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Ingredient Declaration guidance/opinions: reconstituted materials?
Hi!
I’ve noticed a number of water-based products in the marketplace (USA) which list extracts/juices in place of water and pondered about the legality of this approach. I’ve always held the notion that you list “what you add”, not “what you create” during compounding; e.g., 200x aloe vera powder should be declared as aloe vera leaf extract, despite the fact that it becomes aloe vera leaf juice when reconstituted. However, I was unable to locate this scenario within FD&C/FP&L to verify if the approach is acceptable and legal.
Is anyone familiar with this strategy? Is it legal/appropriate to declare reconstituted materials as solutions on final package or is this a case of deceptive labeling?
Thank you in advance for your time and thoughts.
Kefka
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