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I have gone back and forth trying to decide if I was going to chime in on this thread or not. Obviously I have landed on the side of chiming. Lol But I am probably going to ruffle some feathers here, so I am going to write my piece then shut up about it. I am not trying to change anyone's mind, zI just want to offer a different perspective.
Let me start off with saying that I have not looked over this woman's site, have not seen her labels, nor do I know what she sends out with what products. Without that info it is difficult to (really) say how non-compliant she is with regs, if she is. But I see no blatantly "false advertising" except for the word "cure" in the cold/flu tincture. For that, she would get a written letter advising her to alter her word choice and that is all (unless she has failed the correction previously).
I wonder if many of you are reacting to the fact that she sells tinctures and that they have grain alcohol as a prominent ingredient. Tinctures have been made and used as remedies for various maladies for centuries. They are quite effective for many ailments and are always made with grain alcohol, that is normal. Additionally, the amount of alcohol used is pretty much a standardized amount that goes by ratios (they range from 1:1 for fresh herbs and up to 1:4 for dried herbs, depending upon the particular herb).
As for the herbal warnings, some people only use those herbs that are considered safe for all when making their tinctures, which is possibly why there are no warnings. Or, if she does sell some that have properties that could interfere/react with certain conditions or medications, she may label them accordingly. We don't see the actual label, so have no way to know.
As I said, I do take exception to her using the word "cure", as I have never known a tincture to "cure", only to lesson the symptoms, help build immunity to prevent symptoms/ailments, and to help to shorten the length of time that symptoms are present. I think the FDA would approve of that term either, but as I said before, it is just a notice if she hasn't been in trouble before.
Tinctures are sold in many herbal shops, natural food stores, herb festivals/fairs, and even some medical practitioners offices across the country. They are used by the drop(s) and users can drink it straight or mix it in a liquid. Some taste pretty terrible, so mixing them into a tea or juice is best. If you are giving to a child or someone who doesn't want the alcohol part, you just put your drops into hot water and allow the alcohol to evaporate. There are tinctures made/used specifically for infants and children with stomach issues, teething issues and colic. I used them with my kids, and my family used them before me. There is nothing wrong with offering these products. They are an alternative medicine, part of naturopathy and holistic medicine. Just like someone can sell herbal supplements, (which I feel are more likely to be over-used and used without consideration of potential ramifications), they can make and sell tinctures.
She should list the INCI names of the herbs/ingredients, but maybe her labeling does.
The main thing I'd double check before I used one of her tinctures is the dosage amount. They may be correct, but I'd have to study her recipes before I'd go with those amounts. I have always calculated by the drop and so have most of the people I know, which doesn't make her amounts wrong, just not what I am used to seeing.
I am sure you are balking at her indications for the tinctures because we are so strongly ingrained to not make medicinal claims for soap. But if you do make a medicinal claim, it doesn't make your product illegal, it just removes it from the soap category and requires you to then follow the labeling requirements for its new category.
Check out some herbal shops and see how they handle the sale of tinctures. Mountain Rose Herbs is one of my favorite stores. They grow many herbs, wildcraft from their local area, teach, are all organic, and are a leader in their community, as well as the herbal market in general. They make their own tinctures too. Take a look there some time and see how they describe theirs. From what I recall of their site and others I have seen, as well as what was written here about this woman's site, this woman is pretty much describing her products in the same manner.
Without knowing her labeling practices or her background information, I personally would not want to buy from her. But I doubt she is as far off as you all seem to be thinking.
To me, the worst thing I see is the lack of preservative. However, even though I believe that one should always use a preservative when selling water based products, there are people who don't, and people that prefer to buy products without them. It is not against the law to sell un-preserved lotions. Again, her labeling must be correct, expiration date, lot number etc. But since we don't know what her labels look like, we don't know of she is compliant or not. She and her customers need some good education in this area, but I have found that most of those with her mind set are not very open to change in this area. At least she is up front about not using the preservatives, so at least people will know who to sue if their scratch becomes colonized with the bacteria or mold growing in her lotion!
I also find her choice of "emulsifier" interesting. But she is not the only one who does that either.
As for the sunscreen, I am not sure what % of ZO you need to get a spf of 20, so maybe she can offer that. Assuming she can, it is again down to how she labels it. You certainly can purchase the ingredients to make your own sunscreen, and the manufacturers do provide you with the % needed to create various spf levels. So it is possible that she is legally in compliance with her labeling and product.
Personally I don't care to deal with the hassles that are involved in selling a sun screen, and most people I know just make it for their families, but I have known a few that that go all out and sell theirs.
All in all, FB isn't going to care what she sells or how she labels what she sells. The FDA may care, but she is a small fish, so until and unless someone sues her, or many, many people complain about her, she will likely just be ignored. Even if they were to take exception to her labeling she would just get a warning and instruction on what to change if this was a first offense.
As long as she is accurate and compliant with her labeling, the herbal community would not take offense at the little that I have seen from your post. Poppy Swap is an all herbal store website and has many shops that sell similar herbal remedies, including tinctures. They all advertise like this woman. They even have shops with soap, making non soap claims, and they don't even bother with the "the FDA has not ....blah blah blah", yet the AHPA backs and loves this site. In fact, they have won some awards. So I doubt the AHPA will do whatever you are thinking they might.
In the end, without more investigation, I don't think we know enough to say that she is legally non-compliant with anything except using the word "cure" in her description. This woman may be a quack who knows nothing, or she may be a world renown herbalist for all we know. Without discussing anything with her, without investigating her practices more, we have no idea what her background and experience is. Frankly, some of the smartest people I have ever known, people who could whip up salves that would cure you of most anything, if I believed in using the word cure, were backwoods, non-school educated people.
Stepping down off my box now. Let the flogging commence! Lol
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Remember, it's not just that we weather the storm, but how we dance in the rain.
Tammy
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