Questions about Labeling

[hmlove1218]

I'm trying to figure out how to label my soaps correctly. I understand that "soap" is not required to list any ingredients as it is not under FDA control. However, some of my soaps will have exfoliants in them, which means that they are regulated by the FDA because I plan to label them as "exfoliating soaps." I've been reading through the legal jargon on the FDA site and have one question that I can't find the answer to

FDA site states "The name and place of business of the firm marketing the product must be stated on an information panel of the label (21 CFR 701.12). The address must state the street address, city, state, and zip code. If a firm is listed in a current city or telephone directory, the street address may be omitted."

I make my soaps in my kitchen at home and would really prefer to not have my home address advertised. If my shop has a listing on yellowpages.com, would that count as a current city or telephone directory listing?

 

[lsg]

Do you have an e-store, if so, just put the email address of your store.

 

[AnnaMarie]

Soap Queen has some good posts on labeling. They translate a lot of the legal jargon for us which is helpful.
Cheers!
Anna Marie

 

[cmzaha]

Stating exfoliating on your soap will probably push it into the drug category and that is not a place to go. The book Soap & Cosmetic Labeling by Marie Gale is a very good reference. To keep products as soap or cosmetics you cannot state that they do something. Just a little note, if you think FDA will not find you think again especially if you do online sales.

 

[new12soap]

As I understand it, the answer is no. An online directory or website is not adequate, you must be listed in your local print directory. Otherwise the full address must be printed on the label, not a partial, not a P.O. Box, the actual physical address where the item is produced.

There are groups trying to change that for exactly the reason you stated, a lot of home-based businesses feel they are risking their personal safety to put their address out there on all their products.

I believe exfoliating falls under cosmetic, not drug. The distinction is that it is intended to change the appearance of skin, such as softening or "glowing", not to diagnose treat or cure a specific medical condition.

 

[hmlove1218]

As I understand it, the answer is no. An online directory or website is not adequate, you must be listed in your local print directory. Otherwise the full address must be printed on the label, not a partial, not a P.O. Box, the actual physical address where the item is produced.

There are groups trying to change that for exactly the reason you stated, a lot of home-based businesses feel they are risking their personal safety to put their address out there on all their products.

I believe exfoliating falls under cosmetic, not drug. The distinction is that it is intended to change the appearance of skin, such as softening or "glowing", not to diagnose treat or cure a specific medical condition.

Thank you. That answered my question. I figured that was going to be the answer unfortunately.. And this morning I saw one of the petitions on Soap Queen's website. But I may be able to rent a small building soon so that would solve that whole problem of listing my home address. Thank you again!