Resources for Selling Natural Body, Hair, Skin Products :: Labeling of Cosmetics
March 15, 2012
You have your ideal line of products formulated and your containers picked to perfection. Now what? Labeling your product is the next step in product development and it can be a bit more difficult than slapping on just your brand name. Here are some useful tips to help you navigate the practice of acceptable product labeling, according to the FDA website:
Branding: some of the ways a cosmetic can become misbranded:
- its labeling is false or misleading
- its label fails to provide required information
- its required label information is not properly displayed
- its labeling violates requirements of the Poison Prevention Packaging Act of 1970 (see FDA website link for information).
What languages are acceptable?
All required labeling information must be in English. The only exception to this rule is for products distributed solely in a U.S. territory where a different language is predominant, such as Puerto Rico. If the label or labeling contains any representation in a foreign language, all label information required under the FD&C Act must also appear in that language.
The following information must appear on an information panel:
- Name and place of business. This may be the manufacturer, packer, or distributor
- Distributor statement. If the name and address are not those of the manufacturer, the label must say “Manufactured for…” or “Distributed by…”
- Material facts. Failure to reveal material facts is one form of misleading labeling and therefore makes a product misbranded. An example is directions for safe use, if a product could be unsafe if used incorrectly.
- Warning and caution statements. These must be prominent and conspicuous. The FD&C Act and related regulations specify warning and caution statements related to specific products. In addition, cosmetics that may be hazardous to consumers must bear appropriate label warnings. Flammable cosmetics are an example.
- Ingredients. If the product is marketed on a retail basis to consumers, even it is labeled “For professional use only” or words to that effect, the ingredients must appear on an information panel, in descending order of predominance. As an alternative, when cosmetics are distributed on a mail-order basis, the package mailed to the consumer may contain readily visible instructions for locating the ingredient declaration, such as in a product catalog (currently interpreted as including a website), or instructions for requesting a copy of the ingredient declaration. Mail-order distributors must respond promptly to such requests. Remember, if the product is also an OTC drug, its labeling must comply with the regulations for both OTC drug and cosmetic ingredient labeling, as stated above.
- Click Here to a link for the FDA Cosmetic Labeling Guide.
Please also see our Resources section with links to pertinent information regarding these and other product selling resources.
Kelly Kenny – Blog Contributor for Joan Morais Naturals