If you have not yet registered your manufacturers, distributors and packers of cosmetics with the FDA’s Voluntary Cosmetic Registration Program, WB Skinner recommends that you consider doing so.

Click here to visit the website for importers to register.

• Although the program is currently voluntary, it may soon become a regulation and we highly recommend that, at a minimum, you become familiar with the site now.
• Getting to know the VCRP site will help you better understand why some products may get held up. Claims, labeling and marketing are some of the factors FDA looks at in potentially holding up shipments.
• If your Cosmetic Product Ingredient Statements (CPIS) are registered with the FDA, release of your goods MAY be quicker.

If your products are registered with the FDA, and a problem arises, we believe that if the FDA has a record of your product, it may give you as the importer more leverage in dealing with the agency and securing a quicker release. And if/when the program becomes compulsory, you’ll be that much ahead of other competitors in your industry.

• Is your cosmetic product actually considered a drug? Does it have an active ingredient or is it all natural? Labeling and marketing are two of the ways FDA checks on products, ensuring that claims of cures or prevention are carefully backed up.
• Are there descriptive words that signal potential issues with the FDA? As an example, “all natural anti-wrinkle cream” could be flagged as a drug, because it indicates it will prevent wrinkles.
• Antiperspirants are another word that will capture attention from the FDA. Deodorants do not contain drugs that stop perspiration while antiperspirants do.

Registering on the VCRP site can help you become familiar with these issues and how to identify and prevent potential problems with your own shipments.

Check back here at wbskinner.com for updates or contact us for more information.

Best Regards,
Julie Hartenfels
Vice President, Compliance Officer
Julieh@wbskinner.com
201-644-7214