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Labeling Question
Hello,
Question about labeling.
So I make facial products and my containers are very small. My emulsions are 50 g. I’m having a hard time fitting all of the FDA requirements on the tiny label.
My question is, is it acceptable to include a little paper with every product that displays the INCI, volume and place of production instead of having this information on the label itself?
I’ve noticed that there are commercial products that display this information on the box the product comes in, instead of the product’s packaging itself.
Thank you.
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7 Replies
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The answer is affirmative, as long as the primary package is inside a secondary display carton for retail sale. You may print most of your label content on the carton, less on the bottle/jar/tube as long as it is comprised by the same SKU. Alternatively you can have your label formatted in a pressure-sensitive accordion-style like the Rx drug products use. These triple the label space, but have high MOQ, work well and are no harder to machine-apply than the common p-s labels.
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I think this will help you
https://www.fda.gov/cosmetics/cosmetics-labeling-regulations/cosmetics-labeling-guide#clgl14specifically this section:
Off-package Ingredient Labeling
Qualifying Conditions -
My humble Opinion.
50 g. jar in a box is better than naked jar.
For lower MOQ, you could ask your local printing house if they can do digital printing box.
when you reach high MOQ, you can change it to offset box. -
Why don’t you use tubes?
They are better preserved from contamination by customer
They are less expensive
You can write everything on it and dont use extra box for it. (Extra cost saving)Customer can carry it every where and use it more often.(more money for you).
It looks better than jar unless your jar is so luxury and costs 10 times more than what the product itself cost.
In business
You can not make profit when selling.
You can make profit when purchasing.
So %70 of your focus should be on reducing the costs if you want to do business. -
You can also put the information on a card or pamphlet and have it attached to the product just like the swing tag. You may even be able to just put the pamphlet next to the product and make sure it is in the bag when sold.Hope that helps Catherine
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Good point from Dr. Pratt, but think 50 gram net weight may be too much for the exemption. Perhaps follow the Olay regenerist line labeling - those are ~50 grams.
“The PDP of a “boudoir-type” or decorative cosmetic container, e.g., cartridge, pill box, compact or special variety, and those containing 1/4 oz or less may be a tear-away tag or tape affixed to the container [21 CFR 701.13(e)(1)]. It may also be the display panel of a card to which the immediate container is affixed [21 CFR 701.13(e)(2)].” -
The other option that’s alluded to in the UK/EU is peelable labels that then give two additional surfaces for information. I don’t have any experience with them in a manufacturing capacity but they’re pretty commonplace here.