Quick Labeling FAQ

[Last updated 18 Mar 2024] Here’s a quick overview of what goes on the label of a soap or cosmetic products and answers to the questions that frequently come up.

Cosmetics and non-cosmetic products have the same BASIC labeling requirements, but there are some differences. See Cosmetics vs Non-Cosmetics Requirements. In the US, soap can be either a cosmetic or a non-cosmetic products. See Soap: Cosmetic or Not? and Melt & Pour Soap: Soap or Cosmetic?

What is REQUIRED on the FRONT Panel?

  1. Name. Your unique product name; the name that separates your lavender soap from someone else’s lavender soap.
  2. Identity. What is the product? (soap, lotion, bubble bath, etc.).
  3. Net Quantity of Contents. How much actual product is there? In both US (oz, pounds, pints, etc.) AND metric (ml, grams, liters, kilos).

Are there limitations on the NAME of the product?
Are there limitations on the IDENTITY of the product?
How do the NET CONTENTS need to be stated?
How big does the net contents statement need to be?
How is the size of the net contents measured?
Where should be net contents be placed?
Are there any other requirements for the net contents?
Can anything else go on the front?
Is there anything that CAN’T go on the front?

What is REQUIRED on the BACK or SIDE Panels?

For all products:

  • The business name and address of the responsible person.

For cosmetic products:

  • Ingredient declaration
  • Directions for safe use (if applicable)
  • Any FDA required warning statements

Whose BUSINESS NAME goes on the label?
What BUSINESS NAME must go on the label?
What ADDRESS must go on the label?
Is the actual street address required?
What about using a PO Box or mailing service that has a street address?
Is there a text size requirement for the business name and address?
What order should the ingredients be listed in?
How should the ingredients be named?
In the US, How should botanical ingredients be named?
Is “saponified oils of …” or “saponified …” acceptable?
Are there special rules for color additives?
What about blended ingredients?
How should infusions, extracts, or teas be listed in the ingredient declaration?
Is there any time an ingredient may be omitted from the ingredient declaration?
What about fragrances?
Is there a minimum text size for the ingredient declaration
What about organic ingredients?
Can descriptions be included in the ingredient declaration?
What about fragrance allergens?
Are directions always required?
What sorts of things should be included in the directions?
What products REQUIRE warning labels?
Where should the warning statement be placed?
Are there text size or other requirements for a warning statement?

Again, you can use the side and back panels for additional marketing text touting the wonderfulness of your products and why a consumer should buy them.  Remember not to use any claims that could be construed as “drug” claims (see blog posts FDA Cracking Down on Cosmetic Product Claims and More on Product Claims for more info).

What other information is ALLOWED on the label?

Your package can include any type of additional marketing text touting the wonderfulness of your product and why a consumer should buy it! You can include pictures and graphic design. You can also include:

  • Website address
  • Email
  • Phone number
  • Social media addresses (or QR code)
  • Batch number
  • Best-if-used-by date
  • Use-within-opening time
  • Bar code

Other information can be included on the label, but this type of information also come with some regulatory requirements and/or limitations:

  • Claims to treat or prevent disease or claims that the product will alter the function or structure of the body. See What is a DRUG?
  • “Recycle” statements or logos
  • Environmental “Green” claims
  • “Free-Of” statements
  • “Made in the USA” (or Made in a US state). See: Made in the USA and Made in “My State” Claims.

If you have a question that isn’t answered here, please feel free to email me. This information (and much more!) is contained in my Soap & Cosmetic Labeling and Navigating the Rules & Regs books.

Soap and Cosmetic Labeling cover

To really be able to create your own labels that comply with the regulations, get my book from Amazon and use it.

  1. 21 USC 364h. Small Business. ↩︎
  2. In 2019, the Handcrafted Soap and Cosmetic Guild (HSCG) filed a Citizen Petition with the FDA to update their regulations regarding the street address to match the wording for non-cosmetic products. No answer or action has been taken on it as yet. ↩︎