In August 2008, I published this post about about the FDA Globalization Act of 2008. Small, independent companies such as this one were vehemently opposed to such a regulatory procedure, as the fees involved were hefty (large enough that only "big business" would be able to afford to register), and the word on the street was that we would have to disclose our ingredients on a percentage basis, meaning we'd have to make our Super Secret recipes public knowledge. Like Dr. Pepper having to say exactly what is in that syrup that gives it the unique flavor. At the end of the year, the future looked a bit more rosey with the changing of the guard. Representative Dingell, the original proponent of the FDA Globalization Act was replaced by Representative Henry Waxman, who had an agenda of his own, and any further movement on the act was tabled.
Then we had the peanut butter recall by the FDA last month. According to the FDA, "the deficiencies observed indicate that the plant was not compliant with Current Good Manufacturing Practices required by the FDA." How does this relate to cosmetics? Both industries fall under the scope of the FDA, and even though the salmonella problem was avoidable (and possibly criminal), it changed the temperature of regulation to piping hot. On January 27, the FDA Globalization Act (now of 2009) was introduced as the first bill of 2009 (now numbered HR 759). It's a whole new ballgame, however. With this draft, the bulk of the fees and more intense regulations are aimed towards the Food and Drug industries. Thanks to many hard working Indies, such as Donna Maria Coles Johnson, Marie Gale, Kayla & Dennis Fioravanti, and Anne-Marie Faiola (just to name a few) who spent hundreds of hours combined on behalf of all of us small-folk, the new draft in it's current form is much more palatable. You want to know what's in your products; I can understand and appreciate that (and even agree with it).
As of the current moment, no cosmetic company is required to register with the FDA. However, should HR 759 pass (as it most likely will), all companies must register within 18 months both their business itself, and their products (with ingredients) with the FDA. Any company that does not comply will be operating illegally. As a nod to small businesses (the ones who actually care about the ingredients we put in our products), there will be no fee to register. Exact formulas are not required - just the same thing that any reputable company does now: a complete listing of ingredients in order of predominance.
I can live with this. I can so live with this, that Purely Cosmetics voluntarily registered with the FDA, and have already submitted all formulas to the Voluntary Cosmetics Registration Program (VCRP). As of the minute this post is being written, I have already received Cosmetic Product Ingredient Statement (aka CPIS #) approval for all but the 3 products submitted yesterday. Which also explains so much of my silence - got any idea how long this input takes??? I have nothing to hide. I use nothing but the best ingredients, produced in a safe manner. Now that all my products are registered, you too can rest assured that Big Brother is watching me.