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: Aimee Watson (formerly Amy White 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:
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.
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 2018 Product Guide v.2 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) aka Young Living’s Vitality line of oils.
So, how do you know the classification of Young Living’s essential oils? Around 2016 Young Living came out with their Vitality line of essential oils. These essential oils contain the EXACT SAME essential oil as that found in its plain/regular labeled twin (for example Peppermint regular label vs. Peppermint Vitality) but the usage directions and the look of the label is different on both bottles. The Vitality line of essential oils is specifically designed to be used and instructed as a dietary supplement. The regular label can be used and instructed as a topical/aromatic essential oil. As representatives of Young Living you can only instruct, teach, advise, suggest usage as the label directs. Once the person purchases the oil then that person can use the oil however he/she desires but you, as a representative with a potential to profit from what you advise (commercial speech) can ONLY advise according to the label’s directions.
Here is an example of Young Living’s Peppermint Vitality (left) and Young Living’s Peppermint regular label essential oil; the screen shot was taken from the recently updated 2018 Product Guide v.2 located on Young Living’s ISSUU account website.
Young Living has released 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 and/or words. Why? Because compliance is based on the overall intent of the message, not on a single word or photo, but the overall intent of the message.
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:
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 2018 Product Guide v.2 on their ISSUU account website and/or those claims released in Young Living’s e-mail newsletter GROW!.
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.