Re: Need some advice on products & labeling

[Guest guest]

I'm sure Maurice will address this more in-depth, but I'm quite

shocked at those ingredient listings - there are several proprietary

names in there, which is strictly against the rules, and I seriously

doubt that they're all presented in correct order. If they are, I'd

be afraid to use them!

I've never recommended Bitter Creek before, and if that's the info

they give you for their labels, I can honestly say I certainly won't

in the future!

Jules/Vancouver BC

> Hi Everyone,

>

> Based on the advice from some other list members, I've posted 3 of

my products below for comments. Maybe someone else on the list can

gain some knowledge as well! They are all bases from Bitter Creek

Candle, and I've added dye (D & C) & fragrance (from Bramble Berry)

to spray, wash and bubble bath. I'll post the lip balm label tonight

after I look it over again. These products are supposed to geared

towards kids. Please let me know if you see anything that doesn't

look right. Also, these are the ingredients I plan to list on the

labels. Please tell me if the names don't look like the proper names

for labeling. Thanks so much. I really appreciate your help!

>

> Best,

>

> Robyn

>

> Hair & Body Protein Mist/Spray:

> 1. De-Ionized Water

> 2. Aloe Vera Gel Stabilized

> 3. Cetrimonium Chloride

> 4. Isopropyl Alcohol

> 5. Propylene Glycol

> 6. Sodium P.C.A.

> 7. Vitamin E

> 8. DMDM Hydantoin

> 9. Methylparaben

> 10. Propylparaben

> 11. Collagen

> 12. Dimethicone

> 13. Seasalt

>

> + Fragrance (FYI - 1/2 oz. F/O per gallon base)

>

> + D & C Red #33

>

>

> Bubble Bath:

>

> 1. De-Ionized Water

> 2. Hampene NA2

> 3. Plantaren APB

> 4. Sodium Chloride

> 5. Aloe Vera Gel

> 6. Citric Acid

> 7. Milk Solids

> 8. Glycol IMonostearate

> 9. Witch Hazel Extract

> 10. Lavender Extract

> 11. Chamomile Extract

> 12. Aloe Extract

> 13. Sage Extract

> 14. Sesame Seed Oil

> 15. Wheat Germ Oil

> 16. Avocado Oil

> 17. Germaben IIE

>

> + Fragrance (FYI - 1 oz. F/O per gallon base)

>

> + D & C Red #33

>

>

>

> Aloe Body Wash:

>

> 1. De-Ionized Water

> 2. Plantaren APB

> 3. Hampene NA2

> 4. Aloe Vera Gel

> 5. Citric Acid

> 6. Sodium Chloride

> 7. Witch Hazel Extract

> 8. Lavender Extract

> 9. Chamomile Extract

> 10. Aloe Extract

> 11. Sage Extract

> 12. Sesame Seed Oil

> 13. Wheat Germ Oil

> 14. Avocado Oil

> 15. Germaben IIE

>

> + Fragrance (FYI - 1 oz. F/O to 1 gallon base)

>

> + D & C Red #33

>

>

>

>

>

>

[Guest guest]

On Tue, 13 Aug 2002 01:33:55 -0000, gardengoddessjules wrote:

>I've never recommended Bitter Creek before, and if that's the info

>they give you for their labels, I can honestly say I certainly won't

>in the future!

FWIW,

All the ingredient declarations found on

http://www.candlesupply.com/bathingredients.html

are WRONG. Products using these ingredient lists are misbranded and

subject to recall.

Section 301( of the Food Drug and Cosmetic Act specifically prohibits

( The adulteration or misbranding of any food, drug, device, or

cosmetic in interstate commerce.

and Section 602(a) further defines when a cosmetic is misbranded:

(a) If its labeling is false or misleading in any particular.

It would appear that the people that put these ingredient lists

together never took the time to read their own website.

http://www.candlesupply.com/FDAinfo.html

Am I being too hard? Or are they just irresponsible vendors to the

homecrafting marketplace??

Maurice

----------------------------------------------------------

Maurice O. Hevey

Convergent Cosmetics, Inc.

http://www.ConvergentCosmetics.com

----------------------------------------------------------

[Guest guest]

Little Mrs. Lurker here. Maurice, you are not wrong! Many people just

learning will follow something they see without question and get into

trouble. It will hurt many people if false information gets around and is

used. I spend many hours on the phone with newbies to toiletries and one of

the first things I tell them is to find the closest FDA office and make sure

you have the number written down for questions. My local FDA office knows

me very well. I am always calling with questions when I do not understand

something in the regulations. I just wish more people took the time to ask

questions and more people willing to say that they do not know something.

JM2C

Wiccan

www.perpleasures.com

Check us out for you container needs

-- Re: Re: Need some advice on products & labeling

On Tue, 13 Aug 2002 01:33:55 -0000, gardengoddessjules wrote:

>I've never recommended Bitter Creek before, and if that's the info

>they give you for their labels, I can honestly say I certainly won't

>in the future!

FWIW,

All the ingredient declarations found on

http://www.candlesupply.com/bathingredients.html

are WRONG. Products using these ingredient lists are misbranded and

subject to recall.

Section 301( of the Food Drug and Cosmetic Act specifically prohibits

( The adulteration or misbranding of any food, drug, device, or

cosmetic in interstate commerce.

and Section 602(a) further defines when a cosmetic is misbranded:

(a) If its labeling is false or misleading in any particular.

It would appear that the people that put these ingredient lists

together never took the time to read their own website.

http://www.candlesupply.com/FDAinfo.html

Am I being too hard? Or are they just irresponsible vendors to the

homecrafting marketplace??

Maurice

----------------------------------------------------------

Maurice O. Hevey

Convergent Cosmetics, Inc.

http://www.ConvergentCosmetics.com

----------------------------------------------------------

[Guest guest]

I was just going to comment on the irony of Doneen putting up a bit

on FDA labelling issues with her own products so totally

mislabelled...even the ingredients listed for the Germben IIE were

wrong! Oy!

Sad thing is, I did a real quick search on a couple of those

proprietary names and I came up with DOZENS of vendors who use the

exact same ingredient listing...either they're buying from Doneen or

using the same supplier.

That really really irks me...I recently got into a discussion on

another list lately about a similar situation, and was told that the

woman's supplier's supplier told her that using proprietary names

like " Germaben II " was okay because " everyone who knows about this

stuff knows what that is " . WHAT???? I didn't manage to find out the

name of this misguided (to be kind) supplier, but the ingredient list

was AWFULLY similar to some of these - right down to listing " Hampene

Na2 " instead of disodium EDTA.

AAARRRGGGHHHHHH....I don't know who should be strung up first - the

person supplying middlemen like Bittercreek, or the people like

Bittercreek who blindly accept what is blatantly incorrect ingredient

listings.

Jules/Vancouver BC

[Guest guest]

On Tue, 13 Aug 2002 01:50:27 -0000, gardengoddessjules wrote:

>AAARRRGGGHHHHHH....I don't know who should be strung up first - the

>person supplying middlemen like Bittercreek, or the people like

>Bittercreek who blindly accept what is blatantly incorrect ingredient

>listings.

I'd start with Bitter Creek. Based on the information on their

website, they KNOW better.

Quoting from the Bitter Creek website:

http://www.candlesupply.com/FDAinfo.html

" The cosmetics distributed in the United States must comply with the

labeling regulations published by the FDA under the authority of the

FD & C Act and the FPLA. Labeling means all labels and other written,

printed or graphic matter on or accompanying a product. The label

statements required under the authority of the FD & C Act must appear on

the inside as well as any outside container or wrapper. FPLA

requirements, e.g., ingredient labeling and statement of the net

quantity of contents on the principal display panel, only apply to the

label of the outer container. The labeling requirements are codified at

21 CFR 701 and 740. Cosmetics bearing false or misleading label

statements or otherwise not labeled in accordance with the codified

requirements may be considered misbranded and may be subject to

regulatory action. "

I guess this is an example of not walking the talk.

Maurice

----------------------------------------------------------

Maurice O. Hevey

Convergent Cosmetics, Inc.

http://www.ConvergentCosmetics.com

----------------------------------------------------------

[Guest guest]

>Bubble Bath:

>

>1. De-Ionized Water

>2. Hampene NA2ÿ

>3. Plantaren APBÿ

>4. Sodium Chloride

>5. Aloe Vera Gel

>6. Citric Acid

>7. Milk Solids

>8. Glycol IMonostearate

>9. Witch Hazel Extract

>10. Lavender Extract

>11. Chamomile Extract

>12. Aloe Extract

>13. Sage Extract

>14. Sesame Seed Oil

>15. Wheat Germ Oil

>16. Avocado Oil

>17. Germaben IIEÿ

>

>+ Fragrance (FYI - 1 oz. F/O per gallon base)

>

>+ D & C Red #33

OK, let's try this pseudo ingredient list first. I will be using the

9th edition INCI names for this post

the INCI name for De-Ionized Water is Water

the INCI name for Hampene NA2 is Disodium EDTA

Plantaren APB is a combination of Ammonium Lauryl Sulfate (and)

Ammonium Laureta Sulfate (and) mide Glucoside (and) Lauryl

Glucoside

the INCI name for Sodium Chloride is Sodium Chloride

the INCI name for Aloe Vera Gel is Aloe Barbadensis Gel

the INCI name for Citric Acid is Citric Acid

the INCI name for Milk Solids is Whole Dry Milk

the INCI name for Glycol IMonostearate is Glycol Stearate

the INCI name for Witch Hazel Extract is Hamamelis Virginiana (Witch

Hazel) Extract

the INCI name for Lavender Extract is could be Lavandula Angustifolia

(Lavender) Extract or Lavandula Spica (Lavender) Extract, insufficient

information.

the INCI name for Chamomile Extract is could be Anthemis Nobilis Flower

Extract or Chamomilla Recutita (Matricaria) Extract, insufficient

information

the INCI name for Aloe Extract is could be Hamamelis Virginiana (Witch

Hazel) Extract or Aloe Andongensis Extract or Aloe Andongensis Leaf

Extract, insufficient information

the INCI name for Sage Extract is probably Salvia Officinalis (Sage)

Leaf Extract

the INCI name for Sesame Seed Oil is Sesamum Indicum (Sesame) Seed

Oil

the INCI name for Wheat Germ Oil is Triticum Vulgare (Wheat) Germ

Oil

the INCI name for Avocado Oil is Persea Gratissima (Avocado)

Oil

the INCI name for Germaben IIE is Propylene Glycol (and) olidinyl

Urea (and) Methylparaben (and) Propylparaben

the INCI name for Fragrance is Fragrance

the INCI name for D & C Red #33 is Red 33

Without more information from Bitter Creek, it is impossible to create

a legal ingredient declaration.

Maurice

----------------------------------------------------------

Maurice O. Hevey

Convergent Cosmetics, Inc.

http://www.ConvergentCosmetics.com

----------------------------------------------------------