Cosmetic Packaging Label Regulations

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The FDA has put several measures in place to protect consumers from false or misleading representations on cosmetic packaging.

A product qualifies as a cosmetic product if it is “intended to be applied to the human body for cleansing, beautifying, promoting attractiveness, or altering the appearance” with the exception of soap.

To set forth uniform standards of safety, the FDA demands that every package you bring to market adhere to 2 main principles:

1.Every package must accurately represent the quantity of the content and facilitate value comparisons.

2. Packages must be branded accurately.

Seems fairly simple, right?  Well, what actually constitutes an accurately branded package?   An accurately branded package avoids the following:

  • False or misleading labels
  • A label that omits the name and address of the manufacturer, filler, or distributor
  • A label that doesn’t state the net quantity of what is in the package, or the fill size is misrepresented
  • The required information is not stated prominently on the package

In short, the FD&C says a package is branded inaccurately if an ordinary individual reads a package and does not see the claim, statement or word with prominence and does not clearly take away the information they have deemed most pertinent.

When creating your package, avoid major FDA faux pas by running your package through the following checklist:

  1. Are the panels of the package large enough to convey the required information in a size that is visible and legible?
  2. Is the type of the required minimum size?
  3. Are the colors contrasted enough for easy readability of the package?
  4. Do any design elements obscure the necessary information of the package?
  5. Are your claims in keeping with regulations?  Do they suggest a physical and not a physiological benefit to consumers?  A cosmetic becomes a drug when it claims to have physiological benefits, and drug packages have a different set of regulations.
  6. Does the principle display panel (PDP) contain all the required information?  Note: the PDP regulations change depending on the shape of the package.
  7. Do your ingredients, warning statements, and fill sizes meet the minimum required size regulations?
  8. Are your ingredients in descending order and written in their commonly recognized names?
  9. Does the name and business address of the manufacturer or distributor appear on the label?
  10. Are you using the correct language with your weight statement?

For more information of cosmetic packaging regulations please visit fda.gov

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