Once upon a time, I worked freelance as a graphic designer, and my first introduction to cosmetic labeling was actually a client instead of my own company. While this gave me a heads-up on understanding the regulations early, it didn’t stop me from making the same labeling mistakes over and over.
Luckily, it was easy for me to fix these issues since I did all of my design and printing in-house. However, if you aren’t handling your own design or are planning on a run of professional printing, a label mistake could be a huge costly mistake, wasting a nice chunk of money on designer or printer fees.
I wanted to share the top labeling mistakes I commonly made as a soap & cosmetic manufacturer in the United States. These labeling mistakes are in tune with current FDA regulations for cosmetic labeling (see Mistake #2 for details about whether or not your soap qualifies!) as of May 2015. Though regulations haven’t changed in a long time, they may or may not change with future legislation.
Ready to dive in? Here we go!
Labeling Mistake #1: Using an ingredient name in the product name.
According to the cosmetic labeling regulations, a product is misbranded if the product name includes a reference to a single ingredient but not all the ingredients in the product. While Passion and Clarify don’t include references to ingredients, the line that follows up below the name of the product does reference specific ingredients and can be interpreted as misbranding.
Labeling Mistake #2: Thinking an ingredient listing is required when it’s not. Or vice versa.
When it comes to soap, the lines get a little blurry. If you are making (and marketing) soap as defined by the FDA, you don’t actually need an ingredients list. However, most soapmakers do make cosmetic claims, so a proper list of ingredients is required.
The biggest point of confusion here? I’ve heard some peeps say that if you add an ingredient listing (and change nothing else about your labels or marketing), your soap now becomes a cosmetic…
Whether you choose to list ingredients or not does not change if the product is primarily alkali salts of fatty acids (aka soap) and if the cleaning action of the product is provided by the soap itself. Now if you toss on the label (or your website description or other marketing materials) that it’ll make you smell nice or keep your skin moisturized, then yes, it’s a cosmetic.
Side note: I always chose to label as a cosmetic for consistency and ease between my soap and other products. It’s up to you on what you decide to do.
Labeling Mistake #3: Using the statement “(and)” in an ingredient listing.
When you use a multi-part emulsifier or a cosmetics base, the ingredients list is usually chock full of (and)s, and that doesn’t belong on your labels. When you use a multi-part ingredient, you need to figure out the predominance of those ingredients with the rest of the ingredients in the product to comply with proper labeling.
Labeling Mistake #4: Using the incorrect type size or measuring it incorrectly.
As a graphic designer, I was taught to measure type size by the lowercase ‘x’ on print materials, however, this doesn’t work for cosmetic labeling!
To measure the type size correctly, you should be physically measuring the printed uppercase ‘L’ or the lowercase ‘o’ on your labels. Different areas of the label require different measurements for type size, and it’s important to consult the regulations to find out if you are in compliance.
Labeling Mistake #5: Forgetting to make the net weight “bold” or placing it in the
One word has caused a world of confusion for makers when it comes to net weight. When the regulations were written, boldface type didn’t necessarily mean the thickest, darkest font in a typeface. It just meant conspicuous, solid, and easy to read. So, this is not the place for thin, condensed, script, or ornate fonts. And you don’t have to use bold-styled type, but you can. (Thanks, Marie Gale for helping to clear that up!)
So, the net weight or contents of your product must be “bold” and located on the bottom third of the principal display panel (PDP) of the product (unless the PDP is less than five square inches.) It also has a defined type size depending on the size of the PDP, remember to measure by the uppercase ‘L’ or lowercase ‘o’!
Labeling Mistake #6: Listing “mica” by itself as an ingredient when cosmetic micas are used to color the product.
A few years ago, using cosmetic micas as a colorant became super popular in soapmaking. And if you plan on marketing your soap as a cosmetic (which means following cosmetic labeling regulations), then you need that mica in your ingredient list.
But surprise! What you and I refer to as mica isn’t just mica; it’s a mica-based pigment. Mica itself is a colorless mineral substance that is then coated with pigments or U.S. Food, Drug, & Cosmetic colors (FD&C colors) to create cosmetic-grade micas.
In order to comply with the ingredient labeling regulations, all those parts and pieces have gotta be listed. For example, Bramble Berry’s Aqua Pearl Mica would be listed as: Mica, Titanium Dioxide, Chromium Hydroxide.
Labeling Mistake #7: Leaving off the required contact information.
The contact information for the company responsible for the product must be on packaging for cosmetics. If it isn’t the manufacturer’s product (as in a private label agreement), then it should state “Manufactured for” or “Distributed by” or likewise.
The contact information that is required gets a little hairy for those of us who manufacture in our homes by requiring the street address, city, state, and zip code.
The good news is that the street address may be omitted (leaving only the city, state, and zip on the product label) if the business is currently listed in a city directory or telephone directory (either online or in print!) Adding additional contact information, like a phone number or email address, is not mandatory, but it’s a good idea if you ask me. 😉
Are these labeling rules news to you? Hit up the FDA’s website to read up or snag a copy of Marie Gale’s Soap & Cosmetic Labeling book that makes it super easy to decipher the regulations and implement proper labeling on your products. Need more help? Take a seat in the Labeling & Marketing Soap vs. Cosmetics workshop!
Do you make these mistakes, too? Or do you have any other common labeling mistakes you’ve seen that you want to share? Hit up the comments and let me know!