Cosmetic Product Labeling

Moneyahoo

Hello,

I would like to know for labeling purposes. I have started a cosmetic company and it has a manufacturing component to it where I manufacture for other companies. It's my recipes but it has there labels on it and it's distributed as their product. 

I would like to know what needs to be included on the label. I see some of the information on the FDA website but it's very overwelming.  
I need to know what needs to be included on the actual cosmetic and on the packaging as well or do they include the same information? 

I also need clarification about what materials facts are as the FDA website says it needs to be included on the label.
How do you properly measure the net quantity of contents for ingredients? 

Perry

The company distributing the products would be responsible for listing their address and making sure the label is correct.

Net quantity would be measured when you fill the product. You have to fill as much as listed on the net contents. You do that by weighing the amount that you put into the container.

EVchem

There are specifics about the font size and spacing and such, but as far as contents here's what i can think of:

• Name of product prominently displayed on PDP

• net wt on PDP (if you're starting  small you can take a weight of the bottle before filling, tare it, and then weigh again for net wt.)
• on side panel you can list your address  and say "distributed by"
• you'll also need ingredients in descending order until you hit 1%, then any order is fine
• we include directions for use and a general warning about external use only, avoid contact with eyes and such.

I'm not 100% sure here but I think you need this information on your outermost packaging only, not necessarily on the cosmetic itself unless you're not packaging it into anything else.

Are you selling only in US? Are you selling in California? 

Moneyahoo

I am selling the products in the US as of now. My business is located in Florida.

Moneyahoo

What do you do if you don't have outside packaging for the cosmetic. I run a small business as of now and we just have the label on the package that includes information, nothing else. Would a card or link to somewhere with that has the needed information on it suffice. 

EVchem

I think inserts are fine, you should read the FDA off-package labeling
 

Moneyahoo

Thank you for the information.

If I use essential oils in my cosmetics but dont market them as having aromatherapy properties, treating diseases, or altering the body in anyway. I dont want to market them as a drug. Do I have to put a warning statement on the label because I used essential oils. If so, what does it need to say? Do I have to put a separate warning statement for each essential oil that I used if the product has more than one essential oil in it?

Microformulation

Have you registered as a Cosmetic Manufacturer with the State of Florida?

EVchem

@Moneyahoo ; If you are only selling in US, then you don't have to follow EU regulations where allergens must be declared (Essential oils usually have components like limonene that are known allergens, you would typically see these listed on the safety data sheets of your materials). 


I know California has separate requirements (like their Prop 65 statements) that changes what needs to be stated on label, but I would encourage you to do research on that before trying to sell there.

Moneyahoo

No I have not registered yet. How would i go about this process

Microformulation

You can't operate without registering. If you are already manufacturing, you are in violation.

https://www.mariegale.com/florida-regulations-changed-2017/

Cosmetic manufacturers are still required to get permits from the state in order to manufacture cosmetics.  That has not changed, nor have the requirements for getting said permits.

General requirements for a permit are:

• The permit may only be issued to a natural person (not a business entity) who is at least 18 years old.
• An establishment that is a place of residence may not receive a permit and may not operate as a cosmetic manufacturer or repackager.
• Good manufacturing practices must be sufficiently in place to ensure that the products produced are safe and are not (and won’t become) adulterated.