PO Box Petition

One of the issues facing soap and cosmetic handcrafters is the fact the full street address of the manufacturer is required on product labels (if the business is not listed in a print city or telephone directors). In that many handcrafters work from home, that means that their home address is required on the label. This can be an issue for many handcrafters who do not, or cannot, receive customers at their homes, and has the potential of causing security issues for them, putting them at risk.

In August 2012, the HSMG submitted a Citizen Petition to change the wording of the existing labeling regulations to allow a USPS Post Office Box in lieu of a street address on product labels. As of filing, the FDA had 180 days to respond.

On February 1, 2013, the FDA responded with an Interim Response, which stated they have "not been able to reach a decision".

Amended Petition

In November, 2014, the HSCG submitted an Amended Petition to the FDA with additional information (our new name and new demographic information).

Final Response

Finally, in late 2014, we received a Final Response to the original petition. The letter is 6 pages and summarizes in great detail the FDA's thought process and methodology in denying the petition.

The Good News

To recap the regulations, the full address of the business is required on a cosmetic product label, but the street address may be omitted if the business name is listed in a current telephone or city directory (city, state and zip are always required).

While FDA denied the petition to use a PO Box instead of a street address (when the street address is required), in the content of the response, the FDA made a very important statement. They said:

Telephone directories are published both in print and online, and a listing in either would satisfy the option under 21 CFR 701.12(d) to list a street address in a current city directory or telephone directory, if the street address is not included on the product label.

Following the quote above, the letter goes on to discuss different types of directory listings available for phone numbers, and includes (in a footnote) www.localpages.com (800-296-7104), smallbusiness.yahoo.com, www. yellowbook.com, www.yellowbook360.com (866-929-3556), business.thewebmap.com and www.yellowpages.com as examples where listings may be obtained. The implication is that listings in this or similar directories would meet the regulatory requirement for listing in a "current telephone or city directory".

This is good news! There are now easy, accessible, fast and cost-effective ways to meet the requirements to omit the street address from the label by getting your phone number listed in a suitable directory - you don't need pay for a business phone line and wait for the local phone book to be published!

Those who have had issues with publishing their street address on their labels now have options for legitimately omitting their street address and still maintaining compliance with the regulations.