Regulatory Issues

Question 1

Labeling and Label Claims

Answer 1

• Aromatherapy products are regulated by the FDA (Food and Drug Administration) as cosmetics. This creates certain problems in labeling and assisting your customers with understanding the health benefits of these products. Aura Cacia labels all products in compliance with regulations in order to protect you and your customer – that’s why you will often see competing products making claims or statements about the product’s supposed benefits that you won’t see on an Aura Cacia label.
• Drug claims: These are claims such as the product treats or cures cancer, bronchitis or any other disease for which prescription drugs are used.
• OTC claims: Over the Counter drugs are drugs that can be sold without a prescription. These are for conditions that are considered by the FDA to be self-diagnosable and self-treatable with a low risk of abuse or misuse of the drugs. Each condition is a separate therapeutic category and there are over 80 categories such as cold and flu, cough suppressant, anti-wrinkle, sunscreens and acne. If a product is making an OTC claim, check to make sure it is an OTC product. This will be evident because it will include the active ingredient (which will be an ingredient approved for use in that OTC category).
• Structure/Function claims: Many cosmetic and aromatherapy companies have tried to adopt structure/function claims in their labeling. However structure/function claims are only applicable to dietary supplements and do not apply to cosmetics. So claims such as “provides support during cold and flu season” are not allowed for aromatherapy or cosmetic products.
• Insect Repellant claims: The EPA (environmental protection agency) regulates the use of pesticides and insect repellents. Even if they approve an essential oil such as lemon eucalyptus or citronella for use as an insect repellent, products making such claims must be registered and approved by the EPA before they can be sold.

Question 2

What you can and cannot say regarding essential oils

Answer 2

• So what can you say? Soft claims, or statements that provide an emotional or general benefit are acceptable ways to describe an aromatherapy product’s uses. It takes some creativity to give the consumer information about the benefits of a product without crossing a legal line. Here are some examples of the type of language you can and can’t use in describing a product’s benefits.
• And you can always point an inquisitive shopper to your book section or recommend some good aromatherapy books from your own experience.