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The label on a cosmetic product is an important selling point for a

company's product. Most cosmetics purchase decisions are made at the


point of purchase, and the product label is important in helping consumers
make those decisions. While planning to print labels for their product, a
manufacturer must go through the rules and specifications set up by the
Food and Drug Administration (FDA).

The FDA's stringent regulations governing the labeling of cosmetic


products serve as a critical foundation for ensuring consumer safety and
transparency within the beauty industry. These labeling requirements
dictate the essential information that must be accurately conveyed to
consumers. It is also applicable to manufacturers of soap and aromatherapy
products. So why are these rules so important to follow?

● The FDA's main purpose is to protect the health of humans.


● These rules ensure that products are suitably labeled and safe for the
purposes for which they are being manufactured.
● The product must be safe for the consumer. It means the labeling and
packaging should be clear when the consumer uses the product as per
the given directions on the label or how people typically use it.
● These regulations protect consumers from unsafe, deceptively labeled
or packaged products.
● It restricts the movement of adulterated or misbranded cosmetic
products.

Under the authority of two acts, the FDA regulates cosmetic labeling. The
Fair Packaging and Labeling Act (FPLA) is one Act; the other authority is
the Federal Food, Drug, and Cosmetic Act (FD&C Act). In 1938, the FD&C
Act was created. FD&C Act authorizes the FDA to supervise food, drugs,
and cosmetics safety.

As per the FDA, the requirements for labels

All labels must be designed and applied to containers properly. The labels
should remain in place and be properly legible during the customary
distribution, storage, and use conditions. It also includes other labeling that
contains user instructions and should remain legible during customary
storage and use.

Let's discuss the rules that the FD&C Act and the FPLA say.

● Except for the ingredients the FDA has listed as restricted,


manufacturers are free to use any ingredients in their products.
Additionally, when adding color additives, it is important to ensure
they have proper approval from the FDA.

● The FDA doesn't prohibit manufacturers from creating cosmetic
products outside their homes. It is important to ensure that all other
rules and regulations are followed. For good manufacturing practices
(GMP), there are no specific rules. The FDA gives a GMP checklist
that lists the things that an FDA investigator would inspect.

● In the case of cosmetic products manufactured for retail store
purposes or online orders, they must also meet the FPLA labeling
requirements and the FD&C Act requirements. The FPLA directs the
Federal Trade Commission (FTC) and FDA to issue label regulations
for all consumer commodities.

● This Act requires labeling packages to provide consumers with
information about the quantity of contents, which must be accurate.
● It will make value comparisons easier. It should also show the
commodity's identity and the name or place of the product's
manufacturer. The Act also allows additional regulations to restrict
other forms of consumer deception because of labeling.

● FD&C Act requires that any information on the immediate container's
label must also be visible through the outside container of the retail
package or appear on the label of the immediate container.

Understanding the FDA's Definition and Criteria


The definition of the term' label' varies for the FD&C Act and the FPLA.
FD&C Act, considers a label as "a display of written, printed or graphic
matter upon the immediate container. " FPLA defines a label as a "written,
printed or graphic matter affixed to any consumer commodity or affixed to
or appearing upon a package containing any consumer commodity."
As per the FD&C Act, a cosmetic is considered to be misbranded if
● Labeling is false or misleading.
● The label does not state (a) the address and name of the
manufacturer, packer, or distributor and (b) the net quantity of
contents.
● The required information is not provided in a way that is obvious,
conspicuous, and easy for consumers to read and understand under
purchase conditions and use situations.
● The container or its contents is misleading.

As per the FD&C Act, a cosmetic is considered to be misleading when


● Labeling may be misleading when a label statement is deceptive and a
material fact is not revealed to the consumer.
● A fact may be relevant if it clarifies a statement made on a label or if
using a product as advised leads to certain consequences.

Understanding the placement of information on labels

FP&L Act requires that The information related to ingredient labeling and
statement of the net quantity of contents appear on the label of the outer
container holding the inner (immediate) container. If a cosmetic product is
not displayed in a box, folding carton, etc., then the outer container holding
the cosmetic product is the immediate container. The outer container can
be a box, folding carton, wrapper, etc.

The part of the label that is most likely displayed or checked under
customary conditions of display for sale is the principal display panel. This
part must state the product's name, nature or use, and the package's net
quantity of cosmetic contents. The quantity should be mentioned as a
measure, numerical count, weight, or a combination of the numerical
count.
The declaration must be legible, placed in the panel's bottom area, and the
container's size as prescribed by regulation. The firm's name and place of
business marketing the product must be stated. It should be mentioned on
an information panel of the label along with the address with a street
address, city, state, and zip code.

As per regulations, Label Warnings should be

Cosmetics that are hazardous to consumers when misused must contain


adequate directions for safe use and appropriate label warnings. The
statements must be conspicuous and prominent. Some cosmetics, such as
cosmetics in self-pressurized containers (aerosol products), feminine
deodorant sprays, and children's bubble bath products, are examples of
products that must bear label warnings or cautions prescribed by
regulation.

The FD&C Act does not require cosmetic manufacturers or marketers to


test their products for safety. However, the FDA strongly urges cosmetic
manufacturers to conduct whatever toxicological or other tests are
appropriate to substantiate the safety of their cosmetics. Suppose the safety
of a cosmetic is not adequately substantiated. In that case, the product may
be subject to regulatory action or may be considered misbranded unless it
bears the following statement: Warning--The safety of this product has not
been determined.

As per the FDA website, the definition of cosmetics mean

"Product, except soap, intended to be applied to the human body for


cleansing, beautifying, promoting attractiveness, or altering the
appearance." It may include shampoo, makeup, other hair products,
tanning products, scrubs, nail products, deodorants, other skin products,
some oral care products, perfumes, and others.
Let's discuss how the label should be while labeling for product
● The necessary content includes the product's name, net quantity, safe
use directions, any warnings, a list of ingredients, and information on
the business.
● The FDA guidelines require that the ingredients be listed in weight
order. Heaviest to lightest must be the order.
● a warning and/or directions for safe use of products
● must have the information displayed legibly.
● The label has to be large enough so that the required information is
prominently displayed and is easy to read.

Conclusion

It is important for manufacturers to familiarize themselves well with the


FDA’s regulations before planning to start working on cosmetic labels. By
adhering to these regulatory standards, manufacturers meet legal obligations
and contribute to building a transparent and accountable cosmetic industry.
The label on a cosmetic product is not merely a marketing tool; it serves as a
way to convey essential details regarding ingredients, usage, and potential
risks.

Beast Branding provides custom labels for all varieties of products and
across different industries. We take wholesale orders at affordable rates.
Browse all our ready-for-label packaging collection today!

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