The FDA isn’t the only governing body that affects the businesses of perfumers and other cosmetic enhancements in the US. Nope, we get bunches more: the EPA, the Department of Agriculture, the IRS…and the US Consumer Product Safety Commission.¹

This latest act covers childproofing laws: if your products contain certain chemicals, your packages are required to be actually childproof, and by childproof they mean actually child proof. They really mean it – there’s a very specific test laid out in their guidlines that insists on testing by specifically authorized companies where kids try to break into (empty) bottles that you intend to use for packaging. Can you imagine having that job?

As to bath and body makers, the chemicals that must be so contained in childproof packaging are:

1)Petroleum distillates
These are common in preservatives, and some fragrance oils may be petroleum-based. You will need to call your suppliers.

2)Anything containing 2% or more of sodium or potassium hydroxide. I’m not soap maker, but I’m assuming this is a statement that soap needs to be wrapped so that young ‘uns can’t wash their mouths out with it. I don’t think the government interpretation will take the argument that the lye isn’t lye once it’s soap even if that’s that correct argument. And since soap is a painfully boring subject to me, I’ll leave it to soapmakers to sort it out.

3)Anything containing 4% or more of methyl alcohol. This is found just about everywhere in US cosmetics: perfumes, shampoos, and any item relying on alcohol as a preservative. This definitely affects perfumers.

And, under drugs, but still relevant in cosmetics:

4)Anything containing 5% or more methyl salicylate. What’s that? Just wintergreen oil. Some dermatologist found out it clears up acne in a percentage of the population and got it classified as a drug. It definitely merits use with caution and a higher than 5% dilution.

What does that mean for those of us who make handmade cosmetics? We need to contact our packaging suppliers and make sure they’re carrying Safety Commission-approved packaging materials – and we need to keep making our stuff well. Ultimately I see these regulations as a good thing, as they’re all things we already need to be doing!

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References

1. Which for all intents and purposes may belong to the FDA and I just can’t unravel it beneath the many levels of beauracracy once government gets down to “agency.” [↩]