In preparation for Membership in the American Essential Oil Trade Association, it’s important to review your product labels, marketing and advertising.
The first website we recommend reviewing is the FDA page on Aromatherapy.
This page was just updated in August, to make the requirements more clear, “If a product is intended for a therapeutic use, such as treating or preventing disease, or to affect the structure or function of the body, it’s a drug.”
Next, review the FDA Warning Letters
One of the violations the FDA has demonstrated they are looking for, in addition to outright medical claims, are implied claims. So testimonials or links to scientific articles, which may lead a customer to believe the essential oil or aromatherapy product you are selling will treat a particular medical condition, may be looked upon as a medical claim. The rules are not exactly clearcut, so it is important to see what the FDA has found fault with in the recent past.
So, it is a good idea to review the recent Warning Letters sent to doTerra and Young Living. The examples in these letters are a good clue to the types of promotion which cause essential oils and aromatherapy products to be misbranded drugs.
DoTerra Warning Letter: http://www.fda.gov/iceci/enforcementactions/warningletters/2014/ucm415809.htm
Young Living Warning Letter: http://www.fda.gov/iceci/enforcementactions/warningletters/2014/ucm416023.htm
There are other warning letters in the FDA Warning Letter archives as well, search “essential oil warning letters” to review some which may not have hit the front page of the news.
Something to keep in mind…
“The fact that a fragrance material or other ingredient comes from a plant doesn’t keep it from being regulated as a drug.”