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Skin-Care Claims Before And After FDA Warning Letters

This article was originally published in The Rose Sheet

Executive Summary

A side-by-side comparison of product claims cited in FDA warning letters and updated claims being used by recipients following their compliance work with the agency. The analysis could provide cues as to promotional language that can be employed without provoking a regulatory response.

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FDA Warning Letter Recipients: Where Are Their Claims Now?

A key component of FDA’s enforcement strategy in the cosmetics space is monitoring companies’ websites for overreaching product claims and issuing warning letters accordingly. Examination of past offenders’ current sites and updated claims offers potential visibility into language the agency will and will not tolerate when it comes to promoting skin-care benefits.

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