Balms, Big Bucks and the Bandwagon

"Most personal care items (lotions, sanitizer, lip balms, etc.) are considered a drug with the FDA and need to follow a specific set of safety requirements," said Hersh. Since the FDA lacks jurisdiction in overseas plants, the safety of imported lip balms, sanitizers, sunscreens, etc. is an open question, with potentially large product liability risks," explained Ellis.

Hersh gave an example. "Many imported sanitizers from suppliers who just added the product to their line are not containing 62 percent alcohol," he said. (The CDC recommends 62 percent alcohol to effectively kill germs.) "They are importing hand sanitizer and acting like it is the same as a calculator. We tested products from many factories in China and two out of 10 actually had the correct ingredients," Hersh said.

Ellis offered a similar warning. "I heard recently of an industry supplier offering an incredible deal on lip balms made in China. Apparently, the supplier could not tell which flavors were in the lot, so they sold them to distributors at cost in an effort to recoup their inventory investment," he said. "My question is, 'What else is in those lip balms that the supplier doesn't know about?' These products are regulated as drugs by the FDA, and the standards are very exacting in order to protect the consumer," Ellis continued. "With imported products, we know that we do not know what is in them. A distributor selling imported personal care products is taking a very large risk." When it comes to liability in the chain of supply, everyone is liable, including distributors.

While the risk of noncompliance in this product category is real, it should not deter you from selling personal care products overall. "The future is bright in this market," House said. "Personal care items that are useful tools for everyday life, are always appreciated and can be additions to any program, gift pack or fundraising event. We expect this category to become more important in the industry."