Lube’s Battle: The FDA’s Crackdown on Lubricant Labeling

Mark Espinosa

Before I happened upon the emotionally satisfying profession of selling topnotch adult “pleasure products,” I actually had aspirations of creating a series of fairy tale books. The easiest part for me was imaging the wild characters and the outrageous situations they would get themselves in to. My stories would be about things like a rambunctious caterpillar that lived inside of an apple core. Or a story about a roller skate that wanted to be a short-order cook. The anthropomorphic possibilities were endless! I soon discovered that putting a grasshopper in overalls was the easy part, the hard part was crafting a story that also taught an extremely valuable lesson. When the tortoise decided to race that rascally rabbit, we learned the lesson that sometimes going too fast could slow you down. That doing a task too fast doesn’t necessarily mean that it’s being done right. Those crafty little pigs taught us the importance of hard work and building a solid foundation. Peter Pan taught us that we should never grow up. That we should avoid responsibility, at all cost, and never really aspire for anything.

Wait, that can’t be right? What the heck was the lesson being taught in “Peter Pan?” Despite that one exception, we are generally told that fighting for something we believe in will yield nothing but positive results and deliver on to us our well deserved “happily ever after.” As beautifully crafted as these stories are, life does not always mirror art. As demonstrated with the current state of affairs with our favorite lube brands. After years of hard work and dragon slaying, the slick tale of the lube industry is currently at a crossroads. With the FDA enforcing strict regulations on most lubricant companies and distribution in a state of flux, we are all left wondering, will this ending have a “happy ending?”

As the number of companies being suppressed by the FDA grows, retailers are in a panic to stock up on their most popular brands or find suitable substitutes for their best sellers.

If you’ve been watching the events unfold online, you’ve seen that the FDA has started to put pressure on the lubricant industry. Because of the advertised intended usage for most lubes, the FDA has been known to classify some brands as “class 2” medical devices, which would require official clearance before allowing further distribution. The process of receiving this “501(k) clearance” has proven in the past to be extremely costly, drawn out, and morally compromising. (Animal testing is required.) Failure to adhere to these mandated requirements can result in your products being seized by the FDA. Normally, such an attempt to regulate ingredients for products intended for use during sexual activity would be seen as a positive step forward for a government agency that has previously demonstrated a willful ignorance towards sexual activities. Instead, this crusade against lube has resulted in the dismantling of an industry that has worked hard to reach an unprecedented level of public acceptance. With each passing day, these same companies are striving to perfect their ingredients so that they may better serve a wider spectrum of body chemistries. And when those already established brands fail to cater to a specifically unique demographic, new companies open up and fill those gaps. Not only is the FDA crackdown hurting a majority of lubricant companies, it’s hurting the customers who have grown dependent on their particular brand. Sometimes, the dragon does win.

As the FDA’s grip grows tighter around the neck of the entire lubricant industry, retailers are left wondering what this “lube drought” will mean for them? As the number of companies being suppressed by the FDA grows, retailers are in a panic to stock up on their most popular brands or find suitable substitutes for their best sellers. This is proving to be easier said than done. As anyone who has ever worked the retail floor can tell you, customers are extremely loyal to their brand. Rightly so — for some individuals, the process of identifying the lube that works best for them is the result of traveling down a road paved in discomfort and sogginess. Everyone’s bodies are different and the lube that works best for you might not be the lube that works for the next person. It’s taken our industry a very long time to establish this dialogue between our educated staff members and the general public. The result of which has been the creation of some of the most organic and body-friendly lubricants ever created.

As the well continues to dry out, I can’t help but wonder if some lube manufacturers are going to attempt to downplay their products' intended use by omitting certain key words on their packaging. Or, perhaps go as far as to say things like “this products is not intended for internal use.” Such phrases could result in the FDA categorizing their products as “moisturizers,” which doesn’t come with the harsh restrictions as “Class 2” identification. While this would make things easier for manufacturers, the obvious downside would be the confusion such declarative statements would stir within the already weary consumer. It’s difficult to assume how this war on lube will turn out, regardless, it’s essential that retailers be as straight-forward as possible with their customers. The adult industry has always been forced to exist in the grey area between government regulations. Yet, we’ve flourished and have made outstanding strides forward in human sexuality, pleasure and awareness. What is the lesson of all of this? It’s definitely open to your individual interpretation. I do believe that the moral of this story is that as long as our customers know that we will continue to have their best intentions in mind and will always carry products that are proven safe, we can all live happily (and well lubricated) ever after!

As national sales manager of Pleasure Works Wholesale, Mark Espinosa believes that as the industry progresses alongside communications technology, it’s important that we always remember that we get to say that we “give people orgasms for a living!” So, why not have a little fun in the process?

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