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Where to learn more about US regulatory rules/guidelines?
The sales team at our company frequently reaches out to R&D to ask about claims and badges for packaging. I think I have covered most of the FDA’s webpages about labeling rules, but I’d like to know if there’s any other sources I should look into. For instance, we get requests like “can we call this product cruelty-free?” They want to create their own badge/icon that would say cruelty-free, not use the leaping bunny. Wouldn’t we just need to draft a statment saying the finished product has never been tested on animals? If we were using a standardized badge like the leaping bunny we would validate the raw materials as well, but since this is just a company-made badge, can’t we set our own precedent?
Our regulatory team is shit so I’d like to get some extra knowledge for myself. Are there any other resources I should be aware of?
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4 Replies
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This is a challenging question because it comes down to a legal opinion. The FDA (and the FTC which is the group responsible for policing cosmetic claims) has specifically said this about “cruelty free.”
“Some cosmetic companies promote their products with claims of this kind in their labeling or advertising. The unrestricted use of these phrases by cosmetic companies is possible because there are no legal definitions for these terms.”
(emphasis mine)
So, the FDA pretty much has said you have unrestricted use. Now, you’ll have to have some way of supporting your claim which you’ve already suggested. This is in the event that some lawyer or consumer challenges you in court. But based on what the FDA has said, I see nothing wrong with your strategy. However, I’m not a lawyer and you shouldn’t take legal advice from a non-lawyer chemist.
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The short answer is “Yes” you can claim cruelty-free and create your own badge. “Leaping Bunny” is a private certification organization, so their leaping bunny logo on your product only means that you have paid them money to use their bunny logo and they have confirmed that you don’t do any animal testing on your products. I wonder how they definitively prove that negative and it is any more valid than you yourself claiming that you don’t do animal testing.
Just make sure you don’t include any Sodium Crueltyate in your product and you’re good to go.
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Sodium Crueltyate 😆
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Haha I appreciate the responses! To me this all makes sense, the cruelty-free is just one example. I am trying to cut down the amount of repeat requests we get in R&D when the questions should be handled by regulatory/legal team so I was wondering if there was anywhere I could point them other than FDA website and 21 CFR
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