In this Monday Mailbag we have questions concerning the size of the net weight wording, getting started with GMP, handling incidental ingredients, INCI names and website software.
What are the size requirements for the net weight?
The size of the text for the net weight is dependent upon the size of the principal display panel. If the PDP is less than 5 square inches, height of the net contents must be at least 1/16”. If the PDP is 5 – 25 square inches, the net contents must be at least 1/8” high.
For most cosmetics and soaps, the PDP will be between 5 and 25 so the text of the net contents should be 1/8” high. If the text is in lower case or upper and lower case (i.e. “fl. Oz.” or “Fl. Oz.”), the height is measured by the height of a lowercase “o”. If the text is in only uppercase, it is measured by the height of the uppercase “L”.
In addition, the text should be separated above and below by the space of an upper case “N” and on the sides by the width of three upper case “N’s”, as you can see in the image above.
I have your book on GMP, but I am not really sure where to start. What do you suggest?
There are a couple of suggestions on how to start in the book (Chapter 23).
Since I wrote the book, and in talking to lots of people, I am now suggesting that maybe the best way to start is with the place(s) where there is the highest possibility of errors that could drastically affect your finished product. In most cases, that means:
- Master formulas written and used
- Batch records written and used
- Batch numbers recorded on each product
- Incoming ingredients assigned unique lot numbers
- Ingredient lot numbers tracked in batch records
I’ve heard that there are some incidental ingredients that don’t need to be put in the ingredient declaration. Is that true?
There are circumstances in which certain materials that don’t need to be listed in the ingredient list because they are “incidental ingredients” (which are defined in the regulations).
The first type of incidental ingredients are added because they were in an ingredient that waasdded to the product, AND they have no technical or functional effect in the cosmetic. For example, preservatives that have been added to a liquid color additive. It’s enough to protect the liquid color, but wouldn’t have any functional effect in the cosmetic you are making (too little preservative to be effective).
The second type of incidental ingredients are processing aids, which break down into three types:
- Substances that are added to a cosmetic during the processing, but are removed from the cosmetic before it is packaged in its finished form. Most handcrafters don’t go through a process of removing things from the cosmetic mix. An example from food is putting egg white in a broth base to clarify it – the egg whites are removed before the broth is eaten.
- Substances that are added to a cosmetic during processing for their technical or functional effect in the processing, are converted to substances the same as constituents of declared ingredients, and do not significantly increase the concentration of those constituents. Again, an example from food; putting flour in biscuit gravy to thicken it, when there is already flour in the biscuits.
- Substances that are added to a cosmetic during the processing of such cosmetic for their technical and functional effect in the processing but are present in the finished cosmetic at insignificant levels and do not have any technical or functional effect in that cosmetic. For example, using a small amount of alcohol to dilute a resin; the alcohol in the finished product is very slight and it has no functional or technical effect in the finished product.
It’s my opinion that the cosmetic formulas used by most handcrafters are unlikely to have incidental ingredients that fall under the category of “processing aids”.
It’s also come to my attention that there are a few ingredient manufacturers that have stretched the definition of “incidental ingredient” – so when you purchase an an item from a supplier, make sure you are comfortable with the ingredient information provided to you.
Some of my suppliers provide the INCI name of botanicals as the Latin name. If that’s what I get from the supplier, do I use it in the ingredient list?
In accordance with the current edition of the Cosmetic Ingredient Dictionary, the INCI name for botanicals is the Latin binomial name. Suppliers often choose to use that name to describe their botanical ingredients as it is more exact than the common name.
However, regardless of what information you receive from your supplier, the FDA wants and requires the common name in the ingredient declaration on your product.
Your website seems pretty easy to navigate and use. What program do you use?
The main part of my website is powered by the Joomla! content management system and my blog is powered by WordPress. Both use Yootheme mobile responsive templates that have been slightly modified. In both Joomla! And WordPress I have various plug-ins and extensions to help display the information.
While I know how to program all this stuff, it just seemed easier in my case to use existing platforms. My daughter actually implemented the new design and converted my content to Joomla and WordPress for me. (If you’re interested in getting some work done on your website, she might be interested – email me and I’ll pass it on.)