(c) The statement of the place of business shall include the street address, city, state, and zip code; however, the street address may be omitted if it is listed in a readily accessible, widely published, and publicly available resource, including but not limited to a printed directory, electronic database, or Web site.This is very good news for everyone who makes true soap or other consumer commodities. Comments are being accepted until March 30, 2015.
Well, it’s finally happened. I’m OUT OF STOCK on the 2nd Edition of the book (2010)!The 2015 updated 3rd Edition (I’m calling it the “purple edition”) is almost finished. I’m on the final round of edits and updates. In a way, it’s good that the project was delayed a bit because now I’ll be able to include information about the FDA’s response to the HSCG’s PO Box Petition. At the moment, it looks like the book will be winging its way to the printer sometime near the end of January, and I’ll have books in stock around the end of February. Cost of this edition is the same ($24.95 with free shipping in the US), but orders placed before the book is back in stock will get a 20% discount (reducing the price to $20.00).
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:
What are the size requirements for the net weight?The size of the text for the net weight is dependent upon the size of the principal display panel. If the PDP is less than 5 square inches, height of the net contents must be at least 1/16”. If the PDP is 5 – 25 square inches, the net contents must be at least 1/8” high. For most cosmetics and soaps, the PDP will be between 5 and 25 so the text of the net contents should be 1/8” high. If the text is in lower case or upper and lower case (i.e. “fl. Oz.” or “Fl. Oz.”), the height is measured by the height of a lowercase “o”. If the text is in only uppercase, it is measured by the height of the uppercase “L”. In addition, the text should be separated above and below by the space of an upper case “N” and on the sides by the width of three upper case “N’s”, as you can see in the image above.
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.
One of the things I love about the handcrafted soap and cosmetic industry is how so many people are willing to share and help others. I’m a member of a number of Facebook groups covering different aspects of soap and cosmetics and I am always inspired by the amount of care that the members have for have for each other. Whether it’s advice about how to accomplish something, suggested resources or just a pat on the back for a job well done, these are generally friends you can count on.
In brief, the questions for this week are:
- Licensing needed for bath and body products containing wine or beer?
- “100% natural” with fragrance oils?
- Essential oils as inert ingredients in bug repellent?
- What does that “e” symbol mean?
When we talk about soap and cosmetic labeling, very often the discussion is about the regulations and the requirements. It’s true that the package label must contain very specific elements, but what about the rest of the label content? What about the “labeling,” defined as the materials and text that goes with the product (like promotional materials and website content)?
On your actual product labels and in your accompanying materials, you have many, many opportunities to present your product and your business to your customers and the world. Just because you can’t say that your soap cures eczema or reduces acne, doesn’t mean you can’t say plenty of other good things about the product and the company.
This is the first of my new blog post series, Monday Mailbag, in which I’ll answer soap or cosmetic labeling or GMP related questions that have been sent to me. We’re starting out with an eclectic mix this week – from patenting soap to how to list hydrogenated oils in the ingredient declaration.
If you have a question that you would like answered, please email it to me at hello AT mariegale.com. I hope to be able to answer 5 – 10 questions each week
I recently found a marvelous brochure, Making Soap at Home from February, 1955. Prepared by Irene Crouch, Extension Agent Home Management, and published by the Extension Service (North Dakota), this little document outlines how to make soap at home.
“A thrifty housewife can save many dollars a year by making soap of good quality.”
Can 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”.
The FDA recently updated the Cosmetic section of their website and added some new pages that clarify regulations, particularly for small manufacturers of soap and cosmetics. Some of the most commonly asked questions are very clearly answered in FAQ format.
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.
Over 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.