Want to Build Your Own Successful soap Biz?

The Cosmetic Labeling Mistakes I Always Made (Are You Making Them, Too?)

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.

Feminine Face & Body Soap Duo from the now defunct Amathia Soapworks
Feminine Face & Body Soap Duo from the now defunct Amathia Soapworks which shows some common labeling mistakes!

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
wrong area.

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’!

A beautiful purple cosmetic mica being used in soapmaking.
A beautiful purple cosmetic mica being used in soapmaking.

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!

Share this post

Share on pinterest
Share on facebook
Share on reddit
Share on twitter
Share on linkedin
Share on print
Share on email

Remember to keep it clean (oh, so punny). We moderate comments for keyboard warriors and spam, read our comment policy for more information. If you need a little extra TLC, please reach out so we can best serve you!

74 Responses

  1. Hi there, thanks for sharing. If labeling as a cosmetic, doesn’t that require you to get FDA approval and\or open you up to inspections, etc?

    1. Hi Nic,

      No, cosmetics do not currently need approval. You *should* be following GMP, but they are not required by law and yes, you *could* have an FDA rep wanting to inspect your facility. As it stands right now, the FDA is highly understaffed for the amount of regulatory action necessary to fully enforce the regulations – which is hugely unfortunate, IMO.

      Kenna

    1. It’s important to remember that if you sell soap (as determined by the FDA), you do not need to follow the cosmetic labeling regulations. However, that product does appear to imply medical claims which pushes it into drug territory, not just cosmetics.

      It happens a lot, unfortunately.

      1. Thank you so much for all the information you provide to us soapmakers. You are always so generous. #1 mistake really confuses me, too. So, if I make no medical or cosmetic claims it is ok to put “lavender” in the name of my lavender soap? In fact, I make no claims at all regarding my soap. It’s just soap. It is difficult to wrap my head around some of this. I only sell to friends and family but I still want to be compliant with the regulations. I guess I need to read Marie Gale’s book instead of just letting it sit on my bookshelf!

  2. Would it be possible to showcase a photo of labeling that’s properly done for those of us home soapmakers that are just starting out trying to figure out the correct way to do it?

    1. I looked for one before I published this, and unfortunately, most of my photos are on an external harddrive that is in storage right now. Maybe someone can pipe up with a link to their own products with proper labeling. 😉

  3. Super interesting – thanks for posting! I totally hear you on the bolding Net Wt. Ahh! Gets me every time!

    The one I hadn’t heard of before is actually #1, and I’m having trouble finding the FDA rule about it. Can you point me in the right direction?

    It leads me to wonder if you scent with essential oils and label your soap “Lavender Soap”, for example, if that is considered mis-branded under this rule since your ingredients would contain Lavender Essential Oil. Is it only considered mis-branding if you do not also list the full ingredients on the information panel?

    1. Sure Laura, it’s right over here: http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&sid=2840d521290f433ef8e5afed3f64c86f&rgn=div8&view=text&node=21:7.0.1.2.11.1.1.1&idno=21 (Title 21, §701.1)

      To quote the regulations directly: “The labeling of a cosmetic which contains two or more ingredients may be misleading by reason (among other reasons) of the designation of such cosmetic in such labeling by a name which includes or suggests the name of one or more but not all such ingredients, even though the names of all such ingredients are stated elsewhere in the labeling.”

      1. Thanks for this post! I don’t think i would ever have come across that particular regulation on my own! (#1)
        I went through my shop and took a look at each of my soaps. Most are named by what inspired them, and a few by their scents. Are the ones named by scent ok the way they are. My Simply Lavender soap definitely has lavender in it…..lavender buds and essential oil. But if that were the only ingredient, it wouldn’t be a soap……And even if the name Lavender Soap would do it, i wouldn’t be acknowledging the alkanet root powder….Am i understanding this correctly? So would i be able to use the name on the basis that it is the scent of the soap? Is there an exception for that?

        1. Did you get an answer to this Shadedily? I am only beginning to gather supplies. I want to sell soap as soap. But, I am seeing so much conflicting info. I am unsure if the powers overseeing “just soap” require a label. And also this thing comes up about ..certification of scales….?????….Kenna, or anyone? Can you tell me what that involves? Thanks!

        2. I was just reading about this on Marie Gale’s site too. You can’t name the product Oatmeal, Milk, and Honey since it indicates there is oatmeal, milk and honey in the product. I’ve found all my soap is named after the FO I use, Pumpkin Spice, Honey Ale, etc. I think coming up with different names to be hard. I see soap being sold all the time with these types of names. It’s confusing!

  4. This has been very informative, I’ve been thinking of starting a soap making side business as I already do some bath products for myself and family, and I’m glad to have come across this info before I got started and potentially in trouble.

    1. Happy to help, Nicole. It’s important to remember that these rules apply for cosmetics – which soap only falls under if you aren’t making true soap OR if you market it as a cosmetic (making claims about moisturizing, smelling good, etc.) Good luck on your journey! 🙂

  5. This is all so detailed and tricky. I have searched for designers to help with labels but have been unable to find one with cosmetic labeling experience. Can you recommend any? Thanks!

    1. It is so detailed and tricky, Aileen! I am working on compiling a list of designers for another blog post, they are certainly far and few in between. 🙂

  6. Thanks for the blog post on this!
    Number 4 is the tricky one for me. I have Marie’s book (which I strongly recommend) and I had a hard time wrapping my head around measuring the type as well as knowing where to put things on the PDP. Based on what you wrote, I should print out a lower case “o” and upper case “L” and literally measure them? If so, how do I go about making sure the other letters are sized properly?

    1. Yes, Tara. 🙂 The font and size is acceptable when the “o” and “L” meet the specific measurements necessary.

      Directly from the FDA’s Labeling Guide:

      “Type Size
      Ingredients: 1/16″, 1/32″ (Labeling surface, less than 12 sq. in.)

      Net Contents:

      1/16″ (PDP less than 5 sq. in.)

      1/8″ (PDP 5-25 sq. in.)

      3/16″ (PDP 25-100 sq. in.)

      Warning: 1/16″

      All Others: Reasonably related to panel size

      21 CFR 701.2(a) (b), 701.3(b),
      701.11(c), 701.13(i), 740.2(b)

      Ingredient Declaration: Generally, in letters not less than 1/16″ in height [21 CFR 701.3(b)]. If surface area available to bear label (excludes surfaces with decorative relief, sculptured surfaces) is less than 12 square inches, letter height may be not less than 1/32” [21 CFR 701.3(p)].
      Net Contents Declaration on PDP: Minimum letter height determined by the area of the PDP. In the case of “boudoir-type” containers, including decorative cosmetic containers of the cartridge, pill box, compact or pencil type, and cosmetics of 1/4 oz. or less capacity, the type size is determined by the total dimensions of the container. If the container is mounted on a display card, the display panel determines the letter height [21 CFR 701.13(e) and (i)].

      Warning Statements: Type size no less than 1/16″ unless smaller size established by regulation [21 CFR 740.2].

      Letter Height: The lower case letter “o” or equivalent when upper and lower case letters are used [21 CFR 701.13(h)].”

      http://www.fda.gov/Cosmetics/Labeling/Regulations/ucm126444.htm#clgg

      1. Hi Kenna, on net contents font size, if upper and lower case lettering is used, is FDA asking to measure the uppercase Letters? I’m a bit confused, a physically measured upper case is naturally higher than lowercase… 🙂 thanks!

  7. What I’d love to see someone do a post somewhere that includes a front and back images of a soap label depicting these common labeling mistakes, and then a front and back image of the same label that has been corrected; a before and after post. It’s so confusing trying to interpret legislative language; esp when it includes the word “may;” [“The labeling of a cosmetic which contains two or more ingredients may be misleading by reason…] I guess I’m just a more visual learner. LOL

    1. I’ll see if I can get something like that together, Beryl. 🙂 In the meantime, check out Marie’s book – it has tons of illustrations and examples that makes it easier for a visual learner. 🙂

  8. Great post Kenna,

    I only make products for pets and adhere to the “it’s only soap” ideals. However I have always labeled mine as if it were a cosmetic marketed for people. Keeps me ahead of the regulatory curve.

    1. Assuming sugar is an ingredient in the scrub and there are other ingredients in the product (oils, fragrance, etc.), then yes, this would likely fall under misbranding.

    2. I am in the process of making sugar scrub, too. I had sugar scrub on my PDP… I guess I have to take it off? Did you have to rename as well??

  9. Oh well I as well as 100% of the soap makers I know have a OMH (Oatmeal Milk and Honey) soap. It is a right of passage soap! Guess it’s time for a name change to keep up with the times!

    I have used “and cocoa butter with premium fragrance” and not bolded the net wt!

    Great article thank you Kenna.

  10. I’m just getting to the point to where I’m about to open my online shop, so this article was packed with great info and was a real eye opener for me. Is there a sample anywhere of what a correct label and ingredients list looks like? I am about to have a peep son design my labels and cards but I want to make sure that the meet all requirements even if I’m just a very small online shop. I also plan on getting the book you mentioned in your article. But a sample of how to correctly label and list ingredients would help me visualize and understand all of this even more.
    I had even seen soaps in the all natural/organic isles at several of the stores here in our town and the soaps were not labeled correctly nor did they have any ingredients listed on them at all! I’m not sure how these stores are allowing these to slip by if the regulations clearly state that they need the correct labels and ingredients. They didn’t even have their shop info on them. Just wrapped in plastic and in a box with the supposed scent and a bar code on the back! How that’s legal is beyond me!
    There were also soaps with just cigar bands as a wrap for them. To me, that’s unsanitary and I refuse to buy anything especially soap that could have been handled by anyone and everyone! Even though I’m just an online shop, my soaps will be sealed and labeled. I want my customers to know that they are getting quality products and do not have to worry if the soaps or other products that I make has been contaminated by anything. It can seriously hurt a business and especially if you are just a two person small business.
    If you do have a link to examples of the correct labeling and how to correctly list ingredients, that would be super incredible!
    Great article and it was perfect timing for me!!!

    1. Hi James!

      Marie Gale’s book is a fabulous resource and has a ton of examples and illustrations to help you perfect your labels. 🙂

      As a side note on the sanitary issues with non-airtight packaging on cold process soap, the pH level of the surface of true soap isn’t very friendly to bacteria and the mechanical action of using soap when you wash your hands is what dislodges dirt and germs. I completely agree that customers likely prefer fully enclosed packaging on soaps to ease their concerns, even if they aren’t exactly scientifically valid. 😉

      Thank you for reading! 🙂

      1. Lol…I am on the other side. , though I understand why some would not. I want to sell naked soaps…as soap.. I want to include an insert …about 1/3 or 1/4 the size of printer paper in a bag, with ingredients, cautions, or warnings .( also unsure how to include those) and my contact info. I would like to stamp my soap with my dba name. The insert would be much larger than necessary, but cover the bases. Is that a bad idea?I am still unsure as to the regulations covering soap. Certification scales, ….also if I include a cappuccino powder mix in my soap….I label each and every ingredient? Or if it is sold as soap would it be necessary..lots of questions….sorry…

      2. I am just starting to sell some of my hot and cold-processed soaps, and we do put all of them in bags. I know of at least one person who is horribly allergic to almond oil. I would hate to have someone looking through the soaps, and find out only after holding the soap, that they are allergic to an ingredient in it, or worse, not have any ingredients listed and find out after using it several times that they have allergies to it. I would personally prefer to be totally up front about all ingredients and keep everything sealed so no one has to suffer.

  11. Very interesting post indeed. I make and sell “true” cold-processed soap to the public through my website and in-person shows.

    In addition, I wholesale to a major natural foods chain and they don’t seem to follow these guidelines when accepting products in their bar soap arena. In fact, they even carry soap with NO label at all! Both which are privately produced for them as well as by large and small businesses. They sell some of the soaps in standard bar form as well as cut/weigh ala carte.

    My labeled ingredients are done with easy to understand names in order of predominance and not with the chemical names. I do list the weight and contact info and generally do not make any cosmetic claims as such. I keep an eye out on all my competitors in this space and very few small manufacturers do. I personally prefer to be able to read and know what the ingredients are on the package. I think most people do rather than measuring font size and names that no one can pronounce. Again, I make true soap and so far, my wholesale people haven’t complained. Of, cause, if they did – I’d consider changes!

    1. Hi Rhonda!

      It’s not the retailers job to police regulations and ensure companies are labeling properly, this is the FDA’s job and our job as a largely self-regulated industry to follow the rules. 🙂 Imagine all the different types of products a store can carry, and how many different sets of regulations they would have to know to be able to make decisions based on regulatory compliance! 😉

      I completely understand your preferences for labeling as true soap, as it is certainly easier! One side note is that common botanical names (and not just Latin names) are acceptable for botanical ingredients on cosmetics – for example, Olive Oil.

      Thanks for following along!

  12. When I was researching for the 3rd Edition of my book, I found the Federal Register for Friday, June 28, 1968, when the FDA put through the final regulations for the labeling. They did receive an objection to the “bold” requirement for the net contents, and they clarified by saying “The term bold face type relates to conspicuousness of type rather than style”.

    That’s since been interpreted to mean that it doesn’t have to be the “bold” version of the font, it just needs to be sufficiently solid that it meets the “conspicuousness” requirement. So a light airy font with thin lines might not cut it, but a relatively solid font, even in the “regular” or “normal” weight, should be sufficient.

    1. Thank you for the clarification, Marie! I would assume normal font weight on Garamond or Times New Roman would work, but a lot of sans-serif fonts would be too thin. Wouldn’t it be nice to have better specifications like a measurement to go by? Lol!

      Super appreciate your work in making the regulations easier to understand for those in our industry!

  13. I totally don’t understand #4. 🙂
    My labels are Avery 2×2 labels and everything fits nicely on it. I shrink wrap the soaps and stick the label on one side, so you can see the design around it and on the back. I include company name and phone number, but not the address, since it’s my house. I also did just write mica, and not the whole thing- I guess I’ll have to change that. Everything else I put in order of percentages- from high to low. I also did use ingredient in a name in just few of my soaps, like Tea Tree and Mint for example.
    For weight, I wrote Aprox. Net Weight and then blank, so I can manually write correct weight before selling. I’m not sure about that though. They are usually hand cut, so there’s diferences in weight. Is that the right way to do it? Or should I just weigh them all after curing, and enter the weight of the lightest bar for all of them? For example, my bars range from 4.5-5 oz, so should I just label them all as 4.5 oz? Thanks!

    1. Hi Martina!

      Your type size depends on the principal display panel size (in your case that would be your label.) A 2″ square label would have 4 square inches of space. I posted the type size guides further up in the comment thread as well as a link to a guide. 😉

      For soap, you should label your net weight as the lowest possible weight it could weigh – which would be the total weight of your formula WITHOUT water. As you know, your bars get lighter during cure because the water evaporates. This continues to happen over time, and the best way to ensure your stated net weight is always less than the actual weight is to calculate your individual bar weight without water.

      Hope that helps!

      1. Wait, are you saying that 100% off water evaporates out of the soap??
        I always thought that some does, but certainly not all. I list water as, usually, first or second ingredient, because I list everything in order of high to low percentage.
        So it seems to me that that way would be correct only if whole 100% of water evaporates. But that weight would not be correct if it doesn’t. In that case, I still think it’s correct to enter lowest weight at the end of cure. And that’s why I put approximately on it too. 🙂

  14. Just to clarify, avoiding ingredients on package labels doesn’t prohibit their use in website descriptions. Right? For example, Etsy has input boxes for a limited number of ingredients. If my soap product has more ingredients than the listing’s available input boxes, is there any problem inputting the ingredients that will fit? I say not, but I also didn’t realize how complicated label requirements were even for soap.

  15. I only market my soap as soap. If I wrap my soap for a market can I just do a front planel with name of the soap, my business name address and weight on the PDP?

    Also, if someone at the market ask me about the ingredients do I ask what they are trying to avoid or just tell.them all the ingredients. Would that mean I need a listing somewhere?

    I also have problems with naming my soaps without listing an ingredient and so many I see do just that. It is frustrating.

    Thank you.

  16. So, if you cannot call your sugar scrub a sugar scrub, what can you call it? If I have Handmade Soap in large letters on my label and down lower I call it something like “Lavender Fields” – that is wrong? What would I call it so the customer knows it is a lavender scented soap?

    1. My thoughts exactly, Anita. As a customer, I would want to know what scent or perhaps what exfollients are in the soap. And I can easily see that at a glance by the name of the soap if it’s included there. Common sense, eh?

      Oh, why does this have to be so difficult?

  17. This was actually pretty helpful. Maybe a tad confusing at 345am, but really shows how careful we should be when labeling our products. Thanks!

  18. Came across this today-thank you! Trying to decide if new private labeling requests are right for our company, or just remain wholesaling with our own branding…. it’s my understanding at present the origin of manufacture must still be on the soaps…

  19. I handcraft Sugar scrubs and call them as such on the front label. I can’t imagine what else to call them so that people know what they are buying , this makes no sense!!
    I want to truly understand this in the simplest terms for me and others who have asked similar questions
    1- Can “Citrus Breeze Hand & Body Sugar Scrub ” be listed on the front
    or must I write Summer Breeze Hand and Body Scrub
    2 -Can I name a scrub by its initials of the contents like TlC and then below write what the initials stand for? or must I only do that on the back in the ingrediants list?
    3.Lastly what about the fact that my company Name States Sugar in its title ? any issue there?
    And I originaly came on here to ask because I’ve seen it done, can I refer to my website for an ingrediant list if the label is to small? A 1oz container and the label is super small for all the info needed, I do not supply a box thus no other place to put the info
    Alot of questions, I know, But I hope you will answer each one.
    Thank you for the insight and your time!

    1. Hi, I am considering selling sugar body scrubs as well, is it considered a soap or a cosmetic? It seems the laws are a lot more lenient on soap. I would appreciate your reply, thank you!

  20. Hi Kenna,
    Thank you for the great blog !
    You say “The good news is that the street address may be omitted if the business is currently listed in a city directory, telephone directory (either online or in print!) “. I just wonder how we can make the business listed on those directory? Is it automatically listed there after we register the business to the local government? Please give me some idea.

  21. So if I sell a shaving soap, it’s lemon scented, and I want to name it “LEMON Shave Soap”. Would this violate FDA regulations? Please note, I want this soap to be considered a cosmetic product not a soap.

  22. Hi Kenna,
    You really are an authority when it comes to soap. I have been following you since you came out with a bunch of rainbow tutorial like three or five year ago, I can’t remember exactly the number of years, I was living in Luxembourg with my family. By the time I had found your blog/website/Facebook page etc.. I was starting to discover the soap world and I wishing I could nerd it out the way you do! Years later I’m living in New York, in the middle of a business plan to launch my soap company, and I’ll get back to you very soon because woman if you can’t help, nobody can’t! I’ll check out your schedule to make an appointment with you.
    In the mean time, thanks for being so generous with the amount of information that you gives for free, my respect.

  23. I just think this very fun hobby is just to complicated to try and sell! I think selling off my inventory and doing something easier is what I should do!

    1. There is a lot of pressure to make soapmaking a biz, but it is A-OK to have it be a hobby you love instead! Successful soapmaking businesses are only about 20% about making soap. The rest is financials, marketing, planning, sales. That is not for everyone.

  24. Hi , thanks for this article. Do you know if ingredients need to be listed on the product itself? e.g. lipbalm — or can they be listed on a quarter card that comes with the product?

    thanks!

    1. Brigitte,
      Assuming you are in the United States, you will want to take a look at the FDA regs regarding ingredient listings to see what is mandated for your product.

      For example:
      21 CFR 701.3(b) and (p)

      The ingredient declaration may appear on any information panel of the package which is the outer container in form of a folding carton, box, wrapper etc. if the immediate container is so packaged, or which is the jar, bottle, box etc. if the immediate container is not packaged in an outer container. It may also appear on a tag, tape or card firmly affixed to a decorative or small size container.

      21 CFR 701.3(i)

      The declaration of ingredients in labeling accompanying a cosmetic, i.e., off-package ingredient labeling, requires that:

      (1)The product is not enclosed in an outer container,

      (2)The total package surface area is less than 12 square inches, and

      (3)The products are held for sale in tightly compartmented trays or racks.

      The ingredient declaration must be in letters not less than 1/16 of an inch in height and may appear on padded sheets, leaflets or similar labeling accompanying the product.

      Products which are not eye or facial make-up cosmetics or nail enamels must be displayed for sale in tightly compartmented trays or racks of a display unit. The holder of the padded sheets or leaflets bearing the ingredient declaration(s) must be attached to the display unit.

      Products which are eye or facial make-up cosmetics or nail enamels may be held for sale in tightly compartmented trays or racks located below the sales counter. The holder of the ingredient labeling must be attached to a display chart which bears samples of the product shades and is displayed to purchasers.

  25. Can I put made in the US or made in California for my soaps if some ingredients came from foreign sources?

  26. Good afternoon,
    if I am doing sugar scrubs,
    Do I need add a ingredients list at the back of the jar?

    Many thanks.

    1. If you are in the United States (and many other locations), scrubs are a cosmetic and need to be labeled according to cosmetic regulations linked in the article. And that includes ingredients (although not necessarily on the back). Hope that helps, Querida.

  27. Hi! I make scrub cubes with a melt and pour soap base adding salt/sugar and micas. In an ingredient list I would need to add all the melt and pour ingredients, correct? I’m at a loss on the labels for these. Thanks!

  28. I just think this very fun hobby is just to complicated to try and sell! I think selling off my inventory and doing something easier is what I should do!
    ok

  29. I agree with you…this makes no sense to me! Major brands sell and label sugar scrubs as such. Here is a link to one by Neutrogena (link removed due to comment policy) (see the 2nd image). Does this mean Neutrogena is misbranding here??

Leave a Reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.