Labeling Regulations for Cosmetics
Proper labeling is important for cosmetics as it provides information about a product to the prospective customer. The labeling usually contains information about a product's intended use, its ingredients, net quantity of contents, its place of manufacture or distribution and any related warnings. On top of that, labeling is also an important aspect of marketing as good labeling attracts consumers.
In the USA, cosmetic labeling is regulated by the U.S. Food and Drug Administration (FDA) under the authority of both the Food, Drug, and Cosmetic Act (FD&C Act) and the Fair Packaging and Labeling Act (FPLA). The regulations ensure that the labeling is accurate and not misleading.
Principal Display Panel and Information Panel
The principal display panel is the part of a label that the consumer sees when the product is displayed for retail sale. A label usually consists of more than one panel. While the front panel is known as the principal display panel or "PDP", the back and side panels are generally called information panels. The principal display panel contains two important pieces of information: An identity statement and an accurate statement of the net quantity of contents. In the FD&C Act it is determined that:
"The identity of the commodity may be expressed in terms of the common or usual name of the cosmetic, a descriptive name, or when the nature of the cosmetic is obvious, a fanciful name. It may also be expressed in form of an illustration." [21 CFR 701.11]
The net quantity of contents must accurately reveal the quantity of product in the container in terms of:
- Numerical count
- Or combinations of count and weight, volume or measure
In some cases, reasonable variations are acceptable. For example, when there is loss or gain of moisture. The information panel must contain information about the ingredients, material facts, the distributor and potential hazards.
Clear labeling is necessary to prevent recalls
Incorrect labeling usually results in misbranding of the product. This can happen for instance when there are missing material facts like directions of safe use. Cosmetic products that could pose hazardous risks must be labeled as such. Specific warning is required when flammable ingredients like aerosols are being used. The list of ingredients always needs to be complete even if it is labeled "for professional use only".
Cosmetic manufacturers are not required by law to print expiration dates on the labels of their products. However, cosmetic firms are in charge of consumer safety. Therefore, the FDA recommends the inclusion of product shelf life on cosmetic labels. However, not all personal care products are classified as cosmetics. Many of them - sunscreen for example, are considered as drugs. Accordingly, other regulations apply to such products.