claimed to be “organic?  What about using the term “organic” in a product or company name?

I did some research, and what I discovered was a little bit surprising.  Seems that the FDA and the USDA don’t actually see eye-to-eye on the subject.