My first experience with cosmetic labeling came in college when I turned over the bottle of a shampoo and looked at the ingredient list. It was right 
around the time when I was learning how to name chemicals and I was confused why I couldn’t recognize almost any of the ingredients. It turns out that the cosmetic industry doesn’t follow the IUPAC system which is what they teach you in college. It follows the system set up by the Personal Care Products Council (PCPC) as described in the INCI Dictionary. See our previous post on cosmetic labeling and the naming conventions in it.
But the ingredients names in your formula are only part of the labeling process. You also have to follow the labeling rules laid out by the FDA that affect ingredient order, placement on the label, text size, language and more. Here are the relevant facts.
Cosmetic ingredient list
In the United States, it is a requirement that all cosmetics be labeled with their ingredients. The LOI (list of ingredients) is supposed to be printed on the container and needs to follow some rules when listing ingredients.
- Ingredients above 1% need to be listed in order of concentration
- Ingredients 1% or below can be listed in any order
- Exception: Color ingredients are listed at the end
The names of the ingredients must be those found in the INCI (International Nomenclature of Cosmetic Ingredients) Dictionary.
Where does the list go?
Once you have the list, you’ll have to put it on the package in the proper position. The FDA requires that it be put on the principle display panel which in most cases just means somewhere on the primary package where people can read it. See this for details.
What kind of font?
To ensure that the ingredient list is readable, the FDA requires that the font size be no smaller than 1/16th of an inch unless your packaging is really small in which case you can make the font 1/32nd of an inch.
What language?
Products sold in the United States must be written in English.
What else do you include?
Other information you need to list includes
- Name of the product (e.g shampoo, lipstick, eyeshadow)
- Name of manufacturer or distributor
- Address of manufacturer including city and zip code
- Net contents in container
- Warning statements if required
For more details about what and how you specifically need to list information on your labels in the United States, see this section on the FDA website.
{ 15 comments… read them below or add one }
Are there any regulations on labeling and expiration dates/shelf life dates?
In the US, the only regulations are related to OTC products, not cosmetics. In the EU, there are regulations about expiration dates.
@Tiffany – it really depends on the claims you make. If you are making medical claims then that would make them a drug and they would be regulated differently. However, stick to cosmetic claims (makes things look better, improves appearance of…) and then you can follow the cosmetic rules.
If you are worried about it, you should check with a lawyer. We are not lawyers here so don’t take what we say as legal advice.
BTW not sure why my avatar is a grumpy face.. sorry
Even if it’s for stretch marks, scars, and the likes?
At what point do I need to write “These statements have not been evaluated by the FDA. This product is not intended to treat, cure, or prevent any disease”? I am looking to make all natural (aside from synthetic preservatives though I’m testing natural ones such as NataPres first) skin care products and I want to label them correctly. I intend to write that they are used for moisturizing, etc but I read that makes them a drug not a cosmetic.. I need help!
Thanks!
Saying they are moisturizers does not make them a drug. You do not need to write the statement that you have indicated. You just need to properly label the ingredient list, the product description, the amount in the bottle, the business location and the other things outlined in the post.
is there any legal implications if i used “and” on the methyl (and) propyl paraben as my ingredients?
It is a violation of the INCI naming rules however, this is unlikely to be something that the FDA would take action against. What would be the benefit of using “and” rather than proper naming rules?
when u list ingredients that have more than one item(like a blend)
i.e glycerin (and) water (and) sodium…do u need to use the (and)’s or do you just list the ingredients>
no you do not use the ‘and’. You use the specific INCI name for the individual ingredients.
Hi, I am designing the labels for our organic facial oils and was wondering what point font is 1/16th of an inch and what font is 1/32nd of an inch. Anyone know?
I like your article but you need to write more about how to handle customer compaints. I am working in cosmetic company last 6 years. We had lot’s of problems of labeling products with our customer. I am writing about cosmetic chemitry in my blog. Please feel free to leave a comment.
http://btumur.blogspot.com
Good a job Perry, keep writing articel. I will visit your blog once in well.
Kim
There is not an exception for lipsticks. What many companies do is use an outer packaging and put the ingredient list on the outer box. The ingredients are listed for the consumers.
I would suggest you take a look at what other companies do when labeling their lipsticks. Take particular note of what big companies do. They are the most likely to be properly following the rules.
Great article Perry! This information is very helpful. I need to be aware of the regulations before I purchase any labels for my cosmetics.
As I have been formulating my lipsticks and lip glosses for Kimistry Cosmetics, I wondered “How am I going to declare all of my ingredients on the small containers?” I noticed some companies only declare the active ingredients or some don’t have a declaration list at all. Is there an exception for lipsticks and lip glosses? Or are the ingredients provided to the customer and not necessarily to the consumer? Thanks and have a nice day!