Labeling cosmetics properly is absolutely crucial when creating their packaging. Cosmetic label requirements fall under the purview of the US Food & Drug Administration. A good place to start researching is the FD&C Act and the Fair Packaging and Labeling Act, among other regulations (CFR 701).
First, it’s important to define what qualifies as a cosmetic. According to the FD&C Act, cosmetics are “articles intended to be applied to the human body for cleansing, beautifying, promoting attractiveness, or altering the appearance without affecting the body’s structure or functions.” Think creams, make-up, lotions, shampoo/conditioner, deodorant, etc.
Cosmetics are different from drugs. Drugs can be defined as products that intend to alter the functions of the body or treat, cure, or prevent disease—anti-fungal creams, toothpastes with fluoride, sunscreen, etc. Drugs have even more stringent regulations. For the sake of simplicity, we will only be covering the labeling of cosmetic products in this article.
General Cosmetic Labeling Requirements
The following items should appear in some form or fashion on your cosmetic label:
Name of the Product
What is the product you’re selling? What is the scent or flavor name? Make it clear on the PDP (primary display panel) of your packaging. This would be the front-facing, main section of your label or the front panel of your carton. Think of the PDP as the main panel the customer first sees or interacts with when viewing your product.
Nature/Use of the Product
According to the FDA website, you must “identify by descriptive name or illustration the nature or use of the product.” It must be clear the intended purpose of your cosmetic.
Net Quantity
This is how much product is in the container that you’re labeling. This can be listed as “net weight” or “net contents.” Make sure to differentiate between “oz” and “fl oz,” if applicable.
Name and Address of Business
This is usually accompanied by “Manufactured for” or “Distributed by.” According to FDA cosmetic labeling requirements, “the address must state the street address, city, state, and zip code. Only if a company is listed in a local directory does the label not require a full address.”
Country of Origin (if outside US)
The Tariff Act of 1930 requires that all products manufactured outside of the US have clear labeling as to their country of origin and must be in English. Products manufactured within the US don’t need “Made in the USA,” but many manufacturers like to add it to the packaging as a source of pride.
Declaration of Ingredients
There a few notable cosmetic label requirements when it comes to displaying ingredients. First, ingredients must be declared on any cosmetic designed for retail purchase. Because of this, some products used by professionals at their salons (and not sold to customers) may not need to meet these requirements. Second, the ingredients listed must be prominent so they are read by a customer before purchase. There are also specific text size requirements for the ingredients—the FDA lists 1/16″ (which would correspond to a 4.5 pt type size) as the minimum size. The exception to this rule would be if the total labeling area is less than 12 square inches—in that case, the type size must be no smaller than 1/32″ (or 2.25 pt). Third, ingredients must be listed in order of predominance (with the exception of color additives).
Label Warnings & Tamper-Resistant Packaging
Depending on the cosmetic, certain safety and warning labels must be added to the packaging. Also, certain cosmetic products require tamper-evident packaging, such as sealing or taping, to ensure user safety. Some cosmetics that require tamper-evident packaging include mouthwash, toothpaste, etc.
Order Cosmetic Labels
Ready to order cosmetic labels? We’ve got great materials—white vinyl, white plastic, metallic plastic, and more. We also offer a variety of laminates that protect your label from water and oil. If you want to see our materials before making a choice, let our Customer Care Team know that you’re interested in a free sample pack!
*This article is not a complete, legally-binding guide to cosmetic labeling. If you are concerned about FDA compliance, contact the FDA directly or find a third-party regulatory review board that would be able to review your packaging before its production. Any information in this article may not be accurate at a given time and will be subject to change per the update of FDA guidelines.
