Bug repellent laws?
- Thread starter aab1
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Help Support Soapmaking Forum:
It's not illegal to make or sell a bug-repellent soap -- don't know where you got that info. You just have to jump through the hoops to market it as a drug, not as a soap and not as a cosmetic. Most people try to "weasel word" their way around meeting the requirements of marketing a product like this in a legal manner.
The FDA website has the specific info you need. Or check out Marie Gale's book which translates the FDA regs into understandable language.
The FDA website has the specific info you need. Or check out Marie Gale's book which translates the FDA regs into understandable language.
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Proceed with caution if you are going to sell. If just used for family, etc, you should be okay.
If you advertise (in print, online, by word of mouth or by any other means) that your product"kills", "repels", "protects against" or imply that the intended use of your product is to perform these functions, you are making a claimand thereby need to prove it through independent testing and registration of your product or face intervention by the FDA, FTC and/or EPA. --
http://bathbodysupply.blogspot.com/2011/06/guidelines-for-marketing-insect.html
If you advertise (in print, online, by word of mouth or by any other means) that your product"kills", "repels", "protects against" or imply that the intended use of your product is to perform these functions, you are making a claimand thereby need to prove it through independent testing and registration of your product or face intervention by the FDA, FTC and/or EPA. --
http://bathbodysupply.blogspot.com/2011/06/guidelines-for-marketing-insect.html
I was just reading an article that led to this from the EPA> http://www.epa.gov/oppbppd1/biopesticides/regtools/25b_list.htm
It has several conditions that if fulfilled permit the use of the ingredients listed below:
BUT I dont know how this applies to soaps, which are a whole 'nother animal
It has several conditions that if fulfilled permit the use of the ingredients listed below:
BUT I dont know how this applies to soaps, which are a whole 'nother animal
In Canada it is considered a pesticide.
Dorymae
Well-Known Member
If you are interested drugs (over the counter) must follow the drug monograph set up by the FDA and CFR. You can find them here:
http://www.gpo.gov/fdsys/pkg/CFR-2013-title21-vol5/pdf/CFR-2013-title21-vol5.pdf
However you also need to follow strict Good manufacturing practice. You can read about that here:
http://www.fda.gov/Cosmetics/GuidanceRegulation/GuidanceDocuments/ucm2005190.htm
If you are willing to conform to the rules then you need to get approval for your drug. However if you conform to a monograph you do not need pre-approval. See here:
http://www.fda.gov/Drugs/DevelopmentApprovalProcess/HowDrugsareDevelopedandApproved/ucm2007006.htm
Also you must register your company and all "drugs" and formulas that you use. See here:
http://www.fda.gov/Drugs/GuidanceCo...ion/DrugRegistrationandListing/ucm2007058.htm
It is quite the procedure but it has been done, even by the little guys.
Edited to say that if your soap is meant to stop insects and it is moisturizing then it stops being "soap" to the FDA (as far as labeling and restrictions) it is then a cosmetic/drug. (Even if it is just moisturizing it is a cosmetic as far as labeling goes.
http://www.gpo.gov/fdsys/pkg/CFR-2013-title21-vol5/pdf/CFR-2013-title21-vol5.pdf
However you also need to follow strict Good manufacturing practice. You can read about that here:
http://www.fda.gov/Cosmetics/GuidanceRegulation/GuidanceDocuments/ucm2005190.htm
If you are willing to conform to the rules then you need to get approval for your drug. However if you conform to a monograph you do not need pre-approval. See here:
http://www.fda.gov/Drugs/DevelopmentApprovalProcess/HowDrugsareDevelopedandApproved/ucm2007006.htm
Also you must register your company and all "drugs" and formulas that you use. See here:
http://www.fda.gov/Drugs/GuidanceCo...ion/DrugRegistrationandListing/ucm2007058.htm
It is quite the procedure but it has been done, even by the little guys.
Edited to say that if your soap is meant to stop insects and it is moisturizing then it stops being "soap" to the FDA (as far as labeling and restrictions) it is then a cosmetic/drug. (Even if it is just moisturizing it is a cosmetic as far as labeling goes.
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Bex1982
Well-Known Member
If its a bug repellant made with herbs/oils, not actual pesticides, you could call it a camping soap. Ppl can look at the ingredients and figure it out. It's not that a formulation of that kind is breaking any laws, itsthat CLAIMING that your soap will repel bugs is breaking a law.
Nevada
Well-Known Member
Bex1982
Well-Known Member
They so are not supposed to be saying bug repellant. Even cosmetics. Its under the ssme laws as topical drugs.
LunaSkye
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Hypothetically: What if I were to tell my friend, whom I gave a soap to, that my soap was made with lavender, an EO that some people have claimed to help repel bugs? Would that be considered stating that the soap does repel bugs?
That is still making a claim
"...They so are not supposed to be saying bug repellant...."
Yep, just because people get away with making drug-related claims or implying same, doesn't make it correct.
Yep, just because people get away with making drug-related claims or implying same, doesn't make it correct.
Something my mum used to say (& I'll bet you mums too) If everyone jumped off a bridge are you going to? It's the same thing here, just because others are breaking the law are you going to?
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Bex1982
Well-Known Member
I think it protects us too. I mean if we make a claim and our soap doesn't do what we claim we could really tick off some customers, and make a bad name for ourselves. I'd really rather not make any claims, if they like the soap then yay, if not then boo. But they cant drag my name through the mud for making a claim that didn't hold up.
