Right now, Floridas laws and regulations for this industry are costly, burdensome and, in many instances, unnecessary. The ingredients cost me almost $36.00 total or $6.00 per tin. If you set it up so your business in Georgia makes the products and then sells them wholesale to your business in Florida, your business in florida is just like any other retailer, selling products it purchases to resell. Could i make bath bombs and label them to be used for FUN in the Tub purpose. In order to be exempt from the cosmetic manufacturing regulations, it must be true soap, and only marketed as soap without any other cosmetic claims. You are still responsible for making sure your ingredients are safe when used according to the labeling, or as they are customarily used, no matter what kinds of ingredients you use. Answer:Yes, you need a couple of licenses: For example, to Buy Wholesale, or if selling Body Scrubs, you need a SELLERS PERMIT. I expect it would be up to the inspector to determine if it is still residential or not. Again, it depends on what the hand soap is made of and how you market it. You also want to avoid anything that could be perceived as offensive or suggestive. If you are labeling them in-house in Florida, then you are a relabeler, which needs a cosmetic manufacturing license as far as I can tell. Soap, if it is exempt from the definition of a cosmetic, and candles are not cosmetics and do not need a cosmetic manufacturers license. So in Florida, in order to make (manufacture) cosmetics and lip scrub is a cosmetic you must get a license as a cosmetic manufacturer from the state, pay the fees and get inspected. If it is given with a product that is sold, then it is considered part of the sale (and therefore a consumer product) and must be properly manufacturer and labeled. Do I need a permit? The only thing that is exempt from the definition of a cosmetic is a product that is primarily the alkali salt of fatty acids (lye/oil/water soap) AND is marketed and sold only as soap. Any product that makes those claims that is not otherwise approved by the FDA is an unapproved new drug. My mistake was not staying with just soap. This is a great article, and Im excited to look at the rest of your site in more depth. Tricky. However I cannot seem to find any info for CT. Where should I ask? Try continuing to call the department, but also send a letter or a fax. What kind of feeling do you want your customers to have when they think of your sugar scrub brand? Over-the-counter drugs are ones that already have safe specifications and the product must meet those specifications for active ingredients and exactly what can be said about it. However if I wanted to start selling privately to friends and family only how would I go about doing that? That way I manufacture my products in another state. Being that this just went into (official) effect on July 1st, 2017, Id say its safe to presume that it will take many administrative hours to update all connecting documentations and forms with the new information that just passed. 1) The bulk of the non-volitile portion is the alkali salt of fatty acids (that is, made with lye/oil/water, not a detergent) Hi, So If I only make SOAP, I can run my soaping business from home? I personally wouldnt consider them cosmetic but Im thinking the state of Florida might consider them that. You may have local zoning regulations pertaining to where a business is located. In answer to your first question I dont know what the State of florida would think about your manufacturing in AL. Thanks. The key for FLORIDA regulations is that cosmetic manufacturers must register and get licensed. Also, was going to sell bubble bars but they have Cocamidopropyl Betaine ( Coco Betaine) which is made from coconuts and is for bubbles. Second is MAKING the product. I printed an application for a permit, and on one of the questions it asks: I have heard rumors that enforcement is changing in Florida, but you should check with Florida State for the current information and to find out if they are allowing any exceptions. Thanks again I really appreciate your advice. As per (b) above, the products you can make are limited to: I think they were trying to limit exempt cosmetic manufacturers from making the more risky items such as like products that go on the eyes or lips. You can apply online at the TDA Website. 2. The GMP is at the level that would be required to manufacture ANY drugs so as you can imagine they are very detailed and exact. You dont have to be a certified anything in order to manufacture cosmetics, although you must show that you can manufacture cosmetics safely. Can you please help me? The actual questions are below., They are slightly edited for readability and I have bolded and colored the questions that will probably be the most problematic: Once you have paid your fee and submitted the application, your facility must be inspected and pass before you can start legally making cosmetics. A company (with all the registration and such in place) makes the product for you, complete with seal and label. First crush doesnt include an ingredient or make a claim. Florida doesnt require labels to be submitted for cosmetics, but they may have an interpretation as to whether a listing in Sunbiz would be sufficient for omitting the street address. The requirements are covered in Florida Rules 61N-1.010. (The link goes to Amazon.com and opens in a new tab or window.). Is there any regulation for adding beer into the soap? If the people you teach think they are now versed enough to sell their products, they should be informed of the laws and regulations; in any event, you should should VERY clear that the products they are making are for personal use only not for sale. Do I need to register my cosmetic firm or product formulations with FDA? Have you heard anything new since the original post? A(n) Sugar Scrub Store business doing business under an assumed business name in Maricopa County i.e. Trying to figure out, before I contact them. Its a large fee for the permit and I want to be sure we are properly prepared to go into this line of business. What I found interesting was these two requirements; Remember, its not just ventilated it must be suitable for good manufacturing practices and provide a clean, safe production site that is set up in a way that product is unlikely to be adulterated when made or stored there (and ingredients are unlikely to become adulterated when waiting to be used). Ive been looking for a issue on line and have not been able to find one. If your product is a drug under U.S. law, it must meet the requirements for drugs, such as premarket approval. You need to understand the ingredients in the soap base in order to determine or check with the supplier. No other surfactants (detergents) used. We have a question. This is where Im getting confused. 3. I appreciate any your help The OTHER things you need (licenses, etc) arent about soap, but arer about your BUSINESS (same as most any other business). Only cosmetic manufacturers are limited to not making products in a residence. For everyone worried about making soap in your home. Do I need a license to sell my product? - Legal Answers - Avvo We are starting our soap and scrub business and were unaware of the restrictions here in FL. So i just want to be clear, I cant make any cosmetics from my home and sell them online. I dont advertise or list my products as cosmetic items. Hello, I live in Florida. The long answer is still no, but there are vital steps you need to take in order to avoid penalties and operate a legal soap-selling business. First, you want to make sure the name is memorable and easy to spell. Wading through all the regulations is NOT for the faint-hearted. Weve also included links for learning more on each topic. It clears a few questions up for me. For soap to be exempt from the definition of a cosmetic (and thus the cosmetic manufacturer regulations) the bulk of the product must be the alkali salts of fatty acids (that is, it is made from the saponification of oils with sodium or potassium hydroxide) AND it must be marketed only as soap AND it can only claim to clean. Hi Marie! just not sure about the other products. You ought to be able to find someone in the right department at the state capitol who can help with these things. While you SAY you wont forget, sometimes it is easy to just lose your place on what you are doing. The Departement of Cosemtology would cover hairdressers, nail techs, barbers, etc. Is that illegal? Loose organic tea would fall under food regulations. Im not sure what the regulations are for those who teach in Florida; the regulations I was discussing have to do with cosmetics manufactured for sale. You might check that. There is a small business exemption for businesses which have less than $25,000 annual revenue (from cosmetics) AND which make only certain limited products. Whether the location of your manufacturing facility needs to be in a manufacturing or commerial zone is normally a factor of the local (city or county) requirements. Any color additives they contain must be approved for the intended use, and some must be from batches certified in FDAs own labs. See the regulation on name and place of business at 21 CFR 701.12. This allows you to pick the cheapest days to fly if your trip allows flexibility and score cheap flight deals to Grenoble. Many of the ingredients theyre dealing with in large enough quantities that they can purchase cheaper than you could. We can respond to specific labeling questions, but cosmetic labeling is not subject to premarket approval by FDA. One that I already have in NJ and open another business in Florida just for sale . I dont know if I want to live there if I can only make soap. No bathroom or sink, since its a storage unit, but after the batch is done, all the dirty dishes (which are strictly for making the balms) gets taken home and washed very thoroughly with its own special soap. I want to open a business in Miami, my goal is buy powder tint for hair (ready to use) and re-pack it into personal amounts. How about its the most fun anyone can have in the tub (c)? Your email address will not be published. If I make and sell soap I can do it at home in Florida correct? Is MP soap a soap or cosmetic? Do you know requirements for facility where you can manufacture cosmetics in Florida. Even though, technically, theres no prohibition (as far as I know) to making products in a motel room in Georgia, youre essentiall saying that a cosmetic manufacturer in Georgia made the products for your business in Florida. Do I Need A License To Sell Sugar Scrubs Register Sugar scrubBusiness in WI I have read the bill content and then I did go to the DBPR website. Then would it be legal since your not actually manufacturing? Greatly appreciate your knowledge. I still c it as soup but does the law in FL c it as cosmetic ? It took me some time, but I have read through this whole post and all of the above commentsI have even contacted John about the Florida Cosmetics Manufacturers Coalition. Okay so though about it, it was a stupid question, if I would be making the products in Florida I would still have to follow Fl regulations and law. Drug manufacturing facilities must be registered and approved at both the federal and state level. Do those items fall under the cosmetic manufacturing requirements? it is not a cosmetic and not a drug. (the people buying the empty lip gloss tube will more than likely make their own products). I was literally super confused about what I can and cant do at home and when I spoke to someone regarding what license I would need to sell my products I specified that I wanted to sell from home and she said absolutely nothing about it. By following this process will help ensure that you have the equipment, tools, and supplies you need to run your business smoothly. There arent any additional federal regulations covering them; I dont think there are any additional regulations in Florida (but I havent checked in depth). At a federal level, bug repellents are overseen by the EPA (Environmental Protection Agency). From my point of view, Product registration is nothing compared with the actual facility requirement. Im not making any claims! An establishment that is a place of residence may not receive a permit and may not operate under this part. So I source a legal supplier, and simply re-label for my business. and let me know what happens! I feel lost in the crazy rules in Florida, Ive found some people that charge a hefty hourly fee for consultation but I simply cannot afford to pay it!! For making bath bombs or shower gel, you need to be registered and licensed as a cosmetic manufacturer in Florida. That is good for 2 years. Under the Cottage Law, I can make my own teas, correct? Do I need read more. Or would it be considered soap since it has what is considered soap in it? The .gov means its official.Federal government websites often end in .gov or .mil. Bath bombs ARE a cosmetic. Where you sell really depends on your business plan and marketing program. My husband and have started and run several businesses but nothing has been as confusing as this.