Classifications, you say! What’s up with that?

Important Note: The information provided here is not necessarily the views of Young Living. This is written by an Independent Representative of Young Living.

Written by: Amy Moore, M.S.

It is no secret that Young Living received a “warning” letter from just one of the many federal regulatory agencies that are charged with ensuring products sold to the public are marketed safely and appropriately.

One of the areas stated as a concern, in that 22 September 2014 letter, was proper classification of Young Living’s essential oils. It is my hope to bring some clarity to a rather confusing topic. I bring this to you complete with direct sources to back up the information, so please stay with me. It is crucial that you do not skim this post. If you want the “whole” picture, please take the time to read this carefully.

Let’s start with the part of the 22 September 2014 letter that discusses this area of concern:

YLFDALtr_ClassificationIssues

So, as you can see, it would not be plausible, under the current regulations that are in place (and have been long before Young Living formed), for a natural product to be classified as both cosmetic/beauty and dietary supplement. The guidelines for each of these classifications are different. The claims that can be made for both of these classifications are different. Why? In simple terms, you cannot ingest a cosmetic/beauty product but you can ingest a dietary supplement.

I can already hear some of the mumbling taking place for those saying that this only concerns labeling. For those saying this, you would be correct . . . but only to a point. Why? Because part of proper labeling includes providing “adequate directions for use.” See the section below taken from the 22 September 2014 warning letter issued to Young Living.

YLFDALtr_DirectionsForUse

Therefore, as Independent Representatives of Young Living, it is our job to properly instruct anyone interested in or already using Young Living products.

Notice that in the new 2015 Product Guide v.3 located on Young Living’s ISSUU account website, the oils have been classified and deemed as either “topical/aromatic” (cosmetic/beauty) or “dietary” (dietary supplement).

OilClassificationGuide

It is important to note that Young Living is in the process of updating and revising more of the oils as this is being typed. So, how will you know if the oil is classified properly? I have been told via e-mail from the Young Living Conduct and Education Department to use the claims (structure-function statements) made in the recently updated 2015 Product Guide, along with those claims (structure-function statements) that have been trickling in via Young Living’s member newsletter called GROW! Not getting GROW! via e-mail? Click/Touch HERE to learn how to check your settings to ensure you are set up to receive notifications from Young Living. You can also find the most recent edition of GROW! in your new Virtual Office under Member News. Okay, back to classifications.

MemberNews

So, how will you know if an oil is classified properly? Look at the claim made for that specific product in the recently updated 2015 Product Guide v.3 located on Young Living’s ISSUU account website. Look for “key words,” such as “diffuse” or  “apply topically.” If you see those claims, you can safely assume the product’s intended use (or classification) is cosmetic (topical/aromatic). However, if you see “key words” such as “when taken as a supplement” or “dietary,” you can safely assume the product’s intended use (or classification) is as a dietary supplement.

Here is an example of Young Living’s Lavender essential oil; the screen shot was taken from the recently updated 2015 Product Guide v.3 located on Young Living’s ISSUU account website.

2015v3PG_Lavender

Notice that Lavender is now classified as “topical/aromatic.” This means that if you, an Independent Member of Young Living, give someone a recipe for, let’s say, “Lavender Tea,” you would not be properly instructing this person on the intended use for this product, as deemed by Young Living, because you would be instructing the person to ingest Lavender, not apply topically, diffuse, or directly inhale.

On that same note, let’s take a look at their Peppermint essential oil; this screenshot is also taken from the recently updated 2015 Product Guide v.3 located on Young Living’s ISSUU account website.

2015v3PG_Peppermint

Notice the symbol on this screenshot, in the upper right corner under “Best Seller!”? That is a symbol indicating this essential oil is classified as “dietary,” and the “HOW TO USE” section (in the above screenshot) states to take it as a dietary supplement. Therefore, all the “DIY” recipes out there for cosmetic/beauty products that include an ingredient such as Peppermint are not instructing people on the proper use of those Young Living products.

This is exactly why Young Living is releasing claims (structure-function statements) that are specific to each particular Young Living essential oil and/or product. The claims must match the classification of that particular product. There is no “one-size-fits-all” list of compliant claims.

So, wait, how do we know Young Living is saying to “advertise these products as classified?” . . . Good question! This question was sent to the Young Living Conduct and Education Department to confirm, and here is their response:

ProductMustBeAdvertisedAsClassified

It is important to touch on one more example. Here is a screenshot of Young Living’s Thieves essential oil blend taken from the 2015 Product Guide v.3 located on Young Living’s ISSUU account website.

2015v3PG_Thieves

Notice that Young Living’s Thieves essential oil blend is classified as “dietary” (dietary supplement). Therefore, you would not provide someone with the appropriate instructions for use if you instruct someone to diffuse Thieves.

How can you help support Young Living and reduce risk? Look through your social media outlets (Facebook, Pinterest, etc.) and remove any graphics/statements that conflict with the oil’s new classification, as can be found only in Young Living’s 2015 Product Guide v.3 on their ISSUU account website and/or those claims released in Young Living’s e-mail newsletter GROW!.

After receiving quite a few e-mail messages about lavender, as an herb, and how chefs use this as an ingredient, I felt it important to add a little further clarity to this topic. Therefore, when it comes to federal regulations/company policies and procedures/and any other type of regulations governing “marketing/labeling” — it is important to separate you, as an individual, from you, as someone who is marketing/selling/representing a specific company. Young Living, as its own individual company that is bottling and labeling a product for the public, must decide, due to federal regulations, how each of its products are to be classified and used by the public. Because of the way in which the regulations are structured, a product cannot be classified as both cosmetic and dietary supplement. Therefore, Young Living has to select which one it will market its own specific product under, so that the claims made and directions for use for that specific product match its classification. As Young Living Representatives, we have to market that product only under its classification and directions for use. This is why it is so important to separate yourself from you as an individual to you as someone who markets for a specific company.

I hope this brings some clarity to a rather delicate and complex area of compliance.

If you have any questions/comments/concerns, please send those directly to Young Living so that you can obtain answers that come directly from the source.

4 thoughts on “Classifications, you say! What’s up with that?

  1. Neelima

    Simply put, you rock. This is the kind of stuff I’ve been explaining to some of my team, who think me rather nit-picky. But yes, the name of the game is Extreme Compliance and we can win at this!!!

    Reply

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