Cosmetic Product Recall Procedure

cosmetic product recall

Do you know how to responsibly execute a cosmetic product recall? There’s been some buzz recently in the clean beauty space after a well-respected, independent brand discovered that one of its most popular formulas isn’t stable. The development hit the airwaves last week, though the product has been beloved by editors and clean beauty fans from coast to coast for several years. The artisan took to their Instagram account and email list to announce that they’re temporarily halting sales while they investigate and reformulate though they stopped short of declaring a recall. I appreciate that this is a teachable moment for our industry, providing an opportunity  to shed some light on the best cosmetic product recall procedure.


How to Responsibly Execute a Cosmetic Product Recall


cosmetic product recall


A graduate of my cosmetic GMP class put the situation on my radar the day after our graduation, and I found the timing ironic. By way of background: I have both a depth of knowledge and an intense passion for the safety of natural cosmetics and ensuring a bright future for those who are pioneering this space. I spent fifteen years bootstrapping my beauty brand, implementing quality control systems, and building GMP-compliant production protocols. And I walked both the halls of Congress and the corridors of the FDA  for several years, working as a small business advocate to encourage government stakeholders to keep small, independent beauty brands in mind as they craft new federal legislation. As a consultant to makers and product designers, I now teach GMP principles to other beauty brand owners.


Product recalls are an unfortunate reality of modern consumerism, and product recall examples are abundant. But there’s a particular cosmetic product recall procedure that needs to be followed.



There’s a whirlwind of confusion about the requirements for creation and distribution of personal care products within the United States. I engaged in direct dialogue with this beauty entrepreneur during her announcement and our conversation only deepened my concerns.

  • She elected not to use the word “recall” in any of the announcements that I could locate. That’s a critical keyword for this process and clarity is key.
  • The message to customers included romanticized verbiage like “bloom” and “mild fermentation” rather than clear terms which accurately describe what’s happening with those products: mold and contamination. She later conceded privately that she made “some language mistakes.” While my recommendation for an updated statement with clear language apparently fell on deaf ears, I remain hopeful that she’ll make an additional public statement with clear instructions for her customers.
  • When the brand owner addressed my concerns in the comments section of her Instagram post, she mentioned that she’d sold tens of thousands of units of this particular product over the years and affirmed that it “has always challenge tested stable.” She later reached out to me privately and said that the company was “undergoing challenge testing for all of [their] formulas as required by the EU regulatory system.” Those statements are contradictory and lead me to wonder if she understands the nature of these tests and when/why they’re required.
  • When customers inquired on Instagram about whether the product in their possession was safe to use, the company expressed that continued use was “at their discretion.” Both those who hadn’t noticed mold and those who spoke of scraping the mold off the tops of their face mask received that same information. *shudder*  This approach jeopardizes the health of customers while exposing the company to legal liability that’s simply not worth the cost of saving face.




Cosmetic Product Recall Procedure


Over the past few years, a host of bad actors have invited unwelcome attention and a sense of hysteria about cosmetic safety. I’m looking at you Claire’s, WEN by Chaz Dean, and Brazilian Blowout.



Meet the Maker: Leah Klasovsky of Leahlani Skincare

Leahlani Skincare

I’m excited to share another installment of our ongoing “Meet the Maker” series.  Here, we share morsels of business wisdom and a peek behind some of our favorite brands. This one is particularly special Leah Klasovsky of Leahlani Skincare.


Meet Leah Klasovsky of Leahlani Skincare




LBC: What inspired you to take the leap as an entrepreneur?

Leah: Realizing that my body was out of balance, I set out on a quest for healing. Fate led me to Spa Luna, a holistic esthetician school on the Island of Maui. With no prior knowledge of skincare and never having had a facial in my life, I felt a strong pull to trust my intuition… so off we went.

My husband and I packed all of our belongings and moved from Oahu to Maui to embark on this new journey. In life, we have so many defining moments… moments that change our very existence. My experience in the year I spent on Maui did just that, it changed my life.

For the next few years, I immersed myself in the world of holistic skincare and soaked in as much knowledge and advanced education as I could. I became a Spa Director at the Hilton Spa on Kauai and also had the privilege of having my own private esthetician practice. Working one on one with my clients during this time proved to be my most valuable education. I have had the honor of touching hundreds of precious faces over the course of years in my practice, each face told a story of skin longing to be heard and longing to be healed. I quickly learned how valuable my hands truly are, and what powerful healing tools they make.


Meet the Makers – Allison and Adam Grossman of The Seaweed Bath Co.

Allison and Adam Grossman of The Seaweed Bath Co.

Allison and Adam Grossman of The Seaweed Bath Co.


This week in our ongoing Meet the Maker series, we’re going behind the scenes with an especially inspiring, mission-driven couple: Allison and Adam Grossman, founders of The Seaweed Bath Co. in Austin, Texas. Welcome, Allison and Adam!


LBC: What inspired you to take your leap as entrepreneurs?

Allison & Adam: Adam suffers from severe psoriasis. We had reached the end of the road with prescribed medications, so we started looking into alternatives. That’s when we discovered the powers of bladderwrack seaweed. We were blown away by the results Adam saw on his skin, we decided to create a line of personal care products to help others. We soon realized that using bladderwrack seaweed benefits all skin and hair types, and have built the line out to appeal to everyone.


LBC: When you first got started, how did you envision your business would be defined?

Allison & Adam: We envisioned the business being defined by the quality of the products and the authenticity of our reason for being. Our team is now made up of inspiring people that, in their own lives, can relate to our story of turning a negative into a positive. That is how we know our vision is coming to life.


LBC: How would you describe what you create?

Allison & Adam: Nutrient-rich, seaweed-based bath, body and hair care products that naturally nourish and soothe all skin and hair types.


LBC: Where can we find your products?

Allison & Adam: Natural products stores across the country, including Whole Foods Market, Sprouts and Natural Grocers. Online on our website (, Amazon, and several other online retailers.


Allison and Adam Grossman of The Seaweed Bath Co.


LBC: Walk us through your typical work day.

Allison & Adam: As a husband and wife team with two small kids, it was imperative that we set boundaries and roles. Adam is the CEO and face of the business. He is responsible for all facets of the business. Allison manages our social media marketing efforts as well as our graphic design.

So, our day usually starts early with goals for the day over coffee in the morning. Adam heads to the office while Allison takes the kids to school. Focusing on Adam’s day from there, a check-in with the team in the morning followed by analysis of sales, inventory and other items. Then the fires start and we try to put them out as soon as possible. As a small business it is hard to move from reaction to pro-active planning.

Our team has doubled in size over the past 120 days (4 to 8 people), so Adam’s days of being in the stores constantly are now replaced with days supporting the team in their roles.


LBC: What are 3 things makers should think through when they initially decide to start a business?

Allison & Adam: 1. Are strangers willing to provide you with capital? Friends and family will be caught up in your excitement. A stranger won’t and it is a good barometer for how well you have thought through the business.

2. What is your personal financial situation? It will take longer to reach your goals than you think. Adding personal financial stress on top of that makes it even more difficult and likely may make you quit earlier than you should.

3. What is your distribution and revenue strategy? Sounds simple, but a lot of businesses don’t fully think through how / where they will make money.


LBC: When you’re overwhelmed, what brings you back to focus?

Allison & Adam: How lucky we are to be doing something we are so passionate about. Also, thinking about everything we have overcome in six years. That gives us strength, knowing that we just need to get back to doing things one step at a time.


Allison and Adam Grossman of The Seaweed Bath Co.


LBC: Tell us about a few of the best business decisions you’ve made to date.

Allison & Adam: There are two decisions we made in 2014 that changed the trajectory of the business. First, we entered into a CPG incubator here in Austin, TX called SKU (formerly Incubation Station). Through that program, we took a fresh look at our business and ended up meeting a group of investors that backed our business in a big way.

The second was our re-design. The products immediately started flying off the shelves when our new vintage beach look launched.


LBC: Please share one mistake or obstacle from your business experience. How did you bounce back/overcome it? 

Allison & Adam: Your own pre-conceived perceptions and beliefs can sometimes be a detriment to your business. We hired somebody who we both liked personally, but we overlooked the person’s professional shortcomings because of the personal connection we felt. It did not work out and we had to part ways.

On the opposite side, we initially resisted a qualified candidate due to a personality we weren’t sure we would want representing us. We ended up bringing on this person, and they have propelled the business forward and we learned that we actually had a lot in common. It was a learning lesson in that you gain respect for people who are great and passionate about what they do.


LBC: Is there a cause or organization that you contribute to that you’re particularly passionate about?

Allison & Adam: We work with the Surfrider Foundation in certain areas of the country. Our team members started this on their own, and it just made sense since we are so passionate about the ocean and its amazing benefits. Keeping our beaches and our oceans clean is crucial. The Surfrider Foundation is working to stem the negative tide of trashed coastlines.


LBC: What are 3 essential resources in your business toolbox that you can’t do without?

Adam: 1. My wife (she is the brains and the level-headed one).

2. A docket – every morning, I break my day into a list bifurcated by Urgent, Important and To Do.

3). TI-83 Calculator – Yes, the one from Algebra in high school. I still have it!


Allison: 1. My husband: he is extremely creative and passionate and always inspires me.

2. Other CPG entrepreneurs: regularly hearing their advice and about their own experiences is invaluable.

3. Google: It sounds so basic, but whenever I need to learn about a new graphic design tool or technique, I can Google it and find the right information I need almost instantly.


Allison and Adam Grossman of The Seaweed Bath Co.


LBC: Suppose we had a time machine. If you blasted ourselves forward a few years, where would we see your company?

Allison & Adam: The Seaweed Bath Co. would be at a place where we are positively impacting thousands of lives on a daily basis. Our team continues to grow personally and professionally through our business. And that we are available wherever high-quality, natural personal care products are sold.


LBC: What’s one thing you would eat, if you could only eat one thing for the rest of your life?

Allison & Adam: Ice cream.


LBC: Your musical playlist is full of…

Allison & Adam: Our girls’ favorite songs for our jam sessions to and from school.


LBC: Share one of your guiltiest pleasures.

Allison & Adam: These cookie dough bites from Better Bites Bakery (a local allergen-friendly baker here in Austin).


LBC: If you could hire someone to do just one thing that you sort of loath doing, what would it be?

Allison & Adam: Laundry. With two young kids, it never ends.


LBC: What’s your favorite quote and who said it?

Allison & Adam: “Happiness does not come from doing easy work but from the afterglow of satisfaction that comes after the achievement of a difficult task that demanded our best.”  –Theodore Isaac Rubin


LBC: If you were given a million dollars, but were not allowed to keep a single penny for yourself, friends or family, how would you spend it or give it away?

Allison & Adam: We would donate it to National Eczema Association with an ask that they focus on continuing to find a cure for infant eczema. Our youngest daughter, Leah (2), was born with eczema from head to toe. We used our products to help get her symptoms under control, but it was (is) very difficult for us. When your child doesn’t sleep because she is itchy and scratches herself constantly, it can feel helpless. Adam has spoken to hundreds of parents who used our products for their kids’ issues, but it is different when it is your kid. We truly understood their plight and feel fortunate that we are part of the solution. But, we envision a world in 10-20 years where parents will have better, safer options to treat, and hopefully one day, cure it.


Thank you, Allison and Adam, for sharing your talent with us!  We absolutely love what you’re doing with The Seaweed Bath Co., and we look forward to all the wonderful things ahead for you. We’re cheering you on!


Want to see your brand featured in our continuing “Meet the Maker” series? Drop us a line: hello AT Please use “MEET THE MAKER” as the subject line and be certain to include your web address. We look forward to hearing from you!


Lucky Break Isn’t Simply For Beauty Brands!


Since Lucky Break launched in late 2012, I’ve had the great privilege of working with a few hundred creative brands from all around the word, from San Francisco to Brooklyn and Sydney to Hong Kong. I launched my first company, a globally-inspired spa brand, in 2003 so I earned my stripes in the bath + body industry. I’ve slept, breathed and dreamed cosmetics for more than a decade; but, if there’s one thing I’ve learned in business, it’s that product-based brands have more in common than not, regardless of the specific category you’re operating in.


I sometimes hear from makers and creative entrepreneurs that they didn’t realize that I work with brands across the creative spectrum, but ’tis true! I’ve rolled up my sleeves and dug in deep on brand building with paper brands, jewelry designers, gourmet food makers and apparel designers down under. I’ve learned something from each + every one and that breadth of experience helps me serve all of the brands that I work with more effectively.


Check out a few dozen of my favorite brands, each of which I’ve been honored to guide through the mazes of wholesale strategy, product pricing, and brand building. These savvy makers have built gorgeous brands with soul and I’m tremendously proud of their hard work.



Blue Flour Bakery

Hudson Henry Granola

Waxing Kara



Etta + Billie

Rachel’s Plan Bee

Handcrafted HoneyBee

Cloud Nine Soap

Zandra Beauty







Happee Monkee

Print Therapy

Everything Little Miss

Sparklefly Candle Co.

Munch Mitt



The Smallest Tribe

The Glitsea Gypsy

Cultural Detour

Kendra Renee Jewelry

Bead For Life

Dear Edna




Unique PL8Z


Lucky Break is the embodiment of everything I wish I had known when I founded my first company. It’s an opportunity to avoid the pitfalls, frustrations and resource drains that too often ambush the journey. It’s a chance to get things right the first time or reinvent what’s not working and build a brand with strong architecture at its core and a gorgeous vision to share with the world. I created these products and services because I’m intimately familiar with the kind of work you do, and I know how to make that work more efficient, less painful and heaps more rewarding.


How can I help you?


Catching up with LBU Alumni: Tamara Lewis of Zandra Beauty

Get Lucky Live - Zandra Beauty - Lucky Break

Another week brings another opportunity to catch up with an LBU alum and I’m particularly excited to show off the hard work that’s been happening behind-the-scenes at the handmade bath and beauty line Zandra Beauty!


Tamara Lewis is guiding her daughter Zandra as she learns the entrepreneurial ropes. This spitfire of a young lady started her bath + body company in 2009, at the ripe “old” age of nine. Yes, nine. As in 1,2,3,4,5,6,7,8,9. Before she exited elementary school.


Tamara + Zandra are graduates of the LBU Summer 2014 semester and I’ve been privileged to enjoy a front-row seat to the explosive growth + rebrand of their teen-centric product collection. When this mother-daughter duo entered my “how to wholesale” program, they decided that a rebrand + relaunch was in order. Let’s take a peek at the prior incarnation, known as “Azariah’s Innocence.”



The original logo for Azariah’s Innocence



An original product from the collection


Several items needed updating:

a) The custom illustrated logo was adorable, but it’s square shape made it difficult to efficiently incorporate into product packaging.

b) The company name was challenging to spell, potentially frustrating interested consumers who were searching for the product online. It was also a bit ambiguous- buyers were perplexed by its nature and nothing indicated that it was a beauty line.

c) Tamara + Zandra wanted a more modern brand aesthetic which spoke specifically to teens. They hoped that by narrowing + refining their focus, they’d gain more traction in the marketplace.

d) The collection had far too many products, limiting the ability to scale and spreading startup resources too thin.


Tamara + Zandra have worked diligently throughout 2014, participating in a complete rebrand (headed by Elea of the Lucky Break creative team) and graduating not only from LBU, but from my GMP program as well. This weekend, my team was honored to host them at Get Lucky Live Atlanta, my inaugural live event, where we rolled out the red carpet to bring their rebrand full-circle! Are you ready to see the new Zandra Beauty? Drumroll, please!


NewProduct1 NewProduct3Wowzers, right?


Less than six months from the spark of an idea to full implementation! The new branding is sleeker, more modern and the color palette + typography speaks directly to their target audience. Each product is infused with a positive affirmation, giving the Zandra Beauty brand a unique marketing position that really resonates with teens + their mothers.


Though branding curriculum is technically outside the realm of a traditional wholesale class, I’ve come to realize that no matter how seasoned the wholesale strategy I teach, good branding is at the cornerstone of success. The Module 2 branding curriculum is some of the most robust of the entire “Secrets to Wholesale Success” program and it’s been rated as the most helpful module by students for the last two semesters! This particularly comprehensive module is released early on in the LBU semester to carefully dissect successful brands, illustrating how those lessons can be applied to our creative businesses in order to hone in on our ideal customers, develop branding style guides  + compelling brand stories and create memorable customer experiences that build brand loyalty. As soon as Tamara completed Module 2, she knew that a rebrand was necessary to take the company to the next level. The new Zandra Beauty brand was brought to life this weekend at Get Lucky Live! through new product photography, drop-dead-awesome editorial shots, new headshots for both Tamara + Zandra and hot-off-the-presses line sheets + order forms.













We shielded all of the photography + graphic design work from our Atlanta participants, until the final hour of this 3-day workshop. Our “Big Reveal” party projected the final results onto a big screen while we sipped champagne and Jay-Z thumped in the background. Here was the reaction as Tamara + Zandra said the new brand for the first time…




The energy in that room was electric and tears were shed. And then I got to do it over + over again, revealing professional brand elements for each of our GLL attendees. It made every moment of blood, sweat + tears that we poured into the Get Lucky Live! experience incredibly worthwhile.


“At Get Lucky Live, I’ve learned so much about what I have to do to make my business the best it can be.”– Zandra


“This has been the best business weekend ever. Thank you to the Lucky Break team for providing the opportunity for us to give our business the attention needed to make it a success. This event has been life-changing.” -Tamara


Get Lucky Live! will roll through Chicago, LA and New York in 2015 and we’d love to save a seat for you. Read more about Get Lucky Live! events and then hop on the Get Lucky Live! mailing list to be the first to know when our red carpet branding experiences touches down in a city near you.


The rebranded Zandra Beauty website is still in the works and the company is moving into new, larger headquarters in Buffalo, NY. In the meantime, you’re invited to connect with Tamara + Zandra on social media. Let them know what you think of all their hard work + keep your eyes on this brand. They’re set to make some serious waves in the beauty category!


Zandra Beauty on Facebook
Zandra Beauty on Twitter
Zandra Beauty on Instagram