≡ Menu

How to Label Cosmetic Products

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. cosmetic label reading

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.

  1. Ingredients above 1% need to be listed in order of concentration
  2. Ingredients 1% or below can be listed in any order
  3. 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

  1. Name of the product (e.g shampoo, lipstick, eyeshadow)
  2. Name of manufacturer or distributor
  3. Address of manufacturer including city and zip code
  4. Net contents in container
  5. 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.

{ 45 comments… add one }

  • Bri 10/24/2014, 3:11 pm

    If your product contains two items with the same concentration, which should be listed first? Is it alphabetical or up to the discretion of the manufacturer?

    • Perry Romanowski 10/27/2014, 8:29 am

      In these situations, it’s up to you. Just be consistent.

  • Georgina 08/12/2014, 2:38 pm

    Gosh! Vert informative article! I had no idea they had to label their products like that. I’ll be double checking everything I buy now!

  • Patent Attorney 06/12/2014, 4:56 am

    Excellent guide! You cover everything that is important, and with cosmetic products there’s not much space for getting things wrong!

  • Heather 06/05/2014, 10:46 am

    Perry
    Can you clarify how to list the name and address of the distributor on cosmetic packaging. I am running an on line business out of my home and don’t want to list my home address on the packaging. Can I open a PO Box and use that address?
    The manufacturer is in Asia. For my packaging, can I just list Made in Korea, Dist. by Corp name, PO Box #, Street address of post office, City and Zip?

    thank you

    • Perry Romanowski 06/16/2014, 5:31 pm

      You just need to list the City and Zip code. You don’t need your street address.

  • Michelle 07/30/2013, 12:41 pm

    On the IL for a consumer porduct is it possible to list the trade name following the INCI name?
    For example:

    Panthenol (Pro-Vitamin B-5)

    Thanks.

    • Perry Romanowski 07/31/2013, 10:02 am

      No. The proper listing is Panthenol. If you want to say Pro-Vitamin B-5 you have to do it in the label copy outside of the LOI.

  • agabeain 01/04/2013, 12:37 pm

    hi Perry
    pls send formula hair stiling gel

    • Perry 01/06/2013, 9:38 pm

      See out post on free cosmetic formulas and search the databases.

  • Guuky 12/05/2012, 1:37 pm

    Do a google search online about labeling and you will see most of the large companies are not putting ingredients, etc on their products. They are listing ingredients in the packaging box (that you throw away immediately) and all that is left is their large logo on product it self as free advertising for several months.

    • Perry 12/09/2012, 7:07 pm

      Well, most cosmetic products are not sold in boxes so this is not true. I’m including in that personal care products.

  • daniella 11/01/2012, 12:35 pm

    hi there Perry im wanting to make natural cosmetics also and am making up a massage blend using essential oils, im aware of the inci name for these oils but i thought you also had to list known sensitisers that canbe found in the essential oils. Are you aware of this and how would i get such a list?

    • Perry 12/09/2012, 7:08 pm

      You should get the list of sensitizers from your supplier of the oil.

  • pintoo 09/08/2012, 12:05 am

    @ Perry, what about the calculation of fill weights?
    How does the Production batch in weight translate to Volume while filling?

  • KC 07/25/2012, 3:49 am

    Hi Perry,
    Your article is really informative, but I have a question.
    If in a product, a % of formulation which in itself contains some preservatives, was added, the labeling needs to show all the preservatives from that formulation by law? thank you!

    • Perry 07/25/2012, 6:30 am

      Yes. If a raw material has preservatives in it, you need to show those one the label of your final product.

      • KC 07/26/2012, 7:04 am

        A follow up question is: if that product didn’t show all the preservatives, is it susceptible to lawsuit? thank you

        • Perry 07/26/2012, 7:47 am

          I’ll preface my answer with the following…I am not a lawyer and am not giving legal advice. This is just my opinion based on my knowledge of the labeling rules. If you want a legal opinion, you should talk to a lawyer.

          Alright, when someone puts out a product that is mislabeled (which is what they would be doing by not listing all the preservatives) the FDA would consider it a Misbranded product and this is what they say would happen….

          “FDA may take regulatory action if it has information to support that a cosmetic is adulterated or misbranded. The agency can pursue action through the Department of Justice in the federal court system to remove adulterated and misbranded cosmetics from the market. To prevent further shipment of an adulterated or misbranded product, the agency may request a federal district court to issue a restraining order against the manufacturer or distributor of the violative cosmetic. Violative cosmetics may be subject to seizure. FDA also may initiate criminal action against a person violating the law.”

          In reality, there is a low probability that you would ever be taken to court over something like this. It is against the rules & a shady business practice but lots of small companies do it.

          • KC 07/26/2012, 8:39 am

            Thank you Perry. I really appreciate you took the time to answer my question.

          • Dorian 05/21/2014, 1:56 pm

            Would like to ask you (Perry) about your thoughts (besides the preservatives in an ingredient) about additives in an ingredient that are declared in the composition section of an Safety Data Sheet (SDS) or Technical Data Sheet (TDS) BUT is NOT declared on the INCI in those documents. Should they (additives) be declared on the LOI? I’m asking because some additives may be Prop 65. Your thoughts?

          • Perry Romanowski 05/29/2014, 6:45 pm

            If you know that an ingredient is in your formula you should declare it on your label. Especially if the ingredient is no the Prop 65 list.

  • AC 07/16/2012, 3:12 pm

    Hi Perry

    I just wondered how to come up with an INCI list for this particular situation. If for instance I have the following ingredients in the product that I made (just a sample formulation to show my point):

    1) Deionized Water — 98 %
    2) Basil Extract (INCI name: Water, Butylene glycol, Ocimum Basilicum (Basil) Flower/Leaf Extract, Lactic acid) — 0.10 %
    3) Lactic acid — 0.25 %

    How is the INCI listing then for this product, considering the extract contains water and lactic acid, ingredients that are used in the formulation as stand alone or the as the individual ingredients themselves?

    Thank you so much. Hope to hear from you.

    • Perry 07/16/2012, 3:17 pm

      If the ingredient is in the formula at under the 1% level then the order does not matter. It can be listed anywhere (as long as it is below the 1% line).

      So, this ingredient list would be

      WATER
      LACTIC ACID
      BUTYLENE GLYCOL
      OCIMUM BASILICUM (BASIL) FLOWER/LEAF EXTRACT

      or it could be

      WATER
      OCIMUM BASILICUM (BASIL) FLOWER/LEAF EXTRACT
      BUTYLENE GLYCOL
      LACTIC ACID

      You have to list all the ingredients that make up the extract but the order you use doesn’t matter in this case because it is under 1%

      • AC 07/16/2012, 3:42 pm

        Thank you a lot Perry. So that means to say then, one cannot tell by just looking at the ingredients list if the extract does contain butylene glycol as solvent and the lactic acid. One can assume then any of the following:
        1) that maybe these two ingredients (butylene glycol and lactic acid) are used independently in the formulation, and that the Basil Extract’s INCI could be just ‘Water and Ocimum Basilicum (Basil) Flower/Leaf Extract’.
        2) that maybe, yes, they are part of the INCI name for the Basil Extract as I have laid down in the formulation above.

        Am I correct in saying that? :)

        • Perry 07/16/2012, 3:44 pm

          Yes, that’s correct. You can not tell from an ingredient list which of the ingredients are added to the formula as a blend.

          • AC 07/16/2012, 3:52 pm

            I see. Another scenario. What if the formulation now is like the one below. How is the INCI list?

            1) Deionized Water – 97.40 %
            2) Basil Extract (INCI name: Water, Butylene glycol, Ocimum Basilicum (Basil) Flower/Leaf Extract, Lactic acid) – 0.10 %
            3) Butylene glycol — 1.10 %
            3) Lactic acid – 1.50 %

            A second question would be: Are the percentages by weight for instance of the components “water”, “butylene glycol”, and “lactic acid” in the extract not considered?

            I hope I am not too much, though I am. You are already very helpful! :)

          • Perry 07/16/2012, 3:58 pm

            In this scenario, you have to figure out the % actives in the extract. So, if the extract is 90% butylene glycol and 10% everything else, the amount of butylene glycol in your whole formula would be 1.19% giving the label…

            WATER
            LACTIC ACID
            BUTYLENE GLYCOL
            (rest of the basil extract name)

            But if it were 1.5% Lactic Acid and 1.45% Butylene Glycol + Extract, then the order would change because the total amount of Butylene Glycol would be 1.54% (1.45% + .09%)

          • AC 07/16/2012, 4:13 pm

            Thanks so much Perry. The percentages of the componets in the extract are something that the supplier or manufacturer of the extract can provide so that makes it easy then for the formulator, isn’t it? Do you see the scenarios I mentioned above the same in both the US and the EU?

          • Perry 07/17/2012, 7:22 am

            Yes, the % breakdown of a raw material should be given to you by the supplier. Both the US and EU follow the naming convention of the INCI so yes, the rules should apply. However, I’m not well-versed in all the country specific cosmetic regulations so I would check with a lawyer or EU cosmetic chemist consultant before moving ahead in one of the EU countries.

  • Aisha 12/07/2011, 10:35 am

    Are there any regulations on labeling and expiration dates/shelf life dates?

    • Perry 12/07/2011, 10:40 am

      In the US, the only regulations are related to OTC products, not cosmetics. In the EU, there are regulations about expiration dates.

  • Perry 07/10/2011, 9:04 am

    @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.

  • Tiffany 07/10/2011, 9:00 am

    BTW not sure why my avatar is a grumpy face.. sorry

  • Tiffany 07/10/2011, 8:59 am

    Even if it’s for stretch marks, scars, and the likes?

  • Tiffany 07/09/2011, 10:51 pm

    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!

    • Perry 07/10/2011, 7:37 am

      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.

  • Shalini 05/22/2011, 7:32 am

    is there any legal implications if i used “and” on the methyl (and) propyl paraben as my ingredients?

    • Perry 05/22/2011, 8:06 am

      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?

  • maria 04/25/2011, 2:45 pm

    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>

    • Perry 04/25/2011, 6:38 pm

      no you do not use the ‘and’. You use the specific INCI name for the individual ingredients.

  • Karen 04/05/2011, 9:29 pm

    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?

  • Tumur 09/27/2009, 12:10 am

    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.

  • Perry 09/21/2009, 10:04 pm

    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.

  • Kimberly Riley 08/29/2009, 1:22 pm

    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!

Leave a Comment