How to Correctly Label Cosmetics
This article applies to cosmetics sold in the United States.
Cosmetics are regulated by the Food and Drug Administration (FDA). The FDA has issued regulations which cover the labeling requirements for cosmetics, which are located in the Code of Federal Regulations Title 21, Sections 700 - 740.
In brief, the label for a cosmetic must contain:
- Identity of the product (what it is)
- Net Contents (how much is in the package)
- Ingredient declaration (what it's made of)
- Any required warning labels
The product identity is what the product IS. Is it soap? Is it an eye cream? Is it a body scrub? What is it?
The identity of the product can be presented in the common or usual name used to describe it (soap, lotion, etc), or - if the nature of the cosmetic is obvious - it can be a fanciful name, or even an illustration showing the intended use of the cosmetic.
In other words, there must be some way for the consumer to understand what the cosmetic is and what it is for. A lotion bar and a bar of soap look similar; it is the identity statement (or image) that tells the consumer what it is.
The product identity is required on the FRONT of the cosmetic package.
The net contents tell the consumer how MUCH product there is in the container or package.
For solid or semi-solid products, the statement must be in terms of weight; for liquid products, the statement must be in terms of volume. Remember that a jar that holds 8 fluid ounces can hold more or less than 8 ounces by WEIGHT, depending on what is put in it. If you fill it with feathers, it may only hold 1 ounce; if you fill it with oil it may hold 7.5oz, and if you fill it will salt, it may hold 11 oz.
The net contents must be stated in inch/pound measurements AND in metric measurements.1
The net contents should be placed in the bottom 30% of the front panel2, parallel with the bottom of the package.
Except for very small packages3 the text for the net contents must be at least 1/8" high, measuring the height of the lower case "o" for upper/lower case text or the uppercase "L" for all uppercase text. This is much larger than you would probably like from a design point of view!
The net contents must be reasonably accurate and may not be more than the actual contents.
All ingredients in a cosmetic must be declared on the label4 in descending order of predominance. In other words, the ingredient present at the highest percentage is listed first, the next highest percentage second, etc.
As an alternative, all ingredients present at 1% or less may be listed in any order following the ingredients present at more than 1%, and color additives may be listed after the ingredients present a 1% or less regardless of the amount of color additive.
Blended ingredients may not be listed as one ingredient; the component ingredients must be listed individually, based on their percentage in the whole. It may take some math and/or information from the supplier of the blended ingredient to determine the correct placement in the ingredient declaration.
The name used to identify the ingredient should be the name that is used in the Cosmetic Ingredient Dictionary (commonly called the "INCI name" except that botanical names should NOT use the Latin binomial name first. Botanical ingredients should be identified by their common English name; the Latin name may be included in parenthesis, but is not required.
Warning statements are required on some cosmetics:
- Bubble bath (unless clearly labeled for adult use only)
- Tanning products without sunscreen
- Feminine deodorant sprays
- Cosmetic aerosols
- Products containing alpha hydroxy acids
Neither the product name nor the product brand are required on the label. However, if a product name is used, it is important to note that the FDA regulations specifically forbid the use of an ingredient name in the name of the product.
1 The Fair Packaging and Labeling Act, which is the law that covers product labeling, was updated in 1992 to require metric measurements. The FDA never updated their regulations accordingly. However, most states have implemented laws/regulations that require metric measurements on cosmetic packages.
2 Positioning the net contents in the bottom 30% of the label may be waived if the front of the package (the Principal Display Panel) is less than 5 square inches.
3 A very small package is one on which the Principal Display Panel is less than 5 square inches.
4 There is a small exception for "incidental ingredients" that are not present at functional levels (generally less than 1%).