Labeling of potential allergans/irritants

[not_ally]

Mods, not sure where to post this, please move if appropriate. Sorry, long wool-gathering post.

So, some of the recent posts on allergic reactions, in combo w/the dandelion threads, have gotten me thinking. My sister and I are in the process of trying to put together a company to start selling an ayurvedic hair oil (pre-shampoo treatment) which is essentially all EO's in a coconut oil base.

Our label - I will probably post it at some point to get y'alls opinions) lists all the ingredients. Some of them are pretty obscure to a US consumer though. In truth, I don't even know if one or more of them are potential allergans/irritants, though we have had many testers use w/o problems and will do more research before we sell. Although, this is a product which is one of the biggest selling ones in the state my family is from in India and also sells widely in the Middle East, the creator/manufacturer is one of my dad's best friends, that is why she has offered us the North American distributorship. But lots and lots of sales with no reports of adverse reactions so for.

Anyway, I didn't know before the dandelion threads that it was such an irritant for some people, now I do. I do know that many e.o.'s are problematic in this respect, expecially in certain cases. My concern is selling to members of the general public that don't. Eg, if there was dandelion in our hair oil (there isn't) would it be morally - if not legally - better to star it, and any others that I know to be problematic and place a footnote at the bottom saying "potential irritant/allergan"? Obviously not such a good idea for sales but wondering if we should do it anyway.

 

[KristaY]

Something like the food manufacturers do with nuts and glutens? "This product was made in plant that processes wheat and peanuts" type thing? If I were you, I'd start looking at the packaging of other products that are similar to what you're looking to do. How do they highlight (or do they) the ingredients that may be problematic? Do they have a sentence similar to one above that says something like "One or more ingredients may be a potential skin irritant. A patch test is recommended". I'd start studying the competitors to see how they handle this situation.

 

[soapswirl]

Your essential oil supplier should be able to provide you with an allergen declaration for each essential oil. You should then include the particular allergen in your ingredient listing. E.g. bergamot eo contains citral, linalool and limonene - so these should be listed at the end of your ingredient listing (possibly starred with a statement that they are naturally occurring components of the essential oil). This is a legal requirement in the EU, I don't know about the laws across the rest of the world but it seems like good practice to me!

 

[not_ally]

Krista, there seems to be a good bit of variation between labels, even among the small group of products that this falls into. I don't think I would be worried about the extra rigorous labeling stuff, ie: "this was made in a facility in which it might have been exposed to nut oils/particles", but would like to come to a place that is someplace in between. But you are right, the next round is to (a) re-read the FDA regs and (b) make a more careful search of how others do it, and figure out the ones that I think look right.

Soapswirl, the EU regs are much more demanding than here, both good and bad (probably good for consumers, not so good for sellers.) One of the problems is that the labels are so little! Although we are thinking of attaching a little hang-tag, as well.

 

[Cindy2428]

I absolutely support good labeling practices and even with my hobbyist soaps use the FDA interpretation from Marie Gales book. Frankly, if you are selling you should buy this book.

That being said, and if I get hammered for it so be it, but what about the responsibility of the buyer? if you follow the labeling laws from your country, you should be fine. I did include a general statement of my first soaps that they "may include essential oils that can cause some individuals dermal sensitivity", or the like.

I would feel horrible for someone using my product that was properly made and labeled, and they had a negative skin response to it. I would probably have them send it back so I could test it and offer them something else as well. But if I did everything right I would stand behind it 100%. I guess that's why I don't feel ready to sell yet.

 

[not_ally]

Cindy, that book is indispensable. Such a good clear guide to a lot of stuff that is really hard to understand otherwise. Even as a lawyer I start there and then go on to check if needed.

 

[soapswirl]

Just for info - here is an example of an eu ingredients listing for a product containing essential oils. The specific allergens are listed at the end and there are no extra statements about allergens anywhere else on the packaging. In my opinion this puts the buyer in a good position to decide if the product will be a problem for them without scaring away others! Obviously im not saying this is what you must do - i know the laws are different - just trying to share some knowledge and a different perspective!

 

[not_ally]

Soap swirl, thank you for being kind enough to post the label for me. It was instructive. I think (but have to go back to the Gale book and do some extra checking for various reasons) that we in the US have to list the common and botanical names but not necessessarily constituents (eg, citral, and the rest.) I might be wrong, though, so more research is in order, but this helped as an example (and estimating how many words would fit on a label

 

[KristaY]

Krista, there seems to be a good bit of variation between labels, even among the small group of products that this falls into. I don't think I would be worried about the extra rigorous labeling stuff, ie: "this was made in a facility in which it might have been exposed to nut oils/particles", but would like to come to a place that is someplace in between. But you are right, the next round is to (a) re-read the FDA regs and (b) make a more careful search of how others do it, and figure out the ones that I think look right.

Soapswirl, the EU regs are much more demanding than here, both good and bad (probably good for consumers, not so good for sellers.) One of the problems is that the labels are so little! Although we are thinking of attaching a little hang-tag, as well.

This might be a good way to go. I know the regs talk about minimum font size so it can be read without a magnifying glass, lol. Also, if the product itself is too small to add the full list (like lip balm tubes) you're allowed to list the ingredients on the packaging. So depending on the size of the container your product will be in, you could consider something like an attached hang tag.