Recently there has been some discussion online (in a Facebook Group) as a result of a report of a conversation with someone from the FDA. The report was that this FDA representative said that if you wanted to use the word “moisturizing” to describe a soap, then your recipe would need to be submitted and evaluated for its composition of moisturizing properties. This FDA person also said that the term “lip balm” is regulated by the FDA as a drug.
I have absolutely no reason doubt that the person reporting this conversation reported it accurately. She was, in fact, doing her due dilligence in checking with the FDA to understand the rules and regulations.
The problem is that FDA staff are human, and may not be completely versed in all the applicable regulations when confronted with a question from the public. I doubt they intentionally give out wrong information, but it’s happened in the past, I expect it will happen in the future, and it’s likely that it happened in this instance. It’s generally better to understand the regulations by referring to the actual regulations, or at least to the written material the FDA provides as it has been vetted and double checked for accuracy.
So, here are a few documents to take a look at when evaluating the accuracy of the information provided by someone at the FDA in this case:
I’ve been discussing, writing, and lecturing on the subject of soap and cosmetic labeling for nearly 10 years now. During that time I’ve discovered that people who are making handcrafted soap and cosmetics seem fall into categories when it comes to knowing and following the regulations.
As with all things, how a person deals with knowing or not knowing a subject, can say a lot about him or her.
More interesting questions from readers this week. Smoothies in soap, trade secrets, essential oils, links to regulations and more. Please feel free to email me your questions to email@example.com!
If you make soap and use a smoothie (i.e. Green Machine or Bolthouse Farms Green Goodness) as water replacement, how would you label it? These products sometimes have about twenty items in them.
The answer depends on what you are doing with the soap and how you are marketing. If you aren’t SELLING the soap, then you don’t have to do anything. If you ARE selling, there are a couple of possibilities.
One of the things that you often see on soap and cosmetic labels are bar codes. They are not required by regulation, but can make a big difference in where and how your products can be sold.
Many of the large stores or chains use UPCs on all their products – both at the point of sale when the customer actually buys the product, but also for inventory, stocking, purchasing and more. If you are looking to get into the wholesale market – especially if you want to wholesale to large stores or chains – bar codes may be an important part of of your package label.