Cosmetic Regulatory Forum: Some New Do's and Don'ts
The Independent Cosmetic Manufacturers and Distributors (ICMAD) met in Newport Beach, CA on February 16. On the agenda were updates on Canadian cosmetics regulations, new sunscreen rules, new insurance tools for growing companies and more including roundtable discussions following the presentations.
Featured speaker David Steinberg of Steinberg & Associates was the former national president of the Society of Cosmetic Chemists and writes a column on Cosmetic Regulations for Cosmetics & Toiletries magazine. He spoke on the enforcement of rules regulating the import and export pf cosmetics.
Steinberg concentrated on five major reasons that products prompt scrutiny by the FDA or are held up in Customs:
- Unapproved colors--The product contains colors not allowed in cosmetics in the US, colors not labeled correctly, colors not meeting self certification requirements.
- Microbial contamination--The FDA can take samples at Customs for microbial plate counts and identification of microbes.
- Incorrect labels--Non compliant, incorrect ingredient listings, not having correct disclosure of net contents.
- Unregistered drugs--They must be in the FDA's data base as being properly registered, making drug claims. A big watch-out is the use of the term 'anti-aging' and the percentage claims (ie. "You will see an 80% decrease in your wrinkles.")
- VOC violations--There are CA requirements and EPA requirements and they are not the same.
'Websites are triggering many warning letters. Even testimonials on websites are being scrutinized," said Steinberg.
And what are some of Steinberg's suggestions for what to do:
- Be sure your ingredients, especially colors are allowed and comply.
- Be sure all batches are tested for microbial contamination before release.
- Be sure your products are labeled incorrectly.
- Be sure you have proof of all your claims. You need clinicals. Don't rely on data supplied for the ingredients by the vendorr.
Learn more about ICMAD at www.icmad.org