Month: August 2019

ALPHA HYDROXY ACIDS

AHA are used in some cosmetics and drug products applied to the skin. Cosmetic products containing AHAs are marketed for a variety of purposes, such as smoothing fine lines, improving skin texture and tone, unblocking pores etc. AHA containing products cause exfoliation or shedding of the surface skin. The extent of exfoliation depends on the concentration of AHA and other ingredients in the product.

Some products that contain high concentration of AHAs or other acids act as skin peelers. Such products are regulated as drugs by FDA. For example, acne treatment products or skin lighteners are considered drugs. FDA has received many adverse reports for AHA containing products listing adverse reactions such as skin burning, peeling, rash, swelling, blisters, increased sunburn etc. FDA has found that applying AHAs to skin results in increased UV sensitivity.

FDA recommends using AHA containing products strictly according to the label directions. It is advisable to use skin protection. FDA also recommends that the labeling of a cosmetic product bear a statement that conveys the following information:

Sunburn Alert: This product contains an alpha hydroxy acid (AHA) that may increase your skin’s sensitivity to the sun and particularly the possibility of sunburn. Use a sunscreen, wear protective clothing, and limit sun exposure while using this product and for a week afterwards.

Liberty Management Group Ltd can help you make sure all elements of your product label are compliant to FDA regulations. LMG provides a wide range of services assisting companies with label compliance, ingredient compliance, FDA registration etc.

Namrata

FDA Regulatory Consultant

support@libertymanagement.us

http://www.fdahelp.us

Published on: August 29, 2019

CBD in Foods and Dietary Supplements

There has been growing interest in the development of consumer products derived from cannabis and its components including CBD-Cannabidiol. FDA has found that many companies are marketing products containing CBD that may put consumers health at risk.

By far FDA has approved only one drug containing CBD for treatment of seizures. But FDA has found that many other CBD containing products are being sold in market, some as dietary supplements. As per FD&C Act, if a substance is an active ingredient (such as THC or CBD) in a drug that has been approved by FDA or is the subject of an IND – Investigational New Drug, for which substantial investigations have been instituted, then products containing such substance are excluded from the definition of dietary supplements. Exclusion from the definition of dietary supplement means that it is prohibited to market such products as dietary supplements.

If a product contains ingredients from such a part of cannabis plant that does not contain THC or CBD, then it may be marketed as a dietary supplement however it must comply with all applicable laws and regulations governing dietary supplement products. Such manufacturers who wish to market dietary supplement that contain new dietary ingredients that were not marketed in US before October 15, 1994 must notify FDA about these ingredients demonstrating that such supplement is safe under the conditions of recommended usage suggested in the labeling. In addition to NDI-New Dietary Ingredient notification, compliance to labeling and cGMP requirements specific to dietary supplements must be met.

If a non-THC or non-CBD ingredient derived from a cannabis plant is added to food products, such food ingredients are subject to premarket review and approval by FDA unless the substance is GRAS -Generally Recognized as Safe, by the experts under the conditions of its intended use. FDA has so far received and accepted only 3 GRAS notifications for hemp seed ingredients. Food companies that wish to use cannabis derived ingredients in their food products must abide by the laws and regulations including food additive petitions and GRAS notifications.

It is important to know the regulatory status of an ingredients that is added to any food or supplement. Liberty Management Group Ltd. can help you with Ingredient compliance, FDA registration, Label compliance and other FDA regulations.

Namrata

FDA Regulatory Consultant

support@libertymanagement.us

http://www.fdahelp.us

Published on: August 14, 2019