Tools and directories

The check, before the first batch

Updated October 2026

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One: rinse-off or leave-on, per product?Two: if rinse-off, what is the exfoliant made of?Three: is the safety substantiated, per finished product?Four: does the jar take the fill, and does the liner take the oils?And decide the warnings you believe in Keep retained samples through a summer File it per product One of the four has no second chance References

Four questions. The first one has no labeling cure if you get it wrong.

One: rinse-off or leave-on, per product?

Decided by whether customers will rinse it rather than by the instructions or the category convention. If it is dual use, treat it as rinse-off, because the asymmetry runs that way: one choice costs an ingredient, the other is a prohibited act.

Two: if rinse-off, what is the exfoliant made of?

Any solid plastic particle under five millimeters intended to exfoliate or cleanse is prohibited. Get the material in writing from the supplier, because a trade name is not an answer and some lawful alternatives have synthetic-sounding names.

Three: is the safety substantiated, per finished product?

Each ingredient and each finished product, before marketing. A new scent in the same base is a new finished product for this purpose. The alternative is a conspicuous warning that the safety has not been determined.

Four: does the jar take the fill, and does the liner take the oils?

Check the published maximum fill temperature against your warm pour, and ask the closure supplier about the liner with your carrier and your essential oil loading named.

And decide the warnings you believe in

A cosmetic label bears a warning whenever necessary or appropriate to prevent a health hazard. For body care, sensitization, phototoxic citrus oils, use in pregnancy and not-for-broken-skin are the honest candidates.

Keep retained samples through a summer

Graining, separation, hardening and liner failure are all slow and some are seasonal. A filled, sealed, dated sample opened at intervals is the only measurement of your package rather than your recipe.

File it per product

Classification, exfoliant material where it applies, substantiation entry, container with its fill temperature, and liner with the supplier’s position. Adding a scent adds a row.

One of the four has no second chance

Substantiation can be completed late, a jar can be changed and a liner can be swapped. A rinse-off product already manufactured with a plastic exfoliant cannot be fixed by any of those, which is why it is first.

References

21 U.S.C. 331(ddd), which prohibits the manufacture or the introduction or delivery for introduction into interstate commerce of a rinse-off cosmetic containing intentionally-added plastic microbeads, defines a plastic microbead as any solid plastic particle less than five millimeters in size intended to be used to exfoliate or cleanse the human body or any part thereof, and provides that rinse-off cosmetic includes toothpaste. law.cornell.edu

21 CFR 740.10, which requires each ingredient and each finished cosmetic product to be adequately substantiated for safety before marketing, and makes an unsubstantiated one misbranded unless it bears "Warning - The safety of this product has not been determined" on the principal display panel. law.cornell.edu

21 CFR 740.1, which requires the label of a cosmetic product to bear a warning statement whenever necessary or appropriate to prevent a health hazard that may be associated with the product. law.cornell.edu

21 CFR 701.3, the cosmetic ingredient declaration, which requires ingredients in descending order of predominance on the label of a cosmetic in package form. law.cornell.edu

Written from federal statute and from measured catalog data, not from a formulation bench. Whether a particular particle is a plastic microbead within 21 U.S.C. 331(ddd) is a question about that particle and its purpose. Nothing here is a determination about a specific exfoliant or a specific formula.