Packages of Similar Items

A package of similar items is a package of multiple similar products. They would have the same composition and only vary by color or fragrance/flavor.¹ For example, a package of 3 soaps or a package of 2 lotions would be packages of similar items. This applies to packages that are created prior to sale and are sold as a unit (not to products that are purchased individually and then placed in a single box or package).

A package of similar items.

Conventional Ingredient Declaration

A conventional ingredient declaration would mean that the complete ingredient declaration for each item would be listed on the outside of the package.²

However, there is an optional combined ingredient declaration that can be used.

Combined Ingredient Declaration

The alternate order for the ingredient declaration takes into account all of the products in the package:³

1. Ingredients present in ALL of the products at more than 1%, listed in descending order of predominance, based on the cumulative amount (percent) in all products;
2. Ingredients, other than color additives, present in ALL products at 1% or less, listed in any order;
3. Ingredients present in one or more products but not all products, identified by the product(s) which contain the ingredient;
4. Color additives used in any of the products.

Example

Let’s take an example of three soaps, made with mostly the same ingredients, and produced in three colors. In this case, each soap has a different specialty oil and the colorants used are blends of several different color additives.

1. Ingredients present in ALL of the products at more than 1%, listed in descending order of predominance, based on the cumulative amount (percent) in all product:
   Olive Oil
   Coconut Oil
   Palm Oil
   Water
   Sodium Hydroxide
   Castor Oil
2. Ingredients, other than color additives, present in ALL products at 1% or less, listed in any order:
   Fragrance
   Rosemary Leaf Extract
3. Ingredients present in one or more products but not all products, identified by the product(s) which contain the ingredient:
   Shea Butter, Tin Oxide (in Lavender Soap)
   Mango Butter, Kaolin (in Rose Soap)
   Rice Bran Oil (in Blue Soap)
4. Color additives present in any of the products (specific product does not need to be identified):
   Mica
   Titanium Dioxide
   Manganese Violet
   Ultramarines
   Iron Oxides
   Green Chrome Oxide

The final ingredient declaration placed on the outside of the package would read:

Small Packages

There is an additional provision to condense the ingredient declaration if the package itself has less than 12 square inches of available labeling space. That’s a cube-shaped box about 1 3/8 inches. This labeling option most generally applies to very small products such as eye shadows.

On a package that small, all the ingredients are listed based on the cumulative amount in the products.⁵ You don’t need to identify the specific product that contains a specific ingredient.

Obviously 3 soaps wouldn’t fit is such a small package, but if the ingredient declaration example were to be used on a small package, it would be modified so the specialty oils are listed right with the ingredients present at more than 1% because the placement is based on the amount in all of the soaps combined (rather than the individual soap). The kaolin and tin dioxide are placed with ingredients present at 1% or less. It saves a little bit of room. The final ingredient declaration would read:

Text Size

The text of the ingredient declaration must be clear and conspicuous and able to read by ordinary individuals under normal circumstances. The ingredient declaration must be in text that is at least 1/16 inch high.⁶

On a small package with less than 12 square inches of available label space, the text size can be 1/32 of an inch high.⁷

See Labeling: Measuring the Text Size for details on how to measure the text size to make sure it’s large enough.

Labels on the Individual Products

If the products inside the package are individually labeled, they only need the identity, net weight, and business name and address. The ingredient declaration specific to each product is not required on the inside items.⁸

Compare to Shaded Lines

Packages of similar items are somewhat like shaded lines but are not limited to only certain types of products.

The labeling option for packages of similar items only applies to the ingredient declaration on the package and it cannot be used on the individual items within the package if they are sold separately.

Soap

The example above applies to soap that is packaged as a cosmetic. There are some additional rules and regulations that determine when and if an ingredient declaration is required on soap at all. See Ingredient Declaration for Soap for details.