Google Answers Logo
View Question
Q: importing herbal creme ( Answered,   0 Comments )
Subject: importing herbal creme
Category: Miscellaneous
Asked by: permagon-ga
List Price: $200.00
Posted: 10 Jun 2006 15:34 PDT
Expires: 10 Jul 2006 15:34 PDT
Question ID: 737066
I want to import herbal hair removing creme from Pakistan and sell it in USA?
What is the procedure and laws about it? Do I need to disclose
and/or prove the ingredients at the time of imports? If so, is there
any organization to help?
At this moment I donot know details of all the ingredients. But
ultimately I want to buy formula and get patent if possible. If  the
product claims that it can remove hair and/or slower the growth and
stop the regrowth of hair what do I need to do to get FDA permission
to make such claim? What is going to be their requirement?  Also
approximate cost and time involved for this process?

Request for Question Clarification by easterangel-ga on 12 Jun 2006 06:39 PDT

I was able to find the procedure required by the FDA but it doesn't
say how long and how much is the cost for the whole process.

Is this ok with you?

Subject: Re: importing herbal creme
Answered By: tox-ga on 21 Jun 2006 22:25 PDT
Hi there permagon-ga,

I have some good news for you - the importing process may be simpler
than you expected.

First of all, hair removal cream typically is classified as a cosmetic
(there's different FDA regulation for cosmetic, drug, soap, etc)

The Food, Drug, and Cosmetic Act (FD&C Act) defines cosmetics by their
intended use, as "articles intended to be rubbed, poured, sprinkled,
or sprayed on, introduced into, or otherwise applied to the human
body...for cleansing, beautifying, promoting attractiveness, or
altering the appearance" [FD&C Act, sec. 201(i)].

Although the agency can take action to get unsafe products off the
market, cosmetic don't go through FDA approval before they are
(as mentioned on the last paragraph of this article:

To summarize:
"Cosmetic firms are encouraged to register their establishments and
file Cosmetic Product Ingredienet Statements with FDA's Voluntary
Cosmetic Registration Program (VCRP). However, firms importing
products considered to be solely cosmetics in the United States are
not required to register with FDA, and a registration number is not
required for importing cosmetics into the United States."
"FDA does not have a premarket approval system for cosmetic products
or ingredients, with the important exception of color additives. "

However, cosmetic products imported into the USA are subject to the
same laws and regulations as those produced in the USA.  This means
"they must be safe for their intended uses and contain no prohibited
ingredients, and all labeling and packaging must be informative and
truthful, with the labeling information in English (or Spanish in
Puerto Rico)."  So, although the FDA does not review or approve
cosmetics, or their ingredients, you are legally obligated to ensure
the safety of the product and put a warning statement of products for
one that has not had extensive safety testing.

You do need the items to be labeled with the ingredients at the time
of import, otherwise the product will be subject to import refusal.
Detailed information on how to properly label the product can be found here:

As far as making claims about the quality and functionality of the
product, that falls under the regulation of the Federal Trade
Commission.  This means, you don't need specific "permission/approval"
for your claim but you must ensure that your claim is not false or
"The same general standards apply to advertising regardless of the
media used. The FTC requires that all objective product claims --
whether express or implied -- be adequately substantiated by the
advertiser prior to their dissemination to the public. Failure to
adequately substantiate a claim prior to its dissemination is an
unfair or deceptive act or practice. See Pfizer, Inc., 81 F.T.C. 23
(1974) and FTC Policy Statement Regarding Advertising Substantiation
The doctrine emerged in the mid-1970s. After Pfizer, the FTC commenced
a campaign to put all major advertisers under advertising
substantiation orders. "

For details on what a claim is, and whether it's false, please visit
the following site and scroll about a fifth of the way down until you
see "False and Misleading Advertising"

So, in terms of FDA approval and permission for product claim, the
cost and time involved is nothing as they are not required.  However,
you do need to know the ingredients, ensure they are safe, and label
the product properly in English.  Of course, this depends on the
nature of the company and your relationship with them.

I also recommend that you look at the FDA page for Cosmetics:

The FDA specifically recommends that importers take a look at the
Information for Industry page:

I hope this has helped and please feel free to ask for any clarification.

There are no comments at this time.

Important Disclaimer: Answers and comments provided on Google Answers are general information, and are not intended to substitute for informed professional medical, psychiatric, psychological, tax, legal, investment, accounting, or other professional advice. Google does not endorse, and expressly disclaims liability for any product, manufacturer, distributor, service or service provider mentioned or any opinion expressed in answers or comments. Please read carefully the Google Answers Terms of Service.

If you feel that you have found inappropriate content, please let us know by emailing us at with the question ID listed above. Thank you.
Search Google Answers for
Google Answers  

Google Home - Answers FAQ - Terms of Service - Privacy Policy