So, a lot of people want to know ALL about my products, and I would love to tell them everything I know! Put it in the listings, put it all on the labels!
But why CAN'T I legally tell you about my anti-aging face serum?* Or my stress-relief bath bombs, for that matter?* Or my skin-healing lotion bars?* Or my amazing pore-cleansing soap that doubles as a great gym soap and also an acne-fighting bar??*
Ok, I'm going to break it down real quick here. In the United states, the codes that relate to labeling for handmade bath & body products allow something to be classified as a basic product, OR a “cosmetic” product, or sometimes even as a “drug product.” There are different testing requirements for some of the categories along with very strict laws for when you can and cannot make a certain claim on your labeling.
So if it's a soap? You can call it a soap. It cleans. Bam, there you have it. But HERE'S THE KICKER – You might have a soap that is super hydrating and nourishing for the skin. It might be wonderful helper for skin with eczema and psoriasis, or little toes that picked up something in the gym showers and need to give it a shake (or help it not stick with you in the first place). It might be a soap that clears out your pores really well and is amazing for zits and blackheads. But if you put ANY of that on the labeling, bam, it's classified as a “cosmetic” or depending on the wording of your claim, a “drug product.” So if I even tell you that my soap is “moisturizing?” Cosmetic. EVEN THOUGH any handmade cold-process soap (if made properly) will allow some of the nourishing oils to stay on your skin after cleansing and it doesn't tend to leave that sticky film and dry out your skin like the commercial bars . . I can't use the word “moisturizing” without an additional EXTREMELY burdensome set of regulations being added. If I tell you it busts acne? It is now classified as a drug product. Now it has to be approved for that use. Now one might wonder why not have it classified as a drug product, right? If that soap moisturizes your skin and clears out your pores like no other, if it fights acne, why NOT go through all the fuss to make sure your customers can know that? Because unfortunately at the level of the individual maker, even a moderate-sized company the testing and FDA submission requirements that are required to make that type of claim are just out of question. It can take hundreds of thousands of dollars and years just to quantify one statement and for what? So that you can put “pore-cleansing” on your Activated Charcoal soap? So that you can put “natural anti-microbial action” on your soap with a Tea Tree Oil blend? So that you can put “anti-aging and with cell regeneration” on your unique blend of skin-loving face oils? The products still do the same thing . . it's just marketing. And let's not even get started with what it would take to get our regulatory agencies with their laws how they currently are now to allow you to tell people the actual multi-modal benefits for your mind, body and spirit of an Essential Oil Aromatherapy Bath Bomb or a shower steamer. . .let's just not. How does one word the application for “soak your Monday away” or “steam the traffic right out of my mind?” Ha!
So . . we can tell you that our soap cleans. We can talk superfat percentage and oils and butters and give you the breakdown on bar hardness and so forth. We can tell you that our lotion bars are a preservative-free dry lotion concept. That they are portable. We can tell you that our Shea butter is refined without solvents and that our Citric acid is highest grade non-GMO sourced. We ALWAYS list all of our ingredients AND WE ENCOURAGE you to do a few searches (we find DuckDuckGo or another engine to be far superior to Google) to learn a little FOR YOURSELF about the potential effects you may experience with our handmade luxury products. Get books on Essential Oil benefits, learn what various oils can do for your skin, learn the difference in USE between handmade soap and commercial (“syndet”) bars etc. - The internet is an amazing thing and yes there are some wonky sites out there but there is some very SOLID information too right at your fingertips so go check it out! We make very high-quality products that we stand by and would LOVE for you to learn more about what you can get out of their use! We cannot, however, tell you about the amazing benefits you MAY receive through use of these amazing ingredients ourselves unless we want to go through the crazy revolutions required for cosmetic or drug product approval and labeling.
But wait! You say. I bought “Stress relief pillow spray” and “Zit busting acne cream” and “Detox bath bombs” from my good friend's handmade company last week! She didn't do any of that stuff in order to label it – it says right on there that Lavender Essential Oil will lift your spirits and make you snooze like a baby and that the cream will clear up all of your zits and that all kinds of chemical assaults can be removed by using the detox bombs! And she doesn't list all of her ingredients, just the basic ones but some things are listed as a “proprietary blend” because she doesn't want copy cats. Isn't that a violation?
Here's our take on all of that. This post is not to talk down on other people and how they choose to label or encourage folks to tattle to regulatory agencies or anything of that sort. If some people are not disclosing their ingredients (especially for powerful components like Essential Oils) or are using labeling practices outside of those specified by the law, it can have often un-intended harmful effects for their users (and children in their care) and in some cases for their business if agencies do catch up to them on that front. We strive at Heart's Path Designs to do our absolute best in the areas of transparency and compliance with applicable laws even if it means that our listings lack a few key words you may be finding elsewhere that do tend to bring buyers in quickly. It's tough some times but we are just going to roll with it. Feel free to slip this blog post into your friend's stocking if you choose to do so but that's NOT particularly why we are writing it – we are writing it so that YOU our valued customer will know why we aren't using those keywords you may have gotten used to seeing and why we cannot directly tell you some of the potential benefits. The ingredients list and a little reading is where the good info is at in our view.
For more information on specific labeling requirements, a great guide is Marie Gale's amazing book “Soap and cosmetic Labeling: How to Follow the Rules and Regs Explained in Plain English.” It is available on Amazon.
*Disclaimer – Of course I'm not actually making these claims or any other drug/cosmetic for any of the products mentioned anywhere in this blog post. I would encourage people to try my products and see what they CAN do, that's all I'm saying!!
Image: Heart’s Path Designs all-natural Plant-Based Face Serum with Argan Oil.
Image Credit Lisa Jenkins/Heart's Path Designs.