One of our members emailed me about the requirements for cosmetic manufacturers in Florida. Their law, enacted July 2008, requires all cosmetic manufacturers to register their facilities and products with the state every two years. The registration fee is $250 – $400. In addition, every product manufactured must be registered, at $30 per product. (Luckily, variations in scent or color don’t count as a unique product.)

The registration process includes submitting the application form, the list of products and the label for each product. Any changes to any products or labels must also be reported (the fee is reduced if there is less than 12 months left on the existing registration). A product that has not be registered may not be sold.

The application form lists out all the items that are included as “cosmetics”. The list is extensive and covers just about everything that and handcrafted soapmaker might make.

If you reside in Florida and are going through the application process, keep in mind the permit application requirements:

• Must be 18 years of age
• Establishment cannot be a place of residence
• Must be done on forms provided by the state

Soap is specifically exempted from the definition of a cosmetic. However, if you make any cosmetic claims about your soap, then it would qualify as a cosmetic and require all the necessary registrations and reporting.

These rules are not unlike the proposed FDA Globalization Act of 2008 requirements.

I’d like to hear from anyone who has gone through the registration process in Florida … or decided to change their business (or move) because of it.

Marie Gale, President