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Labeling on a mosquito lotion….
I am in the final stages of development on a lotion that mosquitos dislike. I have read the FDA labeling guides, but still have some questions, as it did not directly hit on my areas of concern.
1) First….My product will make NO claims that it repels mosquitos. Just state that it is DEET FREE, and have some quirky name that includes Mosquito…but NOTHING about repelling them.
2) No regulated components (Oil of Lemon Euc, (PMD) etc) are included.
3) About 1/2 of the features that mosquitos will dislike, come from essential oils….so here is where my questions begin.
I know that if I were to make a claim…that it repelled…I would need to list the EO’s, and their rate of inclusion. So if I am NOT making any kind of claim….can I lump them under… ‘Fragrance’, not list them individually and not list percentages?
Thank you for your thoughts!
Sidebar……..hehehe….the challenge in this product….has been reducing the volatility, and increasing the duration of dislike, beyond 15-18 minutes. But I almost have that licked.
…. Well I do have it licked….but it is an emulsion killer….but I think I have products on the way…to fix that.
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2 Replies
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https://www.epa.gov/insect-repellents/regulation-skin-applied-repellents
https://www.epa.gov/minimum-risk-pesticides/conditions-minimum-risk-pesticides
You can make a minimum risk repellent that doesn’t require registration, would that not be a good fit?Essential oils have to be listed individually in cosmetics as far as I know, Fragrance usually relates to having a laundry list of individually selected molecules to create a smell
Determining product classification depends on your claims, but if you read warning letters you’ll see that website reviews/customer testimonials are also often considered, or even singular ingredients that have a well-known purpose.
I am not a fan of following rules just because they are rules, but these exist to let consumers make informed choices about what they buy, and the more ‘active’ you want something to be, the greater risk you run of endangering someone- registration/testing guidelines can mitigate harm
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As far as I know you are allowed to list an essential oil blend as “Fragrance,” given that it is placed in the LOI as the combined %wt of all the blended oils.
That said, I don’t think you should. One, it’s a little dishonest. Two, the inclusion of essential oils is, by and large, a selling point for most products and probably increases your cost; why not brag about it?
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