Quick Labeling FAQ

Here are some of the basics of labeling and the questions that frequently come up about the basic labeling.

What goes 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).

Cosmetics and non-cosmetic products have the same BASIC labeling requirements, but there are some differences. See Cosmetics vs Non-Cosmetics Requirements

Of course, other marketing type information can also go on the front panel of the package!

Are their limitations on the NAME of the product?

Are their limitations on the IDENTITY of the product?

What are the requirements for the statement of net contents?

What goes on the BACK or SIDE panels?

For all products:

  1. The business name and address of the responsible party.
  2. Directions for safe use (if applicable)
  3. The declaration of ingredients (Cosmetics only)
  4. Any required warning statements (Cosmetics only)

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).

1. Business Name and Address

The address must include the full street address, city, state and zip code of the place where the product is manufactured OR the place where business is conducted (records kept, business decisions made, etc.)

Can the street address be omitted?

Can a PO Box be used instead of a physical address?

Can the street address of a mailbox service be used?

2. Directions for Safe Use

If there is something the consumer should know in order to use the product safely, that needs to be included on the label.

Are directions always required?

What sort of thing should be included in the directions?

3. Ingredient Declaration

An ingredient declaration is required for all cosmetic products. Ingredients are not required on soap that is not a cosmetic or on other non-cosmetic products.

Must all the ingredients go in the declaration?

What order should the ingredients be placed in?

How should blended ingredients be listed?

How are infusions, extracts, or teas listed?

How are fragrances listed?

Is an ingredient declaration required on soap?

Should the INCI name be used?

Is “Saponified Oils of ___” acceptable?

How should lye be listed?

4. Warning Statements

Warning statements are required on:

  • Bubble bath
  • Feminine deodorant products (including some yoni products)
  • Suntanning preparations that do not contain sunscreen
  • Products containing alpha or beta hydroxy acids

Other Frequently Asked Questions

Is SOAP exempted from the label requirements?

What about organic products

What about “naked” soap?

Other questions?

If you have a question that isn’t answered here, please feel free to email me.This information (and more) is contained in Soap & Cosmetic Labeling and Navigating the Rules & Regs books.
Last updated June 14, 2022

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1 16 CFR 500.5(d)