FDA Updated Its Earlier Guidance for Hand Sanitizer Production

On April 15, 2020, the FDA updated and issued as”final” the three guidance documents it had prepared to promote the availability of hand sanitizers during the COVID-19 crisis, found at: (1) https://www.fda.gov/regulatory-information/search-fda-guidance-documents/policy-temporary-compounding-certain-alcohol-based-hand-sanitizer-products-during-public-health; (2) https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-industry-temporary-policy-preparation-certain-alcohol-based-hand-sanitizer-products-during; and (3) https://www.fda.gov/regulatory-information/search-fda-guidance-documents/temporary-policy-manufacture-alcohol-incorporation-alcohol-based-hand-sanitizer-products-during. None of the three updates to the guidances retract the FDA’s initial advisory announcements that for the duration of the [...]


As noted in our prior post, in response to the demand for hand sanitizers created by the COVID 19 crisis, the FDA announced it would not pursue actions during the pendency of the crisis against state-licensed pharmacies or Federal facilities or registered outsourcing facilities for the compounding of alcohol-based hand sanitizers, provided the resulting products [...]

Hand Sanitizers, COVID19 and FDA Regulatory Actions – Recent Developments

Wow! What a different world we are in than just a month ago.  As consumers lives have been shifted by the sudden emergence of the threat of the COVID-19 virus, the FDA has acted quickly to show that it is not asleep at the wheel, and that it will act both to increase the availability [...]

Expectations of Stricter Standards & More Aggressive Enforcement over Influencer Marketing?

Beauty bloggers. Make-up or skincare tutorial v-loggers. YouTube. Instagram. Twitter. No matter the platform, more and more cosmetic companies are turning to influencer marketing. Most companies are aware there are standards governing the use of social media and other online endorsements--particularly when the endorsement is given after the receipt of some benefit, such as free [...]

Hotel Soap Saga on the Horizon

California Enacts Ban on Use of Smaller Sized Plastic Packaging of Personal Care Products in Hotels In October 2019, California Governor Gavin Newsom signed into law AB 1162, prohibiting any “lodging establishment” from providing personal care products such as shampoo or soap in plastic bottles of 6 ounces or less. AB 1162 broadly defines “lodging [...]


Happy New Year! 2019 was quite the year in many regards. One such area was the significant growth of the CBD marketplace. In response, in the last quarter of the year, the Food & Drug Administration (“FDA”) got busy issuing warning letters and posting consumer notices regarding the safety and use of cannabidiol ("CBD"). For [...]

Unapproved Drug Claims – The Continuing Saga for Cosmetic Brands

Unapproved "drug" claims - a continuing saga. In prior posts we have discussed the importance of cosmetic brands to avoid "drug" claims, and have discussed court rulings on the topic. Unfortunately, such marketing claims continue to be boasted by big and small brands alike, so it is no surprise we have seen an increase in [...]

GRMA is Now an Independent Nonprofit Organization

GRMA is Now an Independent Nonprofit Organization

As I previously announced, I Chair the GRMA Joint Committee on the Good Manufacturing Practices for Cosmetics. I am excited to share after 4-years of hard work by so many of its members, the Global Retailer and Manufacturers Alliance ("GRMA") is now an official, independent nonprofit organization! Many major retailers, manufacturers, trade associations and certification bodies [...]

Face-to-Face at Expo West 2018

Face-to-face at Natural Products Expo West, Anaheim, CA, Thursday, March 8-11, 2018. Angela and her colleague Stephen Paffrath will be attending the Natural Products Expo West in Anaheim this week. If you would like to arrange a face-to-face meeting please contact Angela's assistant Jennifer Chastain at jennifer@dieschforrestlaw.com. Don't delay as their calendar for meetings is filling [...]