While there’s no question that cosmetics companies must follow federal guidelines, those rules and regulations are not always simple. The labeling requirements alone can be a dense tangle of hard-to-follow legalese, which can pose a real challenge: How can you create the perfect label for your cosmetics without running afoul of federal guidelines?
To help make things easy, we’ve created this straightforward, everyday-language guide to the FDA’s regulations on cosmetic labeling.
What follows is a high-level review of those guidelines, intended to make those rules a little easier to digest as you think about your product labels.
Let’s take a quick look at why these requirements exist, then dive into our exploration of what they actually mean.
Why Brands Must Follow Cosmetic Labeling Requirements
The obvious answer here (“because it’s the law”) might be true, but not exactly helpful as context. The real purpose behind these labeling requirements boils down to informing consumers:
- That could mean protecting someone’s health by requiring a list of ingredients to help prevent allergic reactions.
- It could also mean protecting someone’s purchase by requiring that the accurate net weight of the product be shown on the label.
- It could even mean protecting someone’s ability to exercise their personal beliefs by requiring certain conditions be met before a product is labeled “cruelty free” or “organic.”
In any case, the FDA’s goal with these requirements is ultimately to protect the health and well-being of your customers—a goal you undoubtedly share!
A Breakdown of the FDA Requirements for Cosmetic Labeling
The FDA has published, in quite some detail, all their legal requirements for cosmetic labels. While these rules are thorough, they’re also a lot to take in.
To help you make sense of it all, here’s our explanation of what some of these rules mean and how they apply to your labels.
Identity Labeling: Telling Cosmetic Consumers Who You Are
When you think about building a brand, consider the face of your product. The principal display panel, or PDP, is the most visible aspect of your packaging, likely the site of your logo, brand colors, and other key elements that go into your visual identity.
The PDP is also subject to federal requirements, so it’s here that our exploration begins.
This might seem obvious, but the first requirement for your PDP is that it’s large enough to fit all the required label information. Those details also need to be clear and conspicuous to the consumer (in other words, people shouldn’t need a magnifying glass to read it).
The FDA does offer some guidelines for the size of your PDP, which is based on the shape of the packaging:
- For rectangular packages, the PDP’s area should be one entire side.
- For cylindrical packages, the PDP should be 40% of the height multiplied by the circumference.
- For all other shapes, the PDP should be 40% of the total container surface, minus the top, bottom, neck, shoulder, and/or flanges.
The PDP should also identify the commodity in terms of the “common” or usual name of the cosmetic or provide a descriptive name. If it’s obvious what the cosmetic does just by looking at it, a “fanciful” name can also be used, or the identity can be shown via illustration.
These identity elements need to be in bold and in a size similar to the name of the cosmetic, or the most prominent printed words on the label. It should also be printed so that the words run parallel to the base of the packaging.
(If these requirements seem awfully specific, well — we’re just getting started.)
Net Weight: How Much is Your Customer Buying?
Anyone who’s ever bought a bag of chips that was 95% air knows packaging can sometimes be a little misleading. That’s why the FDA requires the net weight of certain products be clearly shown on the label.
For cosmetics, there are four main considerations to how the net weight should be displayed:
- Accuracy
While the FDA does account for reasonable variations that occur as an inevitable part of the life of a product, it doesn’t excuse inaccurate numbers. The net weight figure should correctly describe the weight, volume, measure, numerical account, or combinations thereof for the cosmetic. - Product Consistency
Cosmetic products can be in solid, liquid, viscous, or other physical states. Each of these can affect how the net weight is determined and must be factored into the label display. - Systems
To ensure a standardized system of weight is used across the industry, the FDA requires that weights are shown in terms of avoirdupois pound and ounce. For fluid cosmetics, the measurements should be shown in terms of the U.S. gallon, quart, pint, and fluid ounce. Net contents can also be given using the metric system, but only in addition to the original requirements. - Unit Terms
To make sure the unit of measurement is clear to the consumer, the phrase “net weight” (abbreviated “net wt.”) must be used as part of the weight statement. Likewise, “net contents” (abbreviated “net”) must be used as part of the liquid statement.
Ingredient Labeling: What’s in the Cosmetic?
Ingredient labeling is an important component of consumer safety. After all, it’s important to make sure customers know what’s in a cosmetic before they apply it to their bodies. Your label should include a list of ingredients in order of falling predominance.
When the FDA first created requirements around ingredient labeling in the 1970s, it was clear there needed to be some kind of common agreements on terms. Otherwise, you could end up with the same ingredient going by multiple names depending on the manufacturer.
To that end, the “source of truth” for ingredient names is the Cosmetic, Toiletry, and Fragrance Association’s Cosmetic Ingredient Directory. With regularly published new editions, the directory continues to be updated with new ingredients as they’re developed and introduced.
Exceptions to Ingredient Labeling
There are certain exceptions to what gets included in your ingredient labels. For one thing, if you have an active ingredient that would also classify your cosmetic as a drug, that ingredient should be shown separately from the rest of your ingredient list.
There are also exceptions related to trade secrets and intellectual property. The FDA has agreed that certain ingredients may be considered exempt from public knowledge, in which case your label will simply say “and other ingredients” at the end of the listing. Just be sure your ingredients meet the standards for the exemption before you try going this route.
Name and Address of Manufacturer or Distributor: Who (and Where) You Are
Transparency is the name of the game when it comes to consumer safety. As a result, the FDA requires manufacturers to include their name and address on the packaging.
In some cases, there may be exceptions in which it makes more sense to include the packer or distributor’s name in place of the original manufacturer. That’s OK, as long as the address is prefaced by appropriate wording, such as “distributed by,” to make clear what the name and address refers to.
In any case, the name shown must be the proper corporate name, just as the address should be the principal address of the business.
Warning Statements: Protecting Your Customers
The FDA doesn’t mess around when it comes to warning statements. If your label should have one but doesn’t, it could result in penalties both for your company … and any retailer, manufacturer, and packer that works with you.
There’s also the risk to the consumer. Warning statements are intended to protect your customers from harm, which ultimately protects both you and the people you serve.
How these statements appear on your labels are shaped by two major criteria:
- Prominence
Under no circumstances should a warning label be difficult to find or read. They should appear prominently when compared to the rest of the label, in a format that’s easy to identify and understand. - Conspicuousness
The lettering must be at least 1/16th of an inch in height, bold, and contrast against the background it’s printed on. This helps ensure your customers can’t overlook it.
Drug Claims: Does the Cosmetic Have a Physiological Effect?
Some cosmetics are purely for appearance’s sake, helping customers lock down a killer look.
There are, however, cosmetics that have a physiological effect, in which case they are also classified as a drug.
As such, this subcategory of cosmetics has some additional labeling requirements. The ingredient(s) that delivers the physiological effect must be listed separately on your label, specifically as the “active ingredient(s)” we mentioned above. As part of this labeling, you’ll also need to include the type and quantity of the ingredient(s), along with what proportion of alcohol, if any, your product contains.
Font Requirements
We’ve touched on some of these requirements already, but the font requirements for cosmetic labels are extensive enough that they deserve their own section in this guide. Here are the main things to watch:
- Style and Size of the Letters
On your panel display label, the font needs to be large enough to be legible within the physical confines of the PDP itself. The letters should be easy to read by the average consumer. - Background Contrast
The lettering should stand out against its background. If the contrast is so low it causes legibility problems, you need to design a new label.
- Obscuring Designs and Vignettes
It’s great to feature design work in your labels, but it can’t come at the expense of your required label statements. Make sure your ingredients list and warning label are clear and easy to read. - Ingredient Declaration
Here, the guidelines get pretty specific. Your ingredient list should be in a font that’s no less than 1/16” high. The exception is for labels measuring less than 12 square inches, in which case the letter height should be no less than 1/32” (all the above rules still apply — your ingredient list should have high contrast, no design interference, and be as easy for consumers to read as possible).
Get Expert Guidance on Federal Cosmetic Labeling Requirements
If you’re feeling a little overwhelmed by the extend of the FDA’s cosmetic labeling requirements, that’s OK. No one ever complained federal regulations were too simple. The good news is you don’t have to go it alone.
When you need help finding resources on the rules and regulations for cosmetic label printing, we can help point you in the right direction. And once your design is complete, we’ll help you print a high-quality label you’ll love. Contact us today.
