# Label Claims



## tlcnubians (Jan 21, 2011)

I'm looking for input from a few of you who are more knowledgeable about this than I am  The people who make this product must have a sales rep or else they're really out there pushing it because it's starting to show up in a lot of local retailers and I just recently received a spam email from Livestock Concepts touting it. To me, they're really pushing the envelope on their label claims: . . . "our strongest formula, ready to tackle your toughest aches & pains caused by swelling due to Arthritis , Fibromyalgia, Gout or Injury. Our goat's milk base carries our natural blend of 6 Essential Oils deep into your joints and muscles. German Chamomile, Lavender, Rosemary, Peppermint, Eucalyptus and Birch Bark work together as both an anti-inflammatory and an analgesic. Begin feeling relief instantly, while daily applications have a cumulative effect. Finally, pain management you can feel good about, with a delicate scent, not a strong unpleasant medicinal odor." 

When I emailed the lady at Livestock Concepts to ask whether the manufacturer had received FDA approval for this product, she responded, "Several years ago the FDA took many herbal and vitamin products away from having to be approved. The FDA has what they call a bioactive ingredient list, and has told the manufacturer that they have nothing in their product that they have to have a approval for claims."

So, what do y'all think about this? Me, I think they're skating on pretty thin ice . . .

Caroline


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## jdranch (Jan 31, 2010)

feeling the same way you do about it. Sounds like it pretty much cures everything though- may need to get some


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## hsmomof4 (Oct 31, 2008)

Those are definitely medical claims. They compound the problem by having someone dressed up like a doctor as the main picture for this product on their website.


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## [email protected] (Sep 18, 2008)

I thought claims like this had to have a disclaimer. ??? Like:
"This product has not been evaluated... Please consult a physicial.... YMMV...."
That type of stuff. :/

Heck, if this is true..what's to stop someone from making a soap with fruit juice high in antioxidants and claiming it prevents cancer? Craziness!!


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## hsmomof4 (Oct 31, 2008)

Actually, I'm not so sure those disclaimers carry much weight if you are outright saying, "My product will cure X, Y, and Z!" but are reserved for more nebulous things, like "supports heart health" which means pretty much nothing. But any enforcement on something like this is probably pretty non-existent.


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## LynninTX (Oct 25, 2007)

Are you talking about the item that comes in the cobalt blue bottles? My feed store carries it now and I was fairly surprised by the label....

heck I hesitate to say my coffee soap is good for onion & garlic odors... I say "Great kitchen or mechanics soap!!"


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## MF-Alpines (Mar 29, 2010)

Slightly OT, so how do you go about claiming "moisturizing" or "soothing" or any of those "cosmetic" words. I know it's legal, but HOW do you do it so that it IS legal? In other words, how DO you get approval from the FDA (or whoever)?


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## hsmomof4 (Oct 31, 2008)

From a strictly legal perspective, if you using any of the cosmetic words, you're supposed to label it as if it's a cosmetic (ie, complete ingredients listed in descending order by weight, using INCI nomenclature, etc) like you would label lotion. You don't need approval from anyone.


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## MF-Alpines (Mar 29, 2010)

hsmomof4 said:


> From a strictly legal perspective, if you using any of the cosmetic words, you're supposed to label it as if it's a cosmetic (ie, complete ingredients listed in descending order by weight, using INCI nomenclature, etc) like you would label lotion. You don't need approval from anyone.


That's it? Really? I've been avoiding those kind of words, in both my literature and when talking to people. Currently, my label lists ingredients by weight, but not the INCI nomenclature.

I wonder if it would be too hard for people to read if I used the INCI verbiage? Anyone have any thoughts on this?


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## Faye Farms (Sep 14, 2009)

But isn't the company the OP is talking about making medical type claims? That is a whole different can of worms than cosmetic claims.


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## hsmomof4 (Oct 31, 2008)

Yes, it is. But Cindy said



> Slightly OT, so how do you go about claiming "moisturizing" or "soothing" or any of those "cosmetic" words. I know it's legal, but HOW do you do it so that it IS legal? In other words, how DO you get approval from the FDA (or whoever)?


So I was answering that. Medical claims are another matter entirely, and you absolutely need approval to do that legally, because medical claims turn your product into an over-the-counter drug. Not a good place to go, IMO.

If you use INCI, you can put the ordinary name in parentheses, though it makes for a long label. For example: Olea Europaea (Olive) Fruit Oil.


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## tlcnubians (Jan 21, 2011)

Lynn - yes, that is exactly the product I'm talking about. I've been watching them expand their territory for the last couple of years and continuing to wonder how they get away with making the medical claims they seem to be making on their product label . . . Caroline


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