# How do describe an acne bar w/o violating regulations?



## sudbubblez (May 12, 2012)

How can someone describe a soap like this without being regulated as a drug?  I understand you can't say that on the label or even in the online description.  Cant even say anything like "moisturizing" without it being classified as a cosmetic.  I chose the ingredients and percentages specifically for benefit against acne; neem, kokum butter, jojoba, babassu .  Is there a way around this, like describing the properties and popular uses of each of the ingredients?  For example: kokum butter is rich in fatty acids which aid in cell oxygenation and is non-comedogenic.    Is it a violation to put testimonials from my guinea pigs in the description that go like "Omg this cleared up my backne!"  I've seen lots of sellers that go ahead and make claims anyways...  I don't want to make any specific claims, because theres no one thing that works for everyone, just get the idea across that it was specially forumlated.


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## Genny (May 14, 2012)

If you want your soap to not be regulated by the FDA as a cosmetic, then the only thing you can say about your soap is, "It cleans."

Now if you don't mind it being considered a cosmetic, which all you have to do is change the way you label your soap, then you can say it moisturizes.

Can you say that it helps with acne or even hint towards that? No.

Can you say that the ingredients are known for helping with acne? No.  Because then you are saying, "Since kokum butter helps with acne, and my soaps contain kokum butter, then my soaps must help with acne."

Can you show testimonials that your soap cleared up acne for a customer? No.   

Go here and read "How is a Product's Entended Use Established?"
http://www.fda.gov/Cosmetics/GuidanceCo ... 074201.htm


There is no legal way of saying or even hinting that your soap could help acne.


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## sudbubblez (May 14, 2012)

Gosh this is frustrating.  I see so many online sellers that say this stuff anyways.  I just want to get the idea across that there was special consideration into the ingredients.  I can list the ingredients but the general public is not going to know what qualities each one brings to the soap.  Its like why even bother with specialty ingredients if you can't even say why there there.

Wihout saying the word acne can something like "Made with non comedogenic oils and antiseptic tea tree" be used, even if it does then make it cosmetic?

Oh, great link.  Excellent resource and its now part of my bookmarks.


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## Genny (May 15, 2012)

I don't think you can use "non-comedogenic" since the definition of comedogenic is "Tending to produce or aggravate acne".  

I'm honestly not sure about using "antiseptic".

I'm sure it can be frustrating if you're trying to sell products for different skin problems.  I don't make any body products for sale for skin problems for the exactly this, "Its like why even bother with specialty ingredients if you can't even say why there there."

I save those products to give to family and the occassional close friend.
I've had customers ask me for B & B items to help with acne, eczema, diaper rash, I just explain to them that legally I can not make any claims.  Most seem to respect that.

I know there are 1,000's of other B & B'ers that knowingly don't follow regulations and I think to myself, "If they're so nonchalant about that law, how many other laws do they break?"


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## new12soap (May 15, 2012)

I thought non-comedogenic just meant doesn't clog pores?

Here's what I don't understand... I stopped in the vitamin store today, and vitamins and supplements and herbal remedies and homeopathic medicines are NOT regulated by the FDA (apparently). They ALL say "for acne" or "for hot flashes" or "for bowel health" or whatever on the front of the package, then on the back is the standard disclaimer "These statements have not been evaluated by the FDA and are in no way intended to diagnose treat or cure any medical condition..."

HOW can they possibly get away with that when you can't even say soap is anything other than soap? Very frustrating indeed!


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## Lindy (Aug 24, 2012)

This is a very old thread that I am re-starting to address the cosmetic issues as well as what you see in Health Food Stores.

There are always going to be people who like to skip around the law, okay blatantly ignore it.  You can claim the oils you are using do not clog the pores of your skin.  As a cosmetic, and there is nothing wrong with being classified that way.  It does give you more room.  As a cosmetic product you can call your soap a facial soap, or a complexion bar.  Now there is one thing I do need to clarify - I'm in Canada and our laws are such that soaps are a cosmetic.  Now if you start making claims that your soap gets rid of something it becomes medical and has all sorts of different regulations surrounding it.

In Canada natural medicine is governed under it's own legislation and I would expect it is the same in the US and that allows them to make "some" claims.

Oh yeah I wanted to mention - if you have a cosmetic product you can use terms like "may reduce the appearance of fine lines" and things like that.


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## Hazel (Aug 24, 2012)

Lindy said:
			
		

> In Canada natural medicine is governed under it's own legislation and I would expect it is the same in the US and that allows them to make "some" claims.
> 
> Oh yeah I wanted to mention - if you have a cosmetic product you can use terms like "may reduce the appearance of fine lines" and things like that.



It used to be this way in the US but there has been a recent change. The FDA is starting to enforce the distinction between whether a product is a cosmetic or drug and they are starting to contact sellers who are in violation. 

Helpful links for US based members

Is It a Cosmetic, a Drug, or Both? (Or Is It Soap?)
"Cosmeceutical"
Warning Letters
Warning Letters Address Drug Claims Made for Products Marketed as Cosmetics

An article about one online site which has started complying with the enforcement of FDA law. Etsy Removes Product Categories With Medical Claims

There won't be any more skipping around the law or ignoring it because the FDA will be enforcing compliance. It may take them awhile since the handmade market is so huge but eventually they will work their way through it.


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## judymoody (Aug 24, 2012)

How about "facial soap for oily skin"?


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## dirrdee (Oct 21, 2012)

oops, old post...sorry


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## sunfloweracres (Nov 15, 2012)

Slightly old post, but others are still reading it ... I did. Thank you for the FDA links. It seems soap makers are ok as long as we do not make any claims. We need to list all the ingredients and that's it. On the bright side, we are making true 'soap'. Commercial cleansing bars cannot label their bath bars/beauty bars 'soap' because they are basically detergent. We have that edge on them and can use it.


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