A foaming product with no caution

How it happens

A maker reads 740.17, sees "foaming detergent bath products", and concludes it applies to bubble bath and not to their foaming bath soak or their fizzing bomb with a surfactant in it. The definition is functional.

The test, again

Intended to be added to a bath for the purpose of producing foam, and containing a surface-active agent serving as a detergent or foaming ingredient. Both limbs, and a product meeting both is inside whatever it is called.

Which catches foaming bath bombs

A bomb formulated with a surfactant to produce foam rather than only fizz is doing exactly what the definition describes. The fizz is not the relevant part; the foam and the surfactant are.

And the directions are missed more often than the caution

The paragraph requires adequate directions for safe use as well as the caution. A label with the caution and no dosing direction has satisfied half of it.

The adults-only route has to be real

Labeling a product as intended for use exclusively by adults is the exemption, and it has to be how the product is actually presented. A line of small print under children’s packaging is not that.

Fixing it is a reprint

The caution and the directions live on the label, so a correction means new labels. Deciding the audience before the artwork is the whole saving.

Three positions, chosen deliberately

Adults only with no caution, for children with the caution plus the supervision phrase, or general use with the caution as written. Any of the three is fine and drifting between them is not.

Read the definition, not the heading

The heading says foaming detergent bath products and the definition says intended to produce foam and containing a surfactant. Headings describe the typical case and definitions decide the actual one.

References