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 [...]