A deodorant claimed to stop sweat
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How it happens
A natural deodorant works well, a customer says it keeps them dry, and that becomes the marketing line. "Keeps you dry", "stops sweat", "no more wet patches" are all claims about reducing perspiration.
What it creates
An unapproved drug. An antiperspirant is a drug product that reduces the production of perspiration, and a product represented as doing that is one whether or not it contains a monograph active.
And the monograph is not then satisfied
No listed active at a permitted concentration, no antiperspirant identity statement, no Uses phrase from the menu, no four warnings, no Drug Facts panel. The claim brings all of that and the product has none of it.
The honest claims are still good ones
Controls odor, lasts through the day without reapplying, no baking soda, no aluminum, gentle on skin. All specific, all about odor or composition, and none of them a statement about sweat production.
"Aluminum free" is a composition claim and it is fine
It is also a useful one, because the monograph actives are aluminum compounds. Saying what is not in the product is a different act from claiming what the product does to a gland.
Check the reviews you quote
A customer testimonial about staying dry, reproduced on your own site, is your claim once you publish it. That is the route by which careful label copy gets undone by a marketing page.
Audit everything, not just the label
Listings, the website, social posts, email, influencer briefs. The label gets reviewed and the rest does not, which is the same finding four other properties here reach under four other statutes.
Write the claim rules down for whoever writes copy
One page listing what may and may not be said, with the reason beside each. The label gets lawyered and the Instagram caption does not, and the caption is where this actually happens.