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MEET THE MODERNIZATION OF COSMETICS REGULATION ACT OF 2022 — It’s Here!

Just before the Christmas holiday, in a scramble to avoid a partial government shutdown, both houses of Congress approved a $1.7 trillion government spending bill. Earlier that week, the Senate had amended the Consolidated Appropriations Act of 2023 (the “Appropriations Bill”) to, among other things, reintroduce the Modernization of Cosmetics Regulations Act of 2022 (“MOCRA”). … Continue reading MEET THE MODERNIZATION OF COSMETICS REGULATION ACT OF 2022 — It’s Here!

Register Now! Looking Good in the Eyes of the Law — Updated Agenda

I am excited to announce a few changes to the agenda for our Looking Good in the Eyes of the Law seminar. Curt Valva of Aubrey Organics will be the MC for the seminar.  In addition, Dr. Paula Johnson, Research Scientist and Lead of the California Safe Cosmetics Act Program will be a presenter.  A … Continue reading Register Now! Looking Good in the Eyes of the Law — Updated Agenda

FDA Warning Letter: Needling Device Exceeds Dermabrasion Exemption

On January 9, 2015, the FDA issued a warning letter to Derma Pen, LLC, claiming the company's micro-needle dermabrasion device is an adulterated and misbranded Class 1 medical device and challenging the marketing of the company's line of "cosmeceuticals" as misbranded drugs. FDA asserts that the automated micro-needling device, which uses a stamping action to … Continue reading FDA Warning Letter: Needling Device Exceeds Dermabrasion Exemption

When Puffery Crosses the Line

“Puffery,” or "seller's puff," is an exaggerated or over the top general promotional statement that a reasonable person would not take literally. For example, the claim that “Lilly's Magic Lotion is the best lotion on the market”  would be considered puffery. The claim that the lotion "is the best" is general and a court would find … Continue reading When Puffery Crosses the Line

Cosmetics Industry Continuing to Face Slack Fill Challenges

Recently, local California news channels reported a quarter million dollar settlement involving a store branded line of cosmetic products.  I do not generally name companies involved in such settlements (and will not do so here), but the claims settled in the suit are a good topic of discussion to help your company avoid or at … Continue reading Cosmetics Industry Continuing to Face Slack Fill Challenges