Aftershave alcohol

[cmzaha]

:???:
cmzaha, are you always this nasty?

Sorry not being nasty, just wondering why such a question would be asked. Sales on the internet are not above following the rules. and I happen to be a stickler for rules. If you think you cannot be found if doing only internet sales one could have a rude awakening. A few years ago we had a large order come in and it turned out to be an inspector from the FDA. We never knew if she just wanted the products herself or if they were actually tested and inspected. Never heard back from them
FDA will send out a warning letter, ATF can throw your backside in jail for selling alcohol illegally and I asked such a question since there were already several answers to the question
prior to your asking

 

[lillybella]

Sorry not being nasty, just wondering why such a question would be asked. Sales on the internet are not above following the rules. and I happen to be a stickler for rules. If you think you cannot be found if doing only internet sales one could have a rude awakening. A few years ago we had a large order come in and it turned out to be an inspector from the FDA. We never knew if she just wanted the products herself or if they were actually tested and inspected. Never heard back from them
FDA will send out a warning letter, ATF can throw your backside in jail for selling alcohol illegally and I asked such a question since there were already several answers to the question
prior to your asking

You ASSUMED that was WHY I was asking. It was NOT at all.

 

[froggybean37]

This post is perfectly timed as I just had a special request for aftershave and am starting to look into it. I'm embarrassed to say I have no idea where to start! The client wants an astringent type aftershave (so not a lotion), so I was thinking of also going the alcohol/witch hazel route, would you need something like PS80 to incorporate EO/FO? What % of alcohol : witch hazel : distilled H20 is generally a good starting place?

 

[kchaystack]

Sorry not being nasty, just wondering why such a question would be asked. Sales on the internet are not above following the rules. and I happen to be a stickler for rules. If you think you cannot be found if doing only internet sales one could have a rude awakening. A few years ago we had a large order come in and it turned out to be an inspector from the FDA. We never knew if she just wanted the products herself or if they were actually tested and inspected. Never heard back from them
FDA will send out a warning letter, ATF can throw your backside in jail for selling alcohol illegally and I asked such a question since there were already several answers to the question
prior to your asking

I did not see anything nasty at all in the question, and you are quite right to point out that if a sale crosses state lines not only could it be a state felony, but it becomes a federal felony. I have family members with personal experience about how bad that can mess with your life.

 

[Dorymae]

You ASSUMED that was WHY I was asking. It was NOT at all.

Then to be fair, why were you asking? If it was because you we're not sure if the rules applied to internet sales, she covered that. Honestly I don't believe she was being mean, just trying to give you the facts. Most of us do not tippy toe around subjects here, and we rarely sugar coat things.

You ASSUMED she was trying to be mean. This is the problem with the internet, as you can not see facial expressions, and body language when people reply. However, most people here are very helpful and certainly not trying to hurt your feelings.

 

[The Efficacious Gentleman]

My post from earlier seems to have gone walkies. But as the regulations have been pretty well covered, I was also wondering what exact part of the regulations led to that question. Having read the information and links already provided, something in there might well have sparked the idea and it's worthwhile posting exact parts of the regulations that you read that you are then questioning further, to make sure that people don't think you're referring to a different place

 

[MtnSoaper]

I'm embarrassed to say I have no idea where to start! The client wants an astringent type aftershave (so not a lotion), so I was thinking of also going the alcohol/witch hazel route, would you need something like PS80 to incorporate EO/FO? What % of alcohol : witch hazel : distilled H20 is generally a good starting place?

To start, my understanding is that using an alcohol based witch hazel or denatured alcohol will require a permit if you are indeed selling this item.
(I'm still trying to find a reliable & definitive answer about using high proof consumable alcohol, but I'll save that for yet another post.)

As for the formulation, I would keep the EO/FO low as aftershave is applied to the face (near the nose). I'd start with 1-2% and see how you like that. PS80 may not be needed if the alcohol is high enough to solubilize the EO/FO. A little glycerin would be nice--I'd try 5% to start; you don't want it to be sticky. As for water--check the % in your alcohol base. I'd be concerned with dropping the alcohol much below 75% as things may go cloudy. And if they do, readjust with more alcohol--and keep good notes.

Hope this didn't digress too far.

 

[IrishLass]

Yep, if the alcohol is high enough, there's no need for an emulsifier.

Here's my own recipe for an astringent aftershave to help give you an idea of some good percentages to work off of (at least they are good percentages to my hubby and son, whose feedback guided me). I don't sell this of course, by the way. I only make it for my hubby and for my son for private/home use in small 3oz. batches at a time each as needed, but for whatever light it might shed in helping you to formulate your own, it contains:

50% 190-proof Everclear
20% Aloe vera juice (the George's brand from my health-food store)
15% witch hazel (which already contains some alcohol in it)
12% SD70 alcohol (hubby and son insisted on it's inclusion because they like the smell of it in the aftershave, otherwise I would have left it out and used Everclear as my total alcohol amount)
3% vegetable glycerin

The above percentages total to 100%. I add my fragrance as an extra. As MtnSoaper said, it's best to keep the scent low, but thankfully, not much is needed to get a good scent throw in aftershave. Depending on the FO, I add between .5% to 1% as per the weight of my formula (no emulsifier needed).

IrishLass

 

[snappyllama]

Teg, I've fiddled around with a recipe for an aftershave that's primarily witch hazel with various humectants and poly to emulsify the fo. I seem to have misplaced my notes on my computer . Grr. Suffice to say, I wasn't really happy with my outcome... It kept looking cloudy and felt either too sticky or not moistening enough. I rejected a couple dozen variations. I'll look for my handwritten notes to post them to at least help folks avoid repeating my failures.

My storage area (where my handwritten notes ought to be hiding) is in the midst of a house remodel. Hopefully I'll be able to get to it soon.

I'd love to hear anyone else's recipe or at least a good direction for an alcohol free one.

 

[lillybella]

Yep, if the alcohol is high enough, there's no need for an emulsifier.

Here's my own recipe for an astringent aftershave to help give you an idea of some good percentages to work off of (at least they are good percentages to my hubby and son, whose feedback guided me). I don't sell this of course, by the way. I only make it for my hubby and for my son for private/home use in small 3oz. batches at a time each as needed, but for whatever light it might shed in helping you to formulate your own, it contains:

50% 190-proof Everclear
20% Aloe vera juice (the George's brand from my health-food store)
15% witch hazel (which already contains some alcohol in it)
12% SD70 alcohol (hubby and son insisted on it's inclusion because they like the smell of it in the aftershave, otherwise I would have left it out and used Everclear as my total alcohol amount)
3% vegetable glycerin

The above percentages total to 100%. I add my fragrance as an extra. As MtnSoaper said, it's best to keep the scent low, but thankfully, not much is needed to get a good scent throw in aftershave. Depending on the FO, I add between .5% to 1% as per the weight of my formula (no emulsifier needed).

IrishLass

I was confused & I am still confused.

My interpretation: the above recipe for an astringent aftershave could be sold without approval by the ATF.

 

[The Efficacious Gentleman]

In theory, but subject to state law, certainly - which is why online could actually be a nightmare for you in some ways.

As has been said, one way to be 100% certain is to call them up and ask them

 

[lillybella]

I am going to call today.

 

[cmzaha]

IrishLass makes it just for her families private use. You can make whatever you want as long as you are not selling it. Even from AFT do not take word of mouth to the bank. If you decide to sell you want everything in writing. Word of mouth will usually not stand up in court

 

[IrishLass]

IrishLass makes it just for her families private use. You can make whatever you want as long as you are not selling it. Even from AFT do not take word of mouth to the bank. If you decide to sell you want everything in writing. Word of mouth will usually not stand up in court

Ditto what Carolyn said. I don't sell it. I make the aftershave exclusively for my hubby and son only (who are so incredibly spoiled to have products designed just for them! ).


IrishLass

 

[lillybella]

Ditto what Carolyn said. I don't sell it. I make the aftershave exclusively for my hubby and son only (who are so incredibly spoiled to have products designed just for them! ).


IrishLass

Yes I understand this.

I just sent an email to the the ATF with a couple of recipe templates & my questions & concerns; so I can receive a written reply. I will post it when I receive it.

 

[MtnSoaper]

Yes I understand this.

I just sent an email to the the ATF with a couple of recipe templates & my questions & concerns; so I can receive a written reply. I will post it when I receive it.

I look forward to hearing their reply. I'm waiting to hear back from NYS (I work backwards. After all, who cares what the Feds have to say if the state poo-poos it!).

But until them, how about a little light reading:

Alcohol in the US is regulated for a number of reason but the most important is for taxation; the government wants their money. Anyone planning to sell alcohol for human consumption needs a license. This goes for the wineries, the breweries, the distilleries, the restaurants, and the retail outlets. The government does allow (tax and permit free) the head of a household to make a limited amount of wine or beer for consumption on the property on which it was made, as long as the head of household is at least 21 years of age and provided they don’t make more than (I believe) 200 gallons per year. (Don’t quote me on that amount. I make my own wine and beer but have never even come close to that amount!)

You also need a permit/ license to sell non-consumable products (lotion, aftershave, cologne, etc.) made with denatured alcohol. I believe you are allowed to buy, without a permit, up to 5 gallons per year for formulation—but, you can’t turn around and sell it without the proper permit. Why? Because of taxes. The government, by giving you the permit to sell, is allowing you to buy tax-free alcohol. They want the paper trail so they can make sure that every drop you buy is going into your non-consumable product. You see, denatured alcohol can be distilled back into a consumable product which would bypass the taxes they require for consumable alcohol.

Rubbing alcohol and alcohol-based witch hazel from the drug store would be off limits as well. Why? The paper trail has ended with the drug store (there’s no record that you purchased it and didn’t use it to make bathtub gin).

The confusion for me arises with this:
1. The government has very strict laws for the manufacture and sale of consumable (tax-paid) alcohol.
2. The government has very strict laws for the manufacture and sale of non-consumable (tax-free) alcohol.
3. I have yet to find any guidelines for using a consumable (tax-paid) alcohol in a non-consumable product. After all, you’re paying the taxes on a product that you could, through the proper channels, make tax-free.
4. Marie Gale implies in her book that vodka and Everclear can be used in products for sale. . . . Whether or not there’s a permit required is the question (at least for me).

So why do I want to use Everclear and not perfumers or denatured alcohol? It’s cheaper. Even with the hefty taxes that are built into the price, it’s cheaper than buying denatured alcohol online and paying the hazmat fees.

Please, if anyone can clarify any of this or set me right, please do so. This is all in the interest of polite discussion!

 

[lsg]

SaveOnScents sells perfumers alcohol. They explain in detail, the requirements. If you are not reselling and order less than 5 gallons in a calendar year, then you don't need a permit. If you order less than 5 gallons in a calendar year and use this alcohol in a recipe with other ingredients to make after shave or a product you sell, then you can file a user's permit.

http://www.saveonscents.com/product_info.php/products_id/3572

 

[MidwestSoaper]

I've been looking into the legalities as well. Check out this link:

http://www.ecfr.gov/cgi-bin/text-id...true&tpl=/ecfrbrowse/Title27/27cfrv1_02.tpl#0

especially the following:


I'm not a lawyer, but it is my understanding that since Everclear is tax-paid, and perfumes/ colognes are nonbeverage products, you wouldn't need a permit. . . at least from the Feds. On the state level, it gets rather complicated as each state has it's own laws. I'm still trying to understand NYS but plan on contacting someone at some point.

As for selling products made with SDA, it is my understanding that you need a permit because it is purchased tax-free and therefor needs a paper trail to verify that it is not being used for beverage related products. I gather that SDA can easily be un-denatured in the right hands.

The ATF issues permits through the Tax and Trade Bureau (TTB) http://www.ttb.gov/ for anyone that sells a product made with alcohol regardless of whether you use everclear, rum, vodka, or one of the SDA formulas. SDA contains chemicals that make it nonpotable and it cannot be made drinkable.

TTB has acceptable formulas to follow if you are making perfume, aftershave, toner, splashes, lotion, linen sprays; essentially anything that contains alcohol. If you do not follow their guidelines for your product, then you have to submit a sample of each product to their designated lab and that formula has to be approved prior to offering it for sale to the public.

There are 2 types of permits that apply to bath and body businesses. One is a users permit for anyone purchasing alcohol to manufacture products for sale. The other is a dealers permit for those selling alcohol to manufacturers of products containing alcohol.

Federal laws regarding distribution of alcoholic products apply to all states and all size businesses. Your state, county or local municipality may have additional regulations or restrictions.

Also keep in mind that since alcohol is classed as a hazardous substance, there are additional federal regulatory agencies involved such as DOT, USPS, FAA. For example to mail perfumes there are flashpoint and volume restrictions that may prevent using the USPS or sending the package by air. What you cannot send via regular mail, you have to send via ground transportation and follow appropriate package markings required by DOT. hth

 

[lillybella]

I see lots of shops on Etsy & Amazon selling aftershaves (with alcohol) & shipping via USPS essential oils. BB listed a recipe for an aftershave:
http://soapqueen.tumblr.com/post/80273451460/from-now-until-march-26th-well-showcase

contains Isopropyl Alcohol - does this count as alcohol?

She adds a note:
**NOTE: If you plan on selling your aftershave, leave the rum out. Even though you can’t drink it, you wouldn’t want to run afoul of liquor distribution laws.
She's saying that by leaving the Rum out this is ok to sell.

This is so confusing & complicated. I can't believe (more like I don't want to believe) that so many shops are violating the ATF requirements.