Product Labeling Change: Physical Address Petition Filed

Earlier this year, the HSMG (Handcrafted Soapmakers Guild) filed a Citizen Petition with the FDA to allow the change of the current regulation that requires a street address on cosmetic products, to be changed to allow a PO Box as the place of business on a cosmetic label.  Their argument focused on the personal risk associated with putting a home address on the label and the fact that a PO Box should be sufficient. I strongly urge all of you to comment with a clear, concise, short and professional note to the FDA why this change should be made.  You can comment on this petition here.

PO Boxes are sufficient

Parts of this Citizen Petition read:

“A large percentage of the individual who make handcrafted soap and cosmetics do so as home-based businesses, many of which are part-time and in addition to regular full-time employment outside the home. While a small percentage of these home-based businesses may have designated a small portion of their home as a tiny retail store and welcome customers, most reach their customers by going to the places the customers frequent, rather than opening their homes to the customers.

Safety and Security Considerations:

*For those who have home-based businesses and are not set up for direct sales in the home, placing their home address on a product label poses significant safety and security issues for themselves and their families.

*Customers, seeing a street address on the label, may assume that it is a business keeping “normal business hours” and show up unexpectedly. While the most likely reason for a customer to come to the “business address” is to purchase product, the other reason for a customer to search out the business is if they are upset of disgruntled for some reason or to resolve a complaint. In the latter case, if the customer finds no one home — or worse, a single woman or teenage child home alone– the safety of the home or the occupants may be threatened.

*A criminal, determining that it is a home-based business, may realize that there is likely to be valuable computer or other equipment located at the address and view it as a potential target.

*Illegal drug producers need sodium hydroxide (lye) in order to make methamphetamine. Suppliers of sodium hydroxide are getting more savvy, so those making methamphetamine look for other places to procure sodium hydroxide. Soapmakers legitimately use sodium hydroxide in the production of soap and frequently have 2-50 pounds in stock. The street address of a soapmaker is a veritable open invitation to a methamphetamine producer.

Proposed Alternative

*The United States Postal Service provides PO Boxes as a service. With recent Homeland Security enactments, complete anonymity through the use of a PO Box has been eliminated. Anyone who rents a PO Box must provide two forms of identification (including a photo ID) and must also provide their actual street address. For home-based, handcrafted soap and cosmetics companies, USPS PO Boxes are a suitable alternative to putting the street address on a product label

 

Bramble Berry’s official comment on this matter, to be filed with the FDA, is:

Division of Dockets Management

Food and Drug Administration

Dept of Health and Human Services

5630 Fishers Lane, rm. 1061

Rockville, MD 20852

Re: Citizen Petition (Document ID FDA-2012-P-0872-0001)

To whom it may concern;

Thank you for the opportunity to comment on this address and labeling issue. Bramble Berry Inc. supplies raw materials to soapmakers in the United States. Our primary customers are small businesses, making and selling soap, utilizing off-the-shelf ingredients and selling through wholesale accounts, online, craft and farmer’s markets, and direct home party selling. Generally, they live and work in the same facility that they produce their soap products in.

Because of this, putting a physical address on labels often feels unsafe. The labeling requirement for addresses is both so consumers can reach manufacturers in case of an issue and also so that a consumer can make an informed purchasing decision. Utilizing a Post Office Box, rather than a physical street address, would serve this need as well.

Thank you for your consideration in this matter.

Respectfully,

Anne-Marie Faiola

CEO, Bramble Berry Inc.

 

 

 

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64 Comments

  1. Linda says

    Thank you, Anne-Marie! I dislike having my my home address on all my labels and would much prefer to list a PO Box #. I hope the FDA will allow the change. :)

  2. Lena says

    How long would it take to pass? What is the reason to have a physical address? If it is for contact an email should be sufficient?

    • says

      Hi Lena!

      The original reason (and law) for having a physical address was so that if there was any issues with the product that the maker of said item could be contacted. But, because so many people are running their small businesses out of their homes the privacy issue has come up and many people do not feel safe with their home address on the products any longer. This petition is to get the law changed so that P.O. Boxes can be used. Currently, you do need an address and a phone number on your products.

      -Becky with Bramble Berry

  3. Lauri Strain says

    I received a letter from my Post Office saying that I can now use the Post Office’s actual street address where I have my PO Box. Does that work as an address? I know that being listed in the City Business Directory counts so you only need to put your City and Zip Code on your label. I put my phone & web address too just because I WANT to be found!

  4. Tony says

    I too, find this problematic. A few months ago, I received free business cards, but only wanted to give them to family & friends & not people I didn’t know. I just do not like the idea of placing my home address on anything for safety reasons.

    Before I received the business cards, I was looking for local Shea butter & found a website with an address posted. Since I had down time, I decided to go to this company after all my errands were made. Well low & behold, the company ended up being an actual home in a nice residential neighborhood. So instead of knocking on the door, I turned around & left. Legal or not, I refuse to place my personal address on my products. I have all my information on there accept for my address. I don’t sell a lot, but most of my products goes to family, friends or neighbors. With the awkwardness of my driving to the home, I think it’s best to use a non home address on business cards & products.

    • says

      I think your are right on the ball about this! So many people are selling and creating out of their homes and the privacy issue is a big one. Make sure you write a comment so that our lawmakers know this is important to the small-business community. :)
      -Becky with Bramble Berry

    • Diane says

      I signed up with google Adwords a few years ago. (i make signs and shirts). This does get attached to your physical address and many times I’ve had people call and ask if they can stop by my shop to look at samples. Last Christmas eve I was baking and answered the phone to a lady who wanted something made for the next day. I told her I couldn’t and as I hung up I looked outside to see the same lady sitting in front of my house! I have to find away around this.

  5. says

    Thank you!!!

    This has long been a concern of mine. I actually live on my college campus in married housing, and I do not have a physical address. I have to give the address of my college when I cannot use my PO Box number (which is provided to me through my college). It gets quite confusing at times!

  6. says

    I’m so glad this is being addressed. I’ve also not felt comfortable sharing my actual address on my products. We live in a crazy world full of weirdos and I have children to protect. I do what I’m sure most makers do and share my city, state, and a web address where from there you can find more detailed info to contact me by. I would love to see this changed. I’ll be writing on the petition too.

    I just love your blog. Always inspiring and helping our little business grow, learn, and stay informed! Thank you!

  7. says

    I filed my comment – I would love to be able to use a PO box. With small children at home I need to be able to keep them safe.

  8. says

    Thank you Anne-Marie for keeping us informed and helping us along I appreciate it.
    Mine is in the mail too! edit this if you like not a problem!

    Thank you for this opportunity to comment on the address and labeling issue regarding handcrafted soap. As a small business owner, 90 percent of my market is local farmers markets and gift boutiques. My business is 90 percent face-to-face. Because of this, putting a physical address on labels often feels unsafe, as people know when I will be at the markets. It is know that soap making requires sodium hydroxide, which is a desired by a dangerous element in our society. My labels include my phone number and email address and my clients do get in touch with me directly when necessary.

    I do not sell out of my home but pay a local craft store as a drop off point where my customers can pick up my products when the markets are closed. This works well for all concerned.

  9. Crystal says

    Shoot – this means I may have to redo my labels again, which is a major pain! I didn’t know this was the law and we specifically got a PO box for this exact reason!! I guess now I’m going to have to put the street address of the post office. At least thats now an option.
    Where can I go to sign the petition???

  10. Brian says

    I see a ton of soaps at the store that have nothing more than a city and state for location printed on them.
    If a physical address is required how do they avoid having to do it?
    I had thought that’s all that was needed.

    • says

      If your business is listed in the phone book (archaic – isn’t it?) then you can just have your business name, city and state on your label. With the assumption being that a consumer can easily find your physical address and phone number if needed. For more info check out Marie Gale’s book ‘Soap and Cosmetic Labeling’ it really clarifies these little details.

  11. says

    Thanks so much for this. While I am fortunate to have an off farm, totally seperate building for my soap studio with a completely different address I too am tired of the “physical” address issue. I am not set up for retail sales there; My retail tax licenses are for my farmers market locations, pick-up locations and online in-state sales -all have different rates- but for not my studio location. I’ve gotten so tired of people just showing up- it averages about 3 times a month someone just shows up. This puts me in the precarious positions of either A. selling them soap, hoping they aren’t actally the local tax people checking up and then me filing the tax later with my qtrly, or B: not selling and then ticking them off and losing a sale, losing a customer and possibly gaining a crappy reputation for refusing the sale.

    At my markets and shows I’ve had obvious to not so obvious meth-heads trying to quiz me on how to get lye in the guise of “wanting to learn how to make soap”, all the while looking like they haven’t used a bar of soap in weeks. I’m in a rural area (the Ozarks, actually ground zero for meth), I have a P.O. Box and it’s always listed with the physical address, but folks just don’t always get it. I’ve taken to putting on all my sites, liturature, line sheets and media and the door to my studio “Our soap studio is not set up or open for retail sales”. It doesn’t always work. I had someone knock on the door at 8:00 pm last spring!

    Hmm, I think my comment to the petition may be my comment here. Thanks again for the petition.

  12. says

    I have had people show up at my house expecting to find a store. Since I do have a full time job that takes me out of the house at times, I am not always there to provide the customer service people would expect. This could affect my business negatively and would easily be solved by not having to provide a physical address to begin with. People can call the phone number on my labels or use the web address. The safety issue in this case is secondary to me, but it still is a valid concern.

    Where is this petition so I can put my signature on it?

  13. Sondarya says

    Well, Not writing the address is a genuine concern for home based business.It should be limited to website address and a phone no or email address. I would add a number by adding my name to the petition, only if I knew, where to sign.

  14. says

    As a single mother, I took up an interest in soapmaking as a viable home-based business to “be there” and care for both my teenaged daughter and my elderly, blind mother. The thought of my mother opening the door to a meth addict is quite alarming to say the least.

    And what is to stop a local meth addict from locating your local business in the local phonebook or via “Whois” online? Nothing really. Given that sodium hydroxide is a prized commodity in the “meth netherworld,” it would seem to me that the best course of action would call for no address available anywhere except through contacting the Consumer Protection Agency and/or FDA. Surely the Federal government can do a quick background check with ease on anyone wishing to make a complaint or inquiry. Seems to me it’s another avenue to fight the war on drugs. If someone wishes to make a legitimate and serious complaint, they’re already talking to the right agencies to do so anyway.

    And though safety is a legitimate concern for all of us, here’s another reason for no address on labels. I don’t know about other jurisdictions, but where I live, the law doesn’t allow for foot traffic in and out of home-based businesses as it would disturb the “quiet enjoyment” of the neigborhood. So if I can’t have people coming to my home, there’s certainly NO NEED for my address to be on the label. I believe a phone number and an e-mail address would suffice.

  15. says

    I too would like to see the law changed to allow for the use of a PO Box. I am a single senior citizen female making soap from my home. I do not retail from my home, but instead sell from a local farmer’s market. Having my home address on the label is quite discomforting. A PO Box address would drastically reduce the possibility of someone (good or bad) from showing up at my home.

  16. Angela says

    I too would prefer to use a p.o. box address as opposed to my physical address. I run my business from my home and it is of concern to me that home address is floating out there to the public when I sell products. This more of a personal safety concern. Hoping that Washington will hear all of us on this one.

    Thank you for always keeping us updated.

  17. says

    I think gaining signatures via a change.org petition would go a long way as well. Personally I just list my city, state, and web address on my products. I have gotten several stalkers from markets and craft fairs I have done when I just listed my phone number alone on my business cards (not even on the product). And no, these people were not interested in becoming customers, they were interested in dating me, after I had told them multiple times I am happily married and have kids. Constant texts for weeks on end. I had to stop doing several markets and now make sure I have a friend there to meet me so I am not alone. If they had my physical address I am really terrified of what might happen. Also meth is very problematic in my area, so keeping lye on hand in the garage is just asking to be broken into if you put your address on the products. I want to get my own production space, but for the time being that is not feasible. I would love to list a PO box and be done with it.

    • says

      I think starting a petition with signatures would be a great idea to garner more interest for small business owners. Your experiences sounds really scary and I’m glad you’ve been able to be safe. If you come across one let us know and we will sign on it! :)
      -Becky with Bramble Berry

  18. aami k says

    so has this change been allowed? im just opening a home business and knowing this would really help :)

  19. aami k says

    definitely, so if i was applying for a business now i couldnt use a po box but would have to have my address on each product unless i get my address in the phone book, correct? sorry its all so confusing to me

  20. meg says

    My husband is going into law enforcement, an as such we’re highly discouraged from putting out our home address on anything. It’s become a concern with our labeling since he’s started the process. :/

  21. William says

    I recently was looking for some soap supplies and thought of Brambleberry. I looked it up in local businesses for Bellingham since I live in Burlington. I found it and was going to drive up since I really wanted to get a few items quickly. I looked on your website and saw there was a notation of some sort that said there was no business or store at that address. Something of that sort? So although I would love to be able to come buy some supplies I realized it was probably a home address or maybe just a warehouse address. I could see how that could be of concern especially for single women or women with kids. I put my two cents worth on the comments for the issue. I am still doing test batches for soap, detergents, lip balms, candles, etc. Everything I have made so far has turned out wonderful and I plan on starting sales soon as I am still doing my due diligence. Within 3 months I should be up and running. I also am concerned with this issue. Thanks Anne-Marie

    • says

      Good morning, William!

      The address on Bramble Berry’s website is the address for our warehouse, that isn’t open to the public. But, you are in luck, we do have a storefront in Bellingham called Otion which carries all of our products if you want to come up and take a look. Here is the link to Otion’s website:

      http://www.otionsoap.com/

      And you are correct, this is the sort of thing that many soapmakers and other crafters are worried about. They feel like having a home address on their products can be an invitation to have customers just show up on their doorstep. We’d love for you to leave a comment on this petition and let your lawmakers know your view on it.

      Thanks for leaving a comment.
      -Becky with Bramble Berry

  22. says

    1jx-83m2-uexx That is my tracking number for my comment. I really hope that this changes. I have a kid and there is no way I can put him in danger like this so if this doesn’t change then I may have to rent a store front and I can’t afford that. UGH! this is frustrating.

  23. Lori says

    When I started making soap I never even thought of any meth addicts and lye. I home school and have my mother living with me, customers coming to my door is not what I want. We live in the country and already have a problem with unwanted trespassers I do not need meth heads. When I open a shop I will have to keep a extra eye out for meth users along with at the shows as well. I have taught how to make soap to friends to I will pass this info along. Thanks for the info I pray it all goes well.

  24. Denise says

    It’s really contradictory.
    If the store name and address appear in the local directory, the address doesn’t have to be on the labels.

    Yet in most cities when a license is obtained, you have to abide by the “no customer traffic” laws.
    So, the cities should actually join in on being against the demand for a physical address.

    • says

      Hi Denise!

      We know how confusing and frustrating it is for our customers and that is why Anne-Marie always works so hard to make sure that these bills in legislation take into account all the small businesses out there. Thank you for comment and be sure to keep your eyes on the Soap Queen blog to get up-to-date news on these types of issues in the small business and cosmetics world from Anne-Marie. Have you checked out her latest post? You can read it here:

      Update on Cosmetics Act Legislation: http://www.soapqueen.com/bramble-berry-news/update-on-cosmetics-act-legislation/

      -Becky with Bramble Berry

  25. Doreen says

    I’m new to soaping and want to create a soaping business out of my home. This is so confusing and scary to me. Has there been any word as to how this is going?

    • says

      Hi Doreen – Fear not, there has been talk of legislation for years and nothing has ever made it out of committee =) We have lobbyists in Washington DC working just on this issue. The Soap Guild has one as well. And The Handmade Cosmetic Alliance has one. So between all three of us, we’re definitely making sure that legislators and lawmakers know and understand that any potential legislation must contain a small business exemption. =) If anything at all relevant changes, I will 100% update the blog with a new blog post. And, here is a link to the Handmade Cosmetic Alliance. They also have a news page and are watching out for small business interests. http://www.handmadecosmeticalliance.org/ Donna Maria from Indie Business Network also updates on these issues: http://indiebusinessnetwork.net/ But in a nutshell, I wouldn’t worry =) Congress is pretty preoccupied with immigration reform right now (and last month was gun control and next month will be something else) =)

  26. says

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  27. Ally says

    Has there been any updates on this yet? I’m getting ready to sell in a few months. Thanks for all of this information Brambleberry!

    • says

      Hi Laura,
      Unfortunately, a full address is still required. Here is the verbiage from the FDA website: “A post office box or website address is not adequate for this labeling requirement.

      The FD&C Act requires cosmetic labels to identify the name and place of business of the manufacturer, packer, or distributor. By regulation, this includes the street address, city, state, and ZIP code, although you may omit the street address if your firm is listed in a current city or telephone directory.”

      You can read the full article here: http://www.fda.gov/Cosmetics/ResourcesForYou/Industry/ucm388736.htm#11

    • says

      Hi Lydia!

      The FD&C Act requires cosmetic labels to identify the name and place of business of the manufacturer, packer, or distributor. By regulation, this includes the street address, city, state, and ZIP code, although you may omit the street address if your firm is listed in a current city or telephone directory.”

      You can read the full article here: http://www.fda.gov/Cosmetics/ResourcesForYou/Industry/ucm388736.htm#11

      I hope this helps :)

      -Amanda with Bramble Berry

  28. Ginger says

    Has this been approved? Or is it still the same as always? Placing your entire address on the label?

    • says

      Hi Ginger!

      I did a little research, and according the the FDA’s website, it appears that the entire address is still required. You can read more about this on their website, under the “21 CFR 701.12″ section :)

      FDA Labeling Regulations:
      http://www.fda.gov/Cosmetics/Labeling/Regulations/ucm126444.htm

      It states, “The business address must include the street address, name of the city and state, and the ZIP code. The street address may be omitted if the firm is listed in a current city or telephone directory.”

      I hope this helps!

      -Amanda with Bramble Berry

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