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.
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:
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!
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.
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:
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.)
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:
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.
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.
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.
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:
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.
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:
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.