Any languages below violate the FDA rules on cosmetics a

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Any languages below violate the FDA rules on cosmetics a

Posted by Dtdang on October 1, 2018 at 8:15 pm

The following words that are used for cosmetics are violating the FDA rules:
Natural skincare
anti-aging
anti- wrinkles
fading dark spots
anti-acne
even skin tones

please give me advice .
Thanks in advance .

Dan

belassi replied 6 years, 1 month ago 6 Members · 13 Replies
13 Replies

belassi

Member
October 1, 2018 at 8:38 pm

No problem, just add the word “Helps” in front and that’s that. Or if it’s a quantity use “Up to”. EG “Up to 100% brighter skin!” (0.0000001% is part of ‘up to’)
Dtdang

Member
October 1, 2018 at 8:44 pm

Thanks @Belassi
Microformulation

Member
October 1, 2018 at 10:24 pm

The following words that are used for cosmetics are violating the FDA rules:

Natural skincare. This term will get you in trouble with the FTC (https://www.ftc.gov/news-events/press-releases/2016/04/four-companies-agree-stop-falsely-promoting-their-personal-care)

anti-aging. OK if you stick to this very closely.
anti- wrinkles “Decreases the appearance”
fading dark spots “Decrease the appearance”
anti-acne NO, NO, NO. This is an OTC claim and as such you must follow the OTC rules (monographs).

even skin tones OK

When in doubt refer to this statement from the FDA and be conservative;

FDA defines a cosmetic as a product
(excluding pure soap) intended to be applied to the human body for
cleansing, beautifying, promoting attractiveness, or altering the
appearance.

https://www.fda.gov/cosmetics/guidanceregulation/lawsregulations/ucm074201.htm
Dtdang

Member
October 1, 2018 at 10:45 pm

Thanks @Microformulation
Gunther

Member
October 1, 2018 at 11:32 pm

@Microformulation
“promoting attractiveness” ?
Will you get sued if they no dates, or at least some flirtatious compliments on the street?

I’m sorry, I couldn’t resist
Thank you so much @Microformulation for your informative posts.
DAS

Member
October 2, 2018 at 11:11 am

Actually yes

https://www.dailyrecord.co.uk/news/uk-world-news/man-sues-lynx-after-failing-1040700
Microformulation

Member
October 2, 2018 at 12:49 pm

1. The FDA definition is for US products. The lawsuit is in India.

2. As someone who has some Attorney friends, trust me, you can sue almost over anything. Doesn’t mean you will prevail.
Dtdang

Member
October 2, 2018 at 2:00 pm

That is life!

I appreciate all who input to my topic.
Microformulation

Member
October 2, 2018 at 2:23 pm

@DtdangI will give you some insight on how I approach the instinct for my clients to “stretch” their claims. It has worked great and I have several national accounts that prospered once they got on track.

In the Product Development (a phase you should be doing regardless of where you are in the Market), define 3-5 COSMETIC Claims that you wish to deliver to your clients. Follow the guidelines from the FDA I posted above. There are plenty of good basic ones (moisturization, etc.) and even some “acceptable” marketing based claims (pollution protection comes to mind as it is trendy). Less than 3 (such as these high percentage L-AA Serums) will limit the success of your product and your marketing. More than 5 and you have a difficult time successfully focusing your marketing. Plus, if you are looking to create a line, would you concentrate all these functions into one product even if the Science allowed?

Now, take the next step and select raw materials that can provide these benefits. Deliver these actives and materials EFFECTIVELY in a stable product with good sensorials. (This is your root goal in R&D).

Your marketing is now easy. In a well-written marketing document, educate the client on the benefits delivered, touch briefly on the raw materials and make this the focus. Sell, sell, sell.

The last point (sell, sell, sell) rests upon the point that honestly a Product succeeds based upon the Marketing. As a Formulator who has bumped heads in the past with Marketers I wish it weren’t so, but it is.

If we were shoemakers, our shoes would be 10% leather and 90% polish.
Gunther

Member
October 2, 2018 at 5:56 pm

@DAS very funny, yet true story
here’s the transcript

Man sues Lynx after failing to pull in seven years

A LUCKLESS romeo has sued cosmetics firm Lynx after he failed to land a girlfriend during seven years of using their products.

Indian Vaibhav Bedi, 26, is seeking £50,000 from parent company Unilever for the “depression and psychological damage” caused by the lack of any Lynx effect.

Court officials in New Delhi have accepted dozens of half-used body washes, shampoos, anti-perspirants and hair gels for forensic tests.

Lynx - marketed as Axe in India - is famous for its saucy ads showing barely clothed women throwing themselves at men.

Vaibhav said in his court petition: “The company cheated me because in its advertisements, it says women will be attracted to you if you use Axe. I used it for seven years but no girl came to me.”

Unilever refused to comment on the case.

But India’s leading compensation lawyer Ram Jethmalani said: “There is no data to substantiate the supposition that unattractive and unintelligent men don’t attract women.

“In fact, some of the bestlooking women have been known to marry and date absolutely ghoulish guys.

“I’d suggest the firm settle this issue out of court.”

https://www.dailyrecord.co.uk/news/uk-world-news/man-sues-lynx-after-failing-1040700

I wonder if the out of court settlement will include Will Smith date couching charges
belassi

Member
October 2, 2018 at 6:43 pm

Thanks for that, Gunther. What a story…
OldPerry

Member
October 2, 2018 at 9:04 pm

I’ll just weigh in on the “Natural” claim. I believe it is ok as long as you don’t say “all natural” or “100% natural” based on that FTC action @Microformulation pointed out.
Dtdang

Member
October 3, 2018 at 2:09 am

thanks everyone helping me learning