Trade Dress Exemption Could Be Short-Term Fix To OTC Label Issues - CTFA

A general exemption for OTC products that meet a "clear and conspicuous" performance standard may be an "intermediate fix" for those that do not meet the color requirements in the OTC labeling rule, Cosmetic, Toiletry & Fragrance Association VP-Legal & General Counsel Thomas Donegan suggested. He spoke at an FDA working group meeting to discuss trade dress on product labeling in Rockville, Md. Aug. 24.

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