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Product Labeling Question
Hello, so I had a question regarding product labeling. So I am getting ready to launch a haircare business, but I have problem…I ordered the bottles a few months back and since then I’ve improved the formula and so the ingredient list is no longer accurate. I would love to put out the latest formula as I think it’s better, but obviously it wouldn’t be accurate and I could be fined/sued. However, I have seen on company websites they usually place a disclaimer that their ingredients on the website may be different than what’s on the bottle but to always check the bottle. Would it be possible for me to place a disclaimer note inside the packaging of the box that the bottles come in so as to be transparent and avoid false labeling claims? Please let me know. I want to do what’s right but I also want to launch as soon as possible. If I were to reorder bottles that would set me another 2 months and some cash. Of course I could always just go with the old formula but I would rather not…
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7 Replies
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Unfortunately, the label must reflect the actual contents of the Product.
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I figured that was the case but also wanted to ask. Guess I’ll stick with my old formula for now
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Not aware cosmetic companies comment that they may not be in compliance with FDA regulations. Can you name the ones you saw?
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I’ve seen it here and on target before, so perhaps not by the company itself but by retailers. I could’ve sworn I’ve seen Oribe post a similar notice under their ingredients list as well but I just checked and it’s not there anymore
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Ingredient statement must be provided at point of purchase - with responsibility being on the head of the “guy” named on the package. You’re seeing attemtp at cya from retail folks for their inventory control practices.
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Not sure what type of labeling your bottles have but can you put a small label with the updated ingredients on over the top of the existing label?
You would need to check if overlabeling is acceptable in your country.
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No that wouldn’t work for me because I use aluminum bottles and it wouldn’t look very good. I appreciate the suggestion though, I will just use my old formula for now
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