Why Small Business Should Oppose FDAG 2009 Cosmetic Legislation

The FDA oversees the Good Manufacturing Practices (GMP) of cosmetics. These are a set of guidelines through the FDA and not current legal requirements. The Energy and Commerce is considering either through revision of the currently pending FDA Globalization Act of 2009 (FDAG 2009/HR 759) or through an entirely new bill to be introduced in the future, to:

1. Make mandatory that all cosmetics companies register their facilities, the products they make and the ingredients contained in those products in a federally maintained database; Naturally Green opposes any new legislation that imposes product and ingredient registration, unless legislation contains an exemption to small businesses.
2. Craft a new set of Good Manufacturing Practices (GMP) Guidelines applicable to all cosmetic companies big or small; Naturally Green opposes mandatory compliance, unless legislation contains an exemption for small business.
3. Include provisions dealing with ingredient safety. Naturally Green opposes any legislation that requires premarket testing of cosmetics made from ingredients that are already confirmed as unharmful.

The FDAG 2009 contains a mandatory registration requirement requiring registration of company name and contact information in addition to each product ingredient to be registered. If this new law passes, Naturally Green will be required to register each new product introduced into the market prior to the marketing of the new product in addition to each ingredient contained in each product.

Small companies who distribute small quantity products such as Naturally Green will be impacted by the new FDAG 2009. The Energy Commerce committee should not consider applying the same FDAG 2009 proposed regulations to small business unless there will be an exemption to small business because we are not on the same playing level as big business.

Naturally Green is currently voluntarily registered with the FDA Voluntary Cosmetic Registriation Program(Registration #E1003042), however, we oppose the new law FDAG 2009. This new law should be developed based on the size of the company and not applicable to big and small companies alike.

Please support Naturally Green's efforts in opposing the FDAG 2009 by blogging your comments here.

Kini Johnson
Naturally Green, LLC.