FDA requirements - Label vs misleading / misbranding
I’ll try to keep it short. I had a discussion with one girl, who allegedly wrote a book about FDA requirements after graduating.
I advised someone to put 0.01% of Niacinamide in the product if they want to claim the product contains it. (It was for a wash off product, so no point of having more).
She told me, you can’t claim it on the label, that FDA considers this misleading/misbranding.
I told her she has to have it on the label on the correct place if the product contains it. Also, possibly she could have it on the front as a claim - Contains Niacinamide. And it should be all good.
She’s saying no. I’m not really familiar with FDA, but according to EU, NZ and others I am right, … she is not.
What do you think?
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