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FDA Labeling of Cosmetics Containing Nanoscale Materials
Volume 5, Issue 1

John C. Monica, Jr., Porter Wright Morris & Arthur LLP

Numerous products are regulated by the U.S. Food & Drug Administration (the “FDA”) that contain nanoscale materials. As more products come to incorporate nanomaterials, the number of products correspondingly regulated will only increase. The FDA does not currently require labels stating that products incorporate nanomaterials. The position of the FDA not to require labels indicating that products contain nanomaterials has been controversial for some advocacy groups. In this article, John Monica examines existing cosmetic labeling requirements in the context of recent calls by advocacy groups for special labels for cosmetics containing nanoscale materials. Mr. Monica concludes that while the FDA has made a serious attempt to address cosmetic nano-labeling issues, a more rigorous analysis of some nano-labeling arguments is necessary.

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