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COSMETICS AND PERSONAL CARE

Thompson Coburn helps cosmetics and personal care product companies navigate what is one of the more highly regulated industries in the United States. The U.S. Food and Drug Administration oversight of cosmetics, beauty products and personal care products means industry members must consistently monitor each step in the manufacturing and distribution process, from raw material acquisition, to manufacturing, labeling and marketing. Furthermore, after recent legislation and agency rulemaking, the FDA has significantly stepped up its enforcement efforts, particularly in regard to import regulations and labeling compliance.

Our attorneys are experienced with federal agency regulatory compliance issues, including the Federal Trade Commission on advertising issues, the FDA’s current Good Manufacturing Practices, dealing with FDA inspections and responding to FDA enforcement actions, such as detentions, warning letters and inspections. Our team is also well-versed on import-export issues and the FDA’s detention program related to cosmetics and personal care products.

For our cosmetics, beauty products and personal care product clients we handle varied matters including:

  • Assisting in establishment registrations under the FDA’s Voluntary Cosmetics Registration Program
  • Reviewing cosmetics manufacturing processes for compliance with current Good Manufacturing Practices
  • Assisting companies respond to FDA enforcement actions
  • Advising companies in regards to manufacturing or supplier agreements
  • Labeling reviews to ensure that labeling and marketing materials comply with FDA/FTC regulatory requirements and limitations
  • Review of advertisements to ensure compliance with “green” marketing guidelines

In addition, we work very closely with our clients on engaging in advertising practices that do not prompt FTC review or investigation. The FTC has principal authority over cosmetic, over-the-counter drug product and personal care product advertising. We work with our clients to help them understand how the FTC evaluates advertisements in determining whether or not such advertisements are deceptive or misleading and evaluating the basis for claims in advertisements.

Publications

Illinois legislature makes substantial limiting changes to state law on non-compete and non-solicitation agreements

EEOC issues new guidance on COVID-19 vaccinations in the workplace

Litigation fees may be tax-deductible, confirms new Tax Court ruling

Participate in standard-setting bodies? The enforceability of your patents could be affected

Criminal antitrust prosecutions still loom for employers with ‘no-poaching,’ ‘wage-fixing’ agreements

Supreme Court overturns the Federal Circuit, granting more flexibility to biosimilar makers

What to do when the government comes calling: A checklist for handling facility inspections

USPTO launches new proof of use audit program

The shifting standard for IPR estoppel: Where are we now?

5 tips for environmental due diligence in business transactions

D.C. appellate court strikes another nail in the coffin for the Frye test

What U.S. companies need to know about their IP rights post-Brexit

New OSHA reporting and anti-retaliation rules

USPTO publishes new (and largely improved) guidance for subject matter eligibility

Federal Circuit rules objective prong of willful infringement best decided by judge

TCLE

Better Together? Competition, Price Gouging and Other Antitrust Issues Raised by the COVID-19 Pandemic

Blog Posts

Clearview AI class-action may further test CCPA’s private right of action

‘Aggrieved Persons’ can bring suit under Biometric Information Privacy Act

DOJ continues to investigate, seek recoveries over compounding pharmacy fraud

Fate of legalized cannabis hinges on key vote

FDA to step up enforcement of homeopathic medicine

Recreational marijuana shake-up: Sessions revokes Cole Memorandum

Clinical trials Part I: The upcoming clinical trials reporting rule

The FDA's new Digital Health Plan

FDA’s Health Software PreCert Program to fast-track innovation

FSVP compliance dates arrive, challenges to food industry increase

News

ACI Drug and Medical Device Litigation Conference

Suzanne Galvin Quoted in Bloomberg Law Regarding Revised PFAS Settlement

World Trademark Review names Tom Polcyn to WTR 1000 list

Thompson Coburn releases 2021 Ag Innovation Survey on the impact of COVID, future of the ag industry

Jennifer Post talks to Business Insider about startup considerations before going public

Thompson Coburn releases first Ag Innovation Survey on the impact of COVID, future of the ag industry

Thompson Coburn supports agricultural growth through the Center for Soybean Innovation

Gain Executive Insights on trade developments with Thompson Coburn, Hispanic Chamber of Commerce

New Jersey jury awards $11 million to Thompson Coburn client in pet invention dispute

Agribusiness professionals enjoy hands-on farm simulation at Thompson Coburn

Thompson Coburn leads Missouri Soybean Merchandising Council to $600,000 jury verdict

Thompson Coburn earns corporate counsel recommendations five years running in national report

UMSL Research & Innovation Week to feature Tom Schlafly presentation

Steve Ritchey publishes article on patent basics for American Ceramic Society

Jeff Masson named ‘Influential Appellate Advocate’ for Monsanto Supreme Court win

Three partners named 2013 Up & Coming attorneys

Monsanto wins unanimous ruling from U.S. Supreme Court

19 Thompson Coburn partners named 2013 St. Louis Lawyers of the Year

Jeff Masson featured in AgProfessional magazine

Senior Counsel
St. Louis

Gordon is a highly experienced trial attorney who has achieved significant courtroom wins for clients in cases involving commercial disputes, white collar criminal defens...

Gordon is a highly experienced trial attorney who has achieved significant ...

Gordon Ankney
Partner
St. Louis

Matt represents major agricultural companies in business-critical disputes.

Matt represents major agricultural companies in business-critical disputes....

Matt Bober
Partner
St. Louis

Companies navigating the complex regulatory landscape of the food and beverage industry turn to Kim Bousquet for her experience handling disputes and providing guidance.

Companies navigating the complex regulatory landscape of the food and bever...

Kim Bousquet
Partner
St. Louis

Matt is vice chair of the Intellectual Property Practice Group.

Matt is vice chair of the Intellectual Property Practice Group.

Matt Braunel
Partner
St. Louis

Dan Cox is a litigator handling sophisticated business, tort, product liability, intellectual property, and class action defense cases.

Dan Cox is a litigator handling sophisticated business, tort, product liabi...

Dan Cox
Senior Counsel
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Chip's practice focuses on the representation of individuals, universities, and national and international companies in commercial transactions and counseling involving t...

Chip's practice focuses on the representation of individuals, universities,...

Chip Fendell
Partner
St. Louis

John represents domestic and international clients in complex litigation and multi-district litigation in some of the most challenging state and federal venues in the cou...

John represents domestic and international clients in complex litigation an...

John Galvin
Partner
St. Louis

Clients turn to Suzanne Galvin for results in complex high-profile litigation, particularly in the areas of pharmaceutical, medical device, and environmental exposure cla...

Clients turn to Suzanne Galvin for results in complex high-profile litigati...

Suzanne Galvin
Partner
St. Louis

Wil has a PhD in cellular and molecular biology and experience as research scientist working for a major biotechnology company.

Wil has a PhD in cellular and molecular biology and experience as research ...

Wil Holtz, Ph.D.
Senior Counsel
Washington, D.C.

Benjamin is a corporate advisor and business strategist for a wide variety of privately-held businesses, manufacturers, financial institutions, and nonprofits.

Benjamin is a corporate advisor and business strategist for a wide variety ...

Benjamin Hulsey
Partner
St. Louis

David strategically advises clients in a variety of intellectual property disputes including patent prosecution, IP litigation, brand protection, counterfeiting, Post-Gra...

David strategically advises clients in a variety of intellectual property d...

David Jinkins
Partner
New York

James serves as legal adviser to investors, entrepreneurs, investment advisers and investment bankers as they fund or invest in new companies, grow established private co...

James serves as legal adviser to investors, entrepreneurs, investment advis...

James Kardon
Partner
St. Louis

Tom is Co-Chair of Thompson Coburn LLP's Corporate Department.

Tom is Co-Chair of Thompson Coburn LLP's Corporate Department.

Tom Litz
Partner
St. Louis

Jeff is a litigator, former crop consultant, and agronomic crop specialist.

Jeff is a litigator, former crop consultant, and agronomic crop specialist....

Jeff Masson
Partner
St. Louis

Chris is a valued strategic partner to emerging companies and the institutions and individuals that invest in them.

Chris is a valued strategic partner to emerging companies and the instituti...

Chris Reid
Partner
St. Louis

Steve advises clients on domestic and international patent applications and provides comprehensive counsel on licensing and technology transfer.

Steve advises clients on domestic and international patent applications and...

Steve Ritchey
Partner
St. Louis

Ben brings a background in electrical and computer engineering to his legal practice, which primarily focuses on the preparation and prosecution of patent applications.

Ben brings a background in electrical and computer engineering to his legal...

Ben Volk, Jr.