# From soap to B&B



## gbtreasures (Nov 5, 2007)

Question:  When making a claim on a product you sell such as cleanses, moisturizes, etc., what do you need to consider?  I think it becomes a cosmetic at this point.  How do you label the ingredients?  Is production facility an issue or can you still operate producing cosmetics from your basement?  Are bath fizzes, lotions, lip balms, etc. the same as soap if you bypass any claims on them?  Thank you for the info. I don't understand the differences. :?:


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## Tabitha (Nov 5, 2007)

I am no expert on FDA requirements, but here goes:

1) All ingredients in all cosmetics must be listed in order of greatest to smallest qty. Once you get down to ingredients that are 2% or less they no longer have to be in order.

2) Ingredients must be listed by their formal INCI names http://en.wikipedia.org/wiki/International_Nomenclature_of_Cosmetic_Ingredients#Table

3) If you make any sort of medical claim it stops being a cosmetic & becomes a drug.  EX) We all make our lip balm to soothe dry lips. Most everyone buys it to soothe dry lips, it's an *understanding*, just do not state that on the label. People do *get around* it by saying things like "for millions of years people have used ingredient X to heal dry lips, now I am offering the same product in a tube, etc etc" or "Many studies show the use of ingredient X to be an excellent soother for your lip, etc, etc" It's all side stepping. You just can't say my lip balm will heal your lips, you are no Dr. & your lip balm is not a drug.

4) If you use the word edible it stops being a cosmetic & becomes a consumable product & you will need food handling license & what not, EX) do not label an item edible massage oil, use the term flavored massage oil.

5) All products must have your full business name & full mailing adrress on the label unless you can be looked up in the phone book. Ivory Soap Co Boston MA.

6) All products must have a disclaimer similar to *The safty of this product has not been determined by the FDA Discontinue use if irritation or redness occurs. "

7) You must list directions for use of product. 

That will get you started but I suggest you read the FDA website on cosmetics & see what you get out of it. It's not a black & white, cut & dry website.

The above is just my interpertation of what I have read on the site & picked up over the years.


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## gbtreasures (Nov 5, 2007)

Thanks, Tabitha, for explaining it as well as you have.  Can you make cosmetics in your home as you do soap?  I have seen e-mail addresses on labels.  Is this the same thing as listing your address?  Thanks!!


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## edco76 (Nov 5, 2007)

Tabitha said:
			
		

> I am no expert on FDA requirements, but here goes:



Coulda fooled me. lol Great explanation Tabitha.


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## Bret (Nov 6, 2007)

I don't have my address on anything. Too many crazy people out there... Once I start selling more, I might do a po box if I need to, but no one is getting my home address. Half of that stuff wouldn't even fit on some labels!


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## Tabitha (Nov 6, 2007)

Honestly, I did not place my address on anything prior to gettting a storefront. I did post a web address & figured I would play dumb if I got smacked by the FDA. It is important to have *some* sort of contact info though incase their *is* a reaction you can be found and they can find out what was in the product.


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## Bret (Nov 6, 2007)

Let me add, I do have my etsy address and email on there.


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