FDA labeling

[NMAriel]

I don't have very good luck trying to find something using the search function, so if this has been discussed before I apologize.

Can our soap labels say something like "cleansing, healing, softening, exfoilating, nourishing, revitalizing, oil absorbing". I'm sure there are more descriptions, but those are the ones I can think of.

What is allowed, and what is not allowed? I know if can't say we cure something, but do the words above cross the line? thanks.

 

[Deda]

http://www.cfsan.fda.gov/~dms/cos-218.html
http://www.cfsan.fda.gov/~dms/cos-lbl.html

These two links should get you started. How you label your soap determines whether or not it's a soap or a cosmetic.

 

[Tabitha]

There are diff label requirments for soaps vs cosmetics vs drugs.

You may be selling soap, but when you use words like *healing* you have just made a medical claim & have to label a sa drug & meet those standards.

You may be selling soap but

If a product --

consists of detergents or
primarily of alkali salts of fatty acids and
is intended not only for cleansing but also for other cosmetic uses, such as beautifying or moisturizing, .

You are marketing it as a cosmetic & must label it like a cosmetic & meet those standards.


The FDA is not black & white, it is all subjective but here are the 2 links I find most helpful:

http://www.cfsan.fda.gov/~dms/cos-218.html
Is It a Cosmetic, a Drug, or Both?
(or Is It Soap?)

http://www.cfsan.fda.gov/~dms/cos-lab1.html
Summary of Regulatory Requirements for Labeling of Cosmetics Marketed in the United States.

I do not know if they are the same 2 links Deda posted or not. I was too lazy to click on them :? .

 

[NMAriel]

Thank you. I read the links, and they don't really spell out words not to use. I wish they did, that would at least limit things down.

 

[andreabadgley]

Thank you Tabitha and Deda for those links - I've been wondering about this myself.

 

[angbaby4974]

Thank you. I read the links, and they don't really spell out words not to use. I wish they did, that would at least limit things down.

This part in particular should help you

If a product --

* consists of detergents or
* primarily of alkali salts of fatty acids and
* is intended not only for cleansing but also for other cosmetic uses, such as beautifying or moisturizing,

it is regulated as a cosmetic.

If a product --

* consists of detergents or
* primarily of alkali salts of fatty acids and
* is intended not only for cleansing but also to cure, treat, or prevent disease or to affect the structure or any function of the human body,

it is regulated as a drug.

So, basically if you market it as "healing, softening, exfoilating, nourishing, revitalizing, oil absorbing" etc. then you have just placed your product in the cosmetic &/or drug categories.
At least that's my take on it.

 

[Sonam]

Thanx so much!! I've been wondering too.

 

[NMAriel]

But if you list an ingredient and say what it's for, then that's ok? )IE: green clay, known for oil absorbing properties.) I've seen that type of stuff on peoples websites, and labels. What do you think.