The label is the first thing the consumer sees when browsing the shelves in the store. It is the most apparent marketing tool and must therefore display all the information as laid down by the Cosmetic Labeling Laws. These laws are clear and specific as to what should appear on the front panel of the label and the accompanying pamphlet.
The Cosmetics Regulatory or the FDA (US Food & Drug Administration) has laid down a list of requirements for cosmetic labelling to protect consumers from fraudulent claims of the contents and contents that may contain ingredients dangerous for use.
The consumer has every expectation that what the label says is true, in every respect and buys the product on that basis, expecting the desired results. Here is an overview of what the label should state. It must be noted up front that it is illegal to have, “Approved by the FDA” anywhere on the label or accompanying document even if it is on the FDA listing. This can be construed as a marketing ploy.
According to the Cosmetics Regulatory, a cosmetic is defined as a product that is used solely for the cleansing or beautifying of the physical body and not one that changes the shape or form or cures diseases or allergies etc. If a product states that it cures acne, it is no longer a cosmetic but a medication.
Both Cosmetic and Medication?
If the product claims to be both, the labelling must comply with both over-the-counter (OTC) drug and cosmetic regulations. The drug ingredients must appear separately to the cosmetic ingredients, both in decreasing order of predominance. These ingredients plus the claims of the efficacy of the product must be on the front label and the accompanying pamphlet.
Any cosmetic that is shipped into or manufactured in the US must be labelled in English. If a foreign language is displayed, English must be present on the front panel as well as the accompanying documents.
The Required Labelling Information – on the Principal Display Panel
The Identity of the product. It must indicate the nature of the product by use of either a descriptive name known to the public or an illustration or graphic that easily identifies the product for what it is and does.
It must display the net quantity in the container, either the numerical amount or weight or liquid capacity or a combination.
The Required Labelling Information – on the Information Panel
Name and address of the manufacturer/packer or distributor with contact details.
Must state material facts for instance it must warn that if the product is not used according to directions it could be unsafe or desired result will not be achieved.
It must clearly display warnings or cautionary statements and or graphics, if a product is flammable, for instance and could be hazardous if used near open flame.
All ingredients must appear clearly in descending order of importance. It must give the color additives and preservatives, the fragrances and chemical additives. ‘Trade Secret’ wording is not allowed as the FDA very seldom gives permission for trade secret ingredients. Full disclosure is encouraged on every product.
If the Cosmetic Labelling Laws are strictly adhered to according to the Cosmetic Regulatory or the FDA, the consumer can purchase the products comfortably assured that what she is buying is what she is getting. If she does not get the promised result, she has recourse to the manufacturer as per the information on the label.