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?
There are two items that MUST go on the front panel of any product that is sold to consumers. Whether the product is a soap or a cosmetic, these items are required:
- Name. Your unique product name; the name that separates your lavender soap from someone else’s lavender soap.
- Identity. What is the product? (soap, lotion, bubble bath, etc).
- Net Quantity of Contents. How much actual product is there? In both US (oz, pounds, pints, etc) AND metric (ml, grams, liters, kilos).
FOR COSMETICS, the name may not include the name of one ingredient if there are two or more ingredients in the product.
FOR SOAP, the identity of the product may not include the name of one ingredient, unless that ingredient is present at a “substantial or significantly effective amount”. See blog post, Using an Ingredient Name in a Product Name for a more detailed discussion.
The Net Quantity of Contents should be in a large enough text size (usually 1/8″ high, measuring the lower case “o”) and be placed parallel to the bottom of the package, in the bottom 30%.
Of course, other marketing type information can also go on the front panel of the package!
What goes on the BACK or SIDE panels?
For all products:
- The name and address of the responsible party.
- Directions for safe use (if applicable)
Additionally, for cosmetics:
- The declaration of ingredients.
- Any required warning statements.
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).
Is SOAP exempted from the label requirements?
No. If it is a “true soap” (made from oil and lye), AND the only claim is that it cleanses AND it is only called “soap,” it is exempted from the FDA cosmetic regulations (but not the basic consumer commodity labeling requirements).
If it is exempted from the FDA cosmetic labeling regulations, an ingredient listing is not required. That doesn’t mean you can’t put an ingredient listing on the package, but it is not required, and isn’t regulated by the FDA rules for cosmetic ingredient declarations. See blog post Ingredient Labels for Soap for more info.
Name and Address:
What is required for the NAME and ADDRESS?
The address must include the full street address, city, state and zip code. IF the name used on the label is listed in a CURRENT phone or city directory (print or online) and the street address is included, the street address may be omitted from the label (but the city, state and zip code are still required).
The FTC updated their regulations for online listings for the street address in 2015 to read (bold type by me for emphasis):
(c) The statement of the place of business shall include the street address, city, state, and zip code; however, the street address may be omitted if it is listed in a readily accessible, widely published, and publicly available resource, including but not limited to a printed directory, electronic database, or Web site.116 CFR 500.5(d)
So if your street address is included in any of those places, then it doesn’t need to be on the label.
The same wording was also adopted by the Uniform Packaging and Labeling Regulations, which have been adopted by most states. While technically it only applies to all non-cosmetic products, including soap that is exempt from the definition of a cosmetic, it seems likely that the FDA would accept it as well.
Can a PO Box be used instead of a physical address?
No. An actual physical address is required.
Can a Mailbox Service (like UPS or Mailboxes Etc) be used?
No. The address needs to be the “place where business is conducted.” Obviously, you aren’t sitting in Kinko’s or the UPS store carrying out your business activities.
How should ingredients be identified (named) in the ingredient declaration?
Easiest way to figure it out is to use the Ingredient Lookup provided by the Handcrafted Soap and Cosmetic Guild. You’ll need to be a registered user (free) to access it.
List general ingredients by name listed in the Cosmetic Ingredient Dictionary EXCEPT botanical ingredients (in the United States).
Botanical ingredients – that is, ingredients from plants – should be listed by their COMMON ENGLISH NAME. The Latin/scientific name can go in parenthesis, if you want. Include the plant part and the form. Examples:
- Lavender flower oil
- Lavender flowers
- Shea nut butter
- Coconut Oil
- Coconut (Cocis Nucifera) Oil
- Hemp Seed Oil
- Hemp (Cannabis Sativa) Seed Oil
In what order should ingredients be listed?
Listing ingredients in descending order of predominance (based on their percentage, by weight, in the product) is always correct.
Alternatively, ingredients may be listed in the following order:
- All ingredients present at more that 1%, in descending order of predominance.
- All ingredients present at 1% or less, listed in any order
- Color additives, regardless of amount.2To be listed this way, the color additives must the approved for use in cosmetics and listed by their correct name.
Blended ingredients used in the product (such as pre-made bases or preservatives) must have their component ingredients listed in the ingredient declaration based on the percentage of use in the entire formula.
Fragrances (whether fragrance oils or essential oils) may be listed as “fragrance” without identifying all the component ingredients in the fragrance blend.
Incidental ingredients, trade secrets, and alternative ingredients have special methods of being listed (or not) in the ingredient declaration. See the FDA website, the labeling regulations or the book Soap and Cosmetic Labeling for details.
Does every essential oil have to be listed?
Well, yes and no.
If you list them individual ingredients, then yes, they do need to be individually listed.
However, if you are using them as a fragrance, you can use the term “fragrance” as an all-inclusive description of the essential oil blend.
You always have the option to explain to the customer (on an informational panel) that you are using only essential oils and/or list them if you want. That’s “marketing,” not an ingredient declaration.
Is “Saponified Oils of ___” acceptable?
No, not for cosmetics and soap that is a cosmetic. The oils and lye (or the saponified result) must be listed.
How should lye be listed?
Use the full chemical name “sodium hydroxide” or “potassium hydroxide.”
What about “Organic”?
You cannot use the Organic symbol unless you are registered with National Organic Program.
You should not use the word “organic” on your front panel. See blog post What About “Organic” Cosmetics for more info.
You can identify organic ingredients in your ingredient declaration with an asterisk (*) and then place a footnote below that those are organic ingredients. Don’t use the word “organic” to describe the ingredients in the actual ingredient declaration. You can also state the percentage of organic ingredients in the product.
What about “naked” soap?
Y0u still need to provide the consumer with the necessary information that would be required on the label. Selling in person, you could put the information in signage and on a card to go with the product. Selling online, put the information in the product description and also provide a card or documentation with the product when it is shipped.
Last updated February 21, 2021