Bath Bomb Labeling Woes

I was hoping y'all could help me. I'm trying to polish up my bath bombs for better store-sale. I get a lot of wholesale orders, and I'm trying to "work smarter, not harder".
I'm sure you know that labeling a spherical object is basically a fools errand, but here I am! I've been sending a frame with all of my ingredient information, names, weights, manufactured by, & warnings to accompany my wholesale orders - because I read this on the FDA site

All labels and other written, printed or graphic material on or accompanying a product in interstate commerce or held for sale
Sec. 201(m), FD&C Act
21 CFR 1.3(a)
The FD&C Act defines in sec. 201(m) "labeling" to mean "all labels and other written, printed or graphic matter on or accompanying such article."
This includes labels, inserts, risers, display packs, leaflets, promotional literature or any other written or printed information distributed with a product.

So, I assumed, I was covered, as long as the shop owner put my sign up by the bath bombs (which clearly carry my name, matching logo, etc)


Further reading said it had to be attached to the display... But is that only when the items come in a container?? (think lipsticks or nail polish)


I'm reading and rereading and my eyes are going crossed. In your non-fda-approved opinion, am I still in the clear?

It is my understanding that all of the information must be able to go home with the product. So if you box them, the info can be on the box. If you have a tag it must be attached securely and not be able to be easily pulled off. If you include a card with the product then it must be inside the packaging ( like a circular card at the bottom of a shrink bag - with the writing visible through the bottom of the bag.

Simply giving your wholesaler the information is not enough, the customer must have access to the information WITHOUT having to ask for it.

Think of it this way, someone buys your bath bomb - it gives them a terrible rash. The doctor wants to know what is in them. Can the person provide that information? Then the person decides you should pay for the doctor. Do they have your contact information? The law says they should have it on the packaging. It they do not, I'm sure they will find it, but then you would have more to worry about than just a doctors bill. Someone with an allergy will expect to be able to check your ingredients if a rash develops.

Hi MsAlexisClaire! I am trying to think of an easy solution for you to. I was thinking why don't you use cling wrap around them, then stick a sticker on that with the ingredients, as that is easier to stick to, but I suppose too time consuming?

To which I am wonder if you come up with paper wrapping just for your bombs, that is printed with the name of the products, along with the ingredients all over it in a colourful way? that way any paper you pull to wrap the bomb with will have the ingredients written all over it, and too easy to do. (Think of how some fast food places wrap sandwiches with a paper that has their logo and other things all over it.

It is always to be as cautious and as safe as possible when makin products a person could eat or put on their skin, so could this possibly be a workable so,union for you?

I Walk by this shop when on vacation, in fact I will be there next week, notice in the picture their bath bombs are in baskets not wrapped and not labeled.?????

http://justicefergie.com/2013/06/passion-profiles-naples-soap-company-fl/

Soapsense said:

I Walk by this shop when on vacation, in fact I will be there next week, notice in the picture their bath bombs are in baskets not wrapped and not labeled.?????

http://justicefergie.com/2013/06/passion-profiles-naples-soap-company-fl/

Click to expand...

Just because it is done, does NOT make it right. I could show you dozens of Etsy shops that violate the FDA. As a matter of fact I could probably go into any commercial store that sells health and beauty products and find at least one that is mislabeled.

You see there is no one who walks around and actually inspects these products. Unless something brings the label to the FDA's attention, the FDA will probably never know, that still doesn't make it right or legal. It only means that because of the number of products out there the majority will get away with it.

Places like LUSH put full labels of what you buy and the ingredients on the bag that holds the bathbomb or soap.

Why not make cute little labels on stiffish cardboard with a hole in it and tie or stick them to the bathbomb wrapping?

You could wrap them in small cello bags and either use a stickie label on the bag or a card in the bottom of the bag. I would cut the card the size of the bottom of the bag so it adds support and serves as a label. This way you get a label that supports the bag. I make my bombs cylinder shape, shrink wrap them and use round labels.

Tgool said:

To which I am wonder if you come up with paper wrapping just for your bombs, that is printed with the name of the products, along with the ingredients all over it in a colourful way? that way any paper you pull to wrap the bomb with will have the ingredients written all over it, and too easy to do. (Think of how some fast food places wrap sandwiches with a paper that has their logo and other things all over it.

It is always to be as cautious and as safe as possible when makin products a person could eat or put on their skin, so could this possibly be a workable so,union for you?

Click to expand...

That's a really cool idea! Definitely an option I didn't think of! Thanks so much!!

Soapsense said:

I Walk by this shop when on vacation, in fact I will be there next week, notice in the picture their bath bombs are in baskets not wrapped and not labeled.?????

http://justicefergie.com/2013/06/passion-profiles-naples-soap-company-fl/

Click to expand...

The work around here is that they don't have a wrapper - so the owner of the store has to make sure there is a brochure or flyer of some sort to send out with each item. I send mine wrapped in shrink wrap, which negates this as a possibility because the wrapper then becomes the "Outer wrapping or container"

As Dorymae added - there is a chance this isn't done "legally", but as long as the seller gives the shop keeper a brochure/flyer/card for each item, and that shop keeper passes that onto the customer - it's actually legal!

You lovely's have given me a few ideas. Right now I visited a label maker in Dallas to see how much it would cost to have a dozen different labels done. I've had to decrease what bombs I offer to my wholesale customers - but hey, it's taking off, so I might as well take the right steps now and not get myself in trouble! I know the chances of someone from the FDA knocking on my door are pretty slim, however, I don't play like that ;-) I like everything to be done right!
I'll update you guys on how much the quote is... and what steps I've taken.

You could also get the Avery business cards from walmart and print everything on them, punch a hole in a corner, and tie them to the bath bomb if you use cello bags to package them. Or even cut your own labels out of card stock paper.

I want to say that I didn't post that because I thought it was right or legal, that was the reason for my question marks at the end, I should have been clearer. I posted it because I didn't understand how they are able to do it as this is a company with 6 large retail shops in Florida that have been in business for quite a few years. We also have a resort here where I live with a seven floor gift shop that does the same thing, and has been for as long as I can remember.

MsAlexisClare said:

You lovely's have given me a few ideas. Right now I visited a label maker in Dallas to see how much it would cost to have a dozen different labels done. I've had to decrease what bombs I offer to my wholesale customers - but hey, it's taking off, so I might as well take the right steps now and not get myself in trouble! I know the chances of someone from the FDA knocking on my door are pretty slim, however, I don't play like that ;-) I like everything to be done right!
I'll update you guys on how much the quote is... and what steps I've taken.

Click to expand...

Ahhh...but they could visit your web site. A few years ago we had a FDA inspector purchase a large amount of our products for our website.