Amin Talati Wasserman, LLP helps cosmetic companies stay looking good in the eyes of the law! – Cosmetics & The Law provides cosmetic industry professionals with valuable tips, thoughts, and problem-solving ideas on the business and law of cosmetics with an emphasis on the legal issues facing the industry. Our goal is to help industry professionals help their companies, big and small, to prevent or minimize legal risks and to stay apprised of the legal issues affecting the cosmetic industry.
Traveling to and attending various conferences has prevented me from posting for a couple weeks. So although I have not had time to blog, there has been much to write about-- including the latest round of FDA Warning Letters. In February and March alone, the FDA has issued at least 5 Warning Letters challenging the drug claims … Continue reading More FDA Warning Letters: Strong Enforcement Continues in 2015
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
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
Under the Food, Drug, and Cosmetic Act, cosmetic products and ingredients do not need FDA pre-market approval, with the exception of color additives. As a result, FDA's enforcement of the FDCA are taken against products already on the market. One such enforcement mechanism is the issuance of Warning Letters. As Warning Letters are posted, available here, … Continue reading FDA Warning Letters: cleansers, creams, moisturizers deemed drugs by FDA
The post "When Puffery Crosses the Line" discussed the basic tenets of puffery, or seller's puff, in cosmetic advertising. In addition to running the risk that advertising claims may fall into the realm of false advertising, classic cosmetic puffery may also cause a cosmetic to be a drug under the Federal Food, Drug, & Cosmetic … Continue reading Cosmetic? Drug? How Puffery May Cause Your Product to be a Drug
Cosmetics & The Law 