Labeling Helps Consumers Make Informed Choices About Cosmetics
Everyone deserves the right to know what’s in their products. Not only do they have a right to know, they have a right to understand.
Proper labeling is an important aspect of marketing cosmetics and personal care products. Labeling is used to help inform consumers of a product’s intended use and any related warnings, ingredients and net quantity of contents, and place of manufacture or distribution. The U.S. Food and Drug Administration (FDA) regulates cosmetics labeling under the authority of both the Food, Drug, and Cosmetic Act (FD&C Act) and Fair Packaging and Labeling Act (FPLA). These laws, and related regulations, are intended to protect consumers from health hazards and deceptive practices and to help them make informed decisions about the products they purchase. Federal regulations require ingredients to be listed on product labels in descending order of concentration.
For more information about how member companies of the Personal Care Products Council (PCPC) go beyond what is required by law to promote greater transparency and disclosure, visit PCPC’s website.
Before proceeding with a discussion of labeling requirements, it is helpful to understand what key labeling terms mean:
- Labeling: This term refers to all labels and other written, printed or graphic matter on or accompanying a product [FD&C Act, sec. 201(m); 21 U.S.C. 321(m)].
- Principal Display Panel (PDP): This is the part of the label most likely displayed or examined under customary conditions of display for sale [21 CFR 701.10].
- Information Panel: Generally, this term refers to a panel other than the PDP that can accommodate label information where the consumer is likely to see it. The information on this panel must be prominent and conspicuous.
As part of the prohibition against false or misleading information, no cosmetics or personal care products may be labeled or advertised with statements suggesting the FDA has approved the product. This applies even if the manufacturing establishment is registered or the product is on file with FDA’s Voluntary Cosmetic Registration Program (VCRP). All labeling information required by U.S. law or regulation must be in English. The only exception to this rule is for products distributed solely in a U.S. territory where a different language is predominant, such as Puerto Rico. If the label contains any representation in a foreign language, all label information required under the FD&C Act must also appear in that language [21 CFR 701.2(b)].
The following information must appear on the Principal Display Panel:
- An identity statement, indicating the nature and use of the product, by means of either the common or usual name, a descriptive name, a fanciful name understood by the public, or an illustration [21 CFR 701.11].
- An accurate statement of the net quantity of contents, in terms of weight, measure, numerical count, or a combination of numerical count and weight or measure [21 CFR 701.13].
The following information must appear on an Information Panel:
- Distributor statement: If the name and address are not those of the manufacturer, the label must say “Manufactured for…” or “Distributed by…” [21 CFR 701.12].
- Material facts: Failure to reveal material facts is one form of misleading labeling and therefore makes a product misbranded [21 CFR 1.21]. For example, directions for safe use if a product has the potential to be misused.
- Warning and caution statements: These must be prominent and conspicuous. The FD&C Act and related regulations specify warning and caution statements related to specific products [21 CFR part 700]. In addition, cosmetics and personal care products that may be hazardous to consumers must bear appropriate label warnings [21 CFR 740.1]. Flammable cosmetics, such as aerosols, are an example of products that require specific warnings.
- Ingredients: If a product is sold on a retail basis to consumers (even if it is labeled “For professional use only,” or words to that effect), the ingredients must appear on an information panel, in descending order of predominance. [21 CFR 701.3]. If the product is also an over-the-counter (OTC) drug, such as sunscreens, its labeling must comply with FDA regulations for both OTC drugs and cosmetics and personal care product labeling.
For more information:
- Knowing Your Product’s Ingredients, an infographic about ingredients and labeling
- Reading the Label of Your Favorite Beauty Product, a blog post from PCPC Chief Scientist, Alexandra Kowcz
- Sunscreens: How to Read a Label, Expert Tips, etc.