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 are working together as the GRMA to develop consensus-based American National Standards for Good Manufacturing Practices (GMPs) in several industries. NSF International, an ANSI-accredited standards development organization (SDO), is facilitating the ANSI standards development process on behalf of the GRMA. Continue reading “GRMA is Now an Independent Nonprofit Organization”
California is at it again—potentially expanding federal law regarding cosmetic labeling and animal testing. Introduced on February 15, 2018, Assembly Bill 2775 and Senate Bill 1249 seek to expand federal law. AB 2775, if enacted, would require “professional cosmetics” to be labeled in a manner similar to cosmetics intended to be sold to consumers. SB 1249, if enacted, would make it unlawful to sell cosmetics in California if the finished product or any component was tested on animals. Continue reading “Potential Legislation: Animal Testing and Professional Cosmetics Labeling Requirements”
- Today the FDA posted an additional 5 warning letters issued at the end of July to cosmetics companies addressing drug claims. The letters were issued to: MiN New York; Lavian Ltd.; Peter Thomas Roth Labs, LLC; TPR Holdings LLC; and Finally Pure, LLC. The challenged claims were very similar to those claims addressed in the other warning letters issued earlier in the month as discussed in my earlier post here.
In July, the U.S. FDA issued four warning letters to cosmetics companies. Although only two were prepared by the same office, there were consistent themes across the four letters. As previously discussed here, the FDA continues to crack down on companies making what amount to drug claims on various “cosmetic” products. But what companies need to also be aware of, is that groups of plaintiffs’ attorneys are also beginning to get in the game by sending class action litigation threat letters to companies based on the same marketing claims. While an FDA warning letter may result in a company having to change its marketing and labeling, a class action litigation threat often also results in a payment of “attorneys’ fees” to the plaintiffs’ attorneys lest they will file suit– and even if the company has already agreed to make revisions to its labeling and marketing. Continue reading “Busy “Warning Letters” Month for Cosmetics”
The old adage may be that “time flies when you’re having fun” but unfortunately, lately I have found that it just plain flies! I received an email earlier this week from my friend and mentor Gordon Greenwood of Maclaren Corlett LLP in Canada. He noticed I hadn’t posted in a while, which isn’t really like me, and was just checking in. He also thought my readers and clients could use a nudge regarding the upcoming November 2015 deadline for companies to provide the California Air Resources Board (CARB) 2014 sales data — the next data collection point in the Consumer and Commercial Products Survey as discussed in prior posts. And, as usual, Gordon was right–after all, CARB’s 2014 data reporting for the Consumer Products Program began over 5 weeks ago, and ends on November 1, 2015…less than 3 months from now. Have you started working on the survey? If not, over 25% of your reporting time has already slipped by and reporting can be very time-consuming. Continue reading “Count Down to CARB”
I am excited to announce that I have been appointed Chair of the Joint Committee on Good Manufacturing Practices (“GMP”) for Cosmetics for the Global Retailers and Manufacturers Alliance (“GRMA”). The GRMA was created by the global public health organization NSF International, Inc. and leaders from major retailers and manufacturers to develop consensus-based standards for dietary supplements, cosmetics/personal care products, over-the-counter (OTC) drugs and medical devices. Combining retailer and regulatory requirements into a single standard and auditing program for each product category will help reduce audits and costs while strengthening safety, quality and trust throughout the supply chain. Continue reading “Angela Diesch Appointed Chair of GRMA’s Joint Committee for the Joint Committee on Good Manufacturing Practices for Cosmetics”
On April 20, 2015, Senators Dianne Feinstein (D-Calif.) and Susan Collins (R-Maine) introduced the Personal Care Products Safety Act (S. 1014). This post provides a summary of keys sections of the proposed bill with a comparison to existing law.
According to the press release issued by Senator Feinstein’s office, the S. 1014 has the support of numerous industry trade and consumer groups, including the following: Continue reading ““Personal Care Products Safety Act” S. 1014: Proposed Legislation that will Have a Huge Impact on the Cosmetics Industry if Enacted”