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Well, it is kind of hard understanding all the info on this page:

http://www.cfsan.fda.gov/~dms/cos-lab3.html#clgg

 

I have a few questions that would be great if they could be answered in

plain English:-) instead of FDAese:

 

1: What is the definition that causes a product to be either a cosmetic or

a drug? Particularly, if someone wants to sell a massage oil for

'invigoration' or 'stress relief', or a salve for wound healing or pain

relief, what criteria does the FDA use to determine the classification?

 

2: On the label info given on the fda site, what is meant by " placement of

information " on labels? It sounds like there are actual areas (upper right

corner, lower left corner) that you need to place your blocks of

information in. I usually see the manufacturer's name and address on the

bottom of either the left or right side of the label, but that isn't always

the same.

 

3: Where is the information that I've heard often that if you have less

than 1% of an ingredient, you don't have to list it.

 

4: I understand that there are now standardized botanical names that you

have to list, along with the common names. Can't find that info, either.

 

5: What protects and defines " trade secret " ?

 

I'm asking this on behalf of a lady here in Miami who opened a shop using

the labels of the con artist who sold her the franchise. She is endeavoring

to get everything legit, and I'm hoping this group can help her. She's

lurking here, since she doesn't have much experience with , and

is also having a lot of trouble logging into her hotmail account, so she

can at least read the answers on the website, if not answer them.

 

Thanks for all your help in advance. Her shop is only about six weeks old,

and she now realizes that she needs to fix up the labels on the products.

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Hi Anya,

 

I'll try to answers these for ya.

 

> I have a few questions that would be great if they could be

answered in

> plain English:-) instead of FDAese:

>

> 1: What is the definition that causes a product to be either a

cosmetic or

> a drug? Particularly, if someone wants to sell a massage oil for

> 'invigoration' or 'stress relief', or a salve for wound healing or

pain

> relief, what criteria does the FDA use to determine the

classification?

>

 

If the product does something to the skin, namely beautify it, it is

a cosmetic. If you make a claim for it to do something, like heal,

have an spf of 20 or the like it then becomes a drug. You can call

your massage oil " invigoration " and not make any drug claims and it

would be considered a cosmetic. Your salve could not state that

it " will heal " or it will become FDA territory and you will have to

substantiate it with testing and proof. It would be a drug. What you

can say about it, is that (lets use calendula) that it contains

calendula which has been used for centuries to help heal burns, minor

skin irritation etc.. But you are not actually saying " My product

will heal your owies " .

 

 

> 2: On the label info given on the fda site, what is meant

by " placement of

> information " on labels? It sounds like there are actual areas

(upper right

> corner, lower left corner) that you need to place your blocks of

> information in. I usually see the manufacturer's name and address

on the

> bottom of either the left or right side of the label, but that

isn't always

> the same.

 

Thats a good one. Just make sure your business name is on it, your

address, ingredients in order of predominance and of course product

name. Oh ya, and the weight of the product.

>

> 3: Where is the information that I've heard often that if you have

less

> than 1% of an ingredient, you don't have to list it.

 

Not true this one. List it all in order of predominance.

 

>

> 4: I understand that there are now standardized botanical names

that you

> have to list, along with the common names. Can't find that info,

either.

 

There are some and it is not required that you use them. You can

list Calendula extract as just that.

 

 

> 5: What protects and defines " trade secret " ?

 

Not sure bout that one, except that perfumers use it to protect their

scent blend. Really, like anyone could make the same blend just

knowing that there were 10 different eo's in it. Waste of time and

money. Or perhaps its a legal way to " hide stuff " from us. Hmmmm....

 

Hope all goes okay for the gal with the shop. A really good group

for straight forward info on all the legalities of cosmetics and

their manufacture including labeling is

Cosmeticinfo They have archives of all of this

information and much more.

 

Hth a little,

Margaret

www.naturalindulgences.com

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At 06:26 AM 3/18/2004 -0000, you wrote:

>Hi Anya,

 

Hi margaret -- I had to search for your name at the end, otherwise I

thought you were plumberboy! LOL

you wrote:

>If the product does something to the skin, namely beautify it, it is

>a cosmetic. If you make a claim for it to do something, like heal,

>have an spf of 20 or the like it then becomes a drug. You can call

>your massage oil " invigoration " and not make any drug claims and it

>would be considered a cosmetic. Your salve could not state that

>it " will heal " or it will become FDA territory and you will have to

>substantiate it with testing and proof. It would be a drug. What you

>can say about it, is that (lets use calendula) that it contains

>calendula which has been used for centuries to help heal burns, minor

>skin irritation etc.. But you are not actually saying " My product

>will heal your owies " .

 

Thanks for the 'cosmetic v. drug' definition. I think you might be wrong

with the caution on claims. That all changed last July when there was a

successful lawsuit against the FDA. It'sa First Amendment issue about free

speech. If you put a disclaimer on the product such as " The claims make

about thisproduct have not be evaluated or tested by the FDA " you can make

claims. I have a long reprint from Herbalgram, with all the legal

citations. If you buy any vitamins or supplements, or 'whatever' from the

health food store, look for the new disclaimers.

 

>> 3: Where is the information that I've heard often that if you have

>less

>> than 1% of an ingredient, you don't have to list it.

 

>Not true this one. List it all in order of predominance.

 

Not true?? Wow, I have to search for my reference. This is a mystery. I

know that many low-carb foods can actually hide carbs because the

manufactuers do't have to list the carbs/serving if it's under one, but

some people complain if they eat a lot of the food and get an accumulation

of carbs :-) I guess 10 diet sodas can throw you out of ketosis, LOL.

 

>> 4: I understand that there are now standardized botanical names

>that you

>> have to list, along with the common names. Can't find that info,

>either.

 

>There are some and it is not required that you use them. You can

>list Calendula extract as just that.

 

OK, that is good. I've been seeing so many botanic names cropping up, in

addition to my faulty memory again thinking I had seen some legislation on

that matter, I got confused.

 

>Hope all goes okay for the gal with the shop. A really good group

>for straight forward info on all the legalities of cosmetics and

>their manufacture including labeling is

>Cosmeticinfo They have archives of all of this

>information and much more.

 

I'm going to check into them myself. Now we need a group Druginfo@ for

those who want to market their kava kava or mullein extracts!

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Hi Anya,

 

 

>Hi margaret -- I had to search for your name at the end, otherwise I

>thought you were plumberboy! LOL

 

Funny! I wasn't getting my mail from and so had to reply via online

at the groups site. Actually my hubby is the plumberboy, and we, myself and

kids are the family part. lol

 

 

>Thanks for the 'cosmetic v. drug' definition. I think you might be wrong

>with the caution on claims. That all changed last July when there was a

>successful lawsuit against the FDA. It'sa First Amendment issue about free

>speech. If you put a disclaimer on the product such as " The claims make

>about thisproduct have not be evaluated or tested by the FDA " you can make

>claims. I have a long reprint from Herbalgram, with all the legal

>citations. If you buy any vitamins or supplements, or 'whatever' from the

>health food store, look for the new disclaimers.

 

Looks like I might have to find some time to look into this one myself. I

do know that there are different rules for food stuffs and cosmetics. I'll

see what I can find out.

 

 

>Not true?? Wow, I have to search for my reference. This is a mystery. I

>know that many low-carb foods can actually hide carbs because the

>manufactuers do't have to list the carbs/serving if it's under one, but

>some people complain if they eat a lot of the food and get an accumulation

>of carbs :-) I guess 10 diet sodas can throw you out of ketosis, LOL.

 

Once again, food labeling requirements may be quite different than cosmetic

requirements. I put citric acid in my lotions at about one quarter of a

percent and it definately has to be listed as does the preservative, which

once again is much less than 1%.

 

I'll peruse my cosmetic labeling handbook next chance I get, which could be

a while, but will post again if I find out any concrete facts to report. :)

 

Have a great day all,

Margaret

 

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