Cleaning Products-Registration Issues

[Guest guest]

So, can I state that the products include ingredients with

antibacterial and antiviral properties? I thought by doing this, I'm

claiming proven facts about the ingredients, and that would keep me

legal.

 

Thanks

 

Christine

 

Soul Kitchen Naturals

 

www.skc-mt.com

 

 

Dear Christine,

 

While the use of botanicals is still largely unregulated in the U.S. you run

into a definite gray area when making claims of antibacterial, antimicrobial,

antiviral, etc for your products.

The EPA regulates cleaners making antibacterial claims, it is considered a

pesticidal agent and registration is required. 

 

Please see the links below for more details:

 

Purdue University-

http://ppis.ceris.purdue.edu/htm/links.htm

 

Regulating Antimicrobial Pesticides-

http://www.epa.gov/oppad001/index.htm

 

With regards to proven facts, whose facts?  Do you have efficacy studies?

Rachel A. MarkelManaging PartnerEOILCO LABORATORIES,

LLCwww.eoilco.comhttp://ingredientmanager.eoilcolab.com

www.GreenTerpene.com

 

 

 

[Guest guest]

Christine,

 

I am not certain what regulations on antimicrobial claims are now in

place in the USA, but it looks like they are going in the same

direction as the European ones. Under our regulations you cannot make

such claims unless they are 1. Scientifically validated. 2. The

antimicrobial substance has been registered and approved for use in

products. 3. That the cosmetic product has been inspected and

certified by a " competent person " .

 

Many essential oils are proven antibacterial and antifungal with loads

of research to back that. However, hardly any are proven anti virals,

that is all trade hype. If you are making products with a water base

then you may need to use herbal extracts to make such a claim. For

example, Tea Tree oil is widely touted as " anti viral " but in reality

it is the water or alcohol extract only that has anti viral activity.

Same holds good for many herbs.

 

The best thing you can do is ask the regulators what you can and can't

claim. At least if you ask them, and get something in writing, they

can't then come after you for breaching regulations.

 

Martin Watt

 

ATFE2 , Rachel Markel <ramarkel wrote:

>

> So, can I state that the products include ingredients with

> antibacterial and antiviral properties? I thought by doing this, I'm

> claiming proven facts about the ingredients, and that would keep me

> legal.

>

> Thanks

>

> Christine

>

> Soul Kitchen Naturals

>

> www.skc-mt.com

>

>

> Dear Christine,

>

> While the use of botanicals is still largely unregulated in the U.S.

you run into a definite gray area when making claims of antibacterial,

antimicrobial, antiviral, etc for your products.

> The EPA regulates cleaners making antibacterial claims, it is

considered a pesticidal agent and registration is required.

>

> Please see the links below for more details:

>

> Purdue University-

> http://ppis.ceris.purdue.edu/htm/links.htm

>

> Regulating Antimicrobial Pesticides-

> http://www.epa.gov/oppad001/index.htm

>

> With regards to proven facts, whose facts? Do you have efficacy

studies?

> Rachel A. MarkelManaging PartnerEOILCO LABORATORIES,

LLCwww.eoilco.comhttp://ingredientmanager.eoilcolab.com

> www.GreenTerpene.com

>

>

>

[Guest guest]

The best thing you can do is ask the regulators what you can and can't

claim. At least if you ask them, and get something in writing, they

> can't then come after you for breaching regulations.

>

> Martin Watt

 

 

That's great advice Martin, I would encourage anyone with questions to

consult the EPA or the FDA. I have worked with several individuals at

the EPA in an effort to get my clients products into store shelves and

to market them via the internet. Don't be bashful, they are very user

friendly!

 

I also wanted to clarify a small point related to products sold in the

U.S. There is somewhat of a " gray, " area with regards to

antibacterial/antimicrobial products.

 

Antibacterial (also known as Antimicrobial)A general term that

describes a product that kills or inhibits the growth of bacteria in

foods or on inanimate surfaces or hands.

 

Types of Antibacterial Cleaning Products:

Antimicrobial (germ-killing) cleaning products used in the home fall

into two general categories:

 

1. Personal Cleansing Products - Antibacterial soaps or washes that

are formulated to kill or inhibit certain bacteria on the hands or

body. The FDA regulates antibacterial soaps as over-the-counter drugs.

 

2. Antimicrobial Household and Commercial Cleaning Products - These

are formulated to kill germs on inanimate surfaces. The U.S.

Environmental Protection Agency (EPA) regulates antimicrobial

household cleaning products.

 

 

Be well,

 

Rachel Markel

Managing Partner

www.eoilcolab.com

www.GreenTerpene.com

www.eoilco.com