Q: Do I need the list all ingredients in a hair growth oil that only contains essential oils?

I want to sell a hair growth formula I created. It is a blend of 5 essential oils. I want 3 of them to be kept private. The reason for this is because this specific formulation and combination of oils is currently not on the market and I would like to keep my unique formula protected. Would I be able to use "other botanical oils" or something similar? There are no additional additives.

1 Lawyer Answer
James L. Arrasmith
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Answered

A: When selling a hair growth oil, you generally need to comply with cosmetic labeling regulations, which typically require listing all ingredients on the product label. This ensures transparency and helps consumers make informed choices, especially if they have allergies or sensitivities.

However, you can explore using broader terms like "botanical oils" for proprietary blends. It is essential to verify that this approach complies with the regulations in your target market, as rules can vary by country.

Consult the guidelines from relevant authorities such as the FDA in the United States or the EU Cosmetics Regulation in Europe. Seeking legal advice can help ensure your product meets all necessary requirements while protecting your unique formula.

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