Introduction
Cosmetic labels are a great way to showcase your creativity, they are very important as a label represents your brand and is the first thing a consumer sees. So whilst it is important to make your label stand out and get as creative as possible. It is in fact more important to ensure that your labels are meeting the correct compliancy standards for your region. The EU cosmetic compliance standards are one of the highest and most rigorous in the world. Even if you do not plan to sell your products in EU markets, I still recommend following these standards for best practice.
1) List INCI names of all ingredients
INCI names (International Nomenclature Cosmetic Ingredient) are systematic names internationally recognised to identify cosmetic ingredients (Personal Care Council, 2018). INCI names are an important as they allow us to identify ingredients internationally. All the ingredients listed on your label must have the INCI name and not the common name, whilst it is acceptable to include the common name beside the INCI for consumer transparency it is not necessary.
Ensure you list your ingredients according to their inputs in descending order with the largest input listed first and the smallest input listed last. Any ingredient that is under 1% can be listed in any order.
When listing your INCI names ensure it is spelt correctly. You will be genuinely shocked by the amount of brands that do not spell INCI names correctly. The INCI name of an ingredient should be found in a SDS (Safety Data Sheet). Another helpful resource is CoSing this is the EU’s official database, here you can use the search tool to find the correct INCI names of ingredients you intend to use.
2) List ALL allergens
Consumer safety is paramount. The manufacturer is responsible for the safety of their products, and must ensure that they undergo an expert scientific safety assessment before they are sold (European Commission, 2009).
Now if you are not a cosmetic chemist, once you do a CPSR, the report will list all of the allergens that you are required to list on your product. I recommend you do not pay for your labels or print them until you have a completed CPSR with the list of allergens. As you are legally required to list these allergens on a label, you don't want to waste spending money on labels that are non complaint.
3) Storage Instructions
On your label you must include storage instructions, so your customer knows how to store this product to ensure safety and efficacy. If you do not tell your customers how to store the product, their safety could be compromised.
4) Warnings & Cautions
Nearly all the ingredients used in the cosmetics are potential irritants, as formulators it is our job to ensure the irritation of a product is a low risk. Despite our best efforts irritation can and does happen, therefore we need to ensure suitable warnings are given in the event irritation does occur.
5) Direction’s of use
All products must contain the directions for use. Whilst it may seem obvious not to put shower gel in your eyes. Cosmetic businesses are still required to list the directions of use. That way consumers know the product is safe for use when used as directed. For example, a shower gel may be perfectly safe when used as instructed - washing my body with it. But if I eat it for example I could end up in the hospital, but if a business did not specify the way in which I should use the product, they could potentially be liable for any damage or injury caused to me as the consumer.
6) Responsible Person and Address
Each product must indicate who the responsible person is and the address of manufacture. Now before you panic don't worry your personal name and address is not required. You can use your business name and address. If you are formulating from home, you can purchase a PO Box address or alternatively use your registered business address.
7) Shelf Life
Each product should indicate the shelf life of the product, this is usually 6 months, 12 months, or 24 months. A CPSR will tell you what the recommended shelf life of your product is. There are universal signs you’re probably already used to seeing look like a little cosmetic pot with a lifted lid with either ‘6M’ ‘12M’ ‘24M’ written within. Another reason it is important to state the storage instructions, as storing it incorrectly can effect the shelf life, reducing its shelf life and potentially rendering the product not fit for use.
Conclusion
Now at this point you might be thinking how an earth do I fit all of that information onto one small label, particularly if you are selling a serum or a lip balm. One way to overcome this is by have boxes, you are required to list a lot of information as outer box for the cosmetic product will allow you more room to list all the information required. Alternatively you can produce a leaflet with all the information required, this leaflet MUST come attached with every product and be obviously visible to the consumer. Another option is to purchase labels that you can pull back to reveal further information.
Compliance can seem very overwhelming at first, but it needn’t be and hopefully this blog post has provided insight on what you need to do to have compliant labels and how to overcome issues such as not having enough space on your labels.
References
European Commission. (2009). REGULATION (EC) No 1223/2009 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL. Date Accessed [13/11/2023]. Available at: https://www.eumonitor.eu/9353000/1/j9vvik7m1c3gyxp/vibn2mp7slr0#:~:text=This%20Regulation%20establishes%20rules%20to,of%20protection%20of%20human%20health.
Personal Care Product Council. (2023). INCI. Date Accessed [13/11/2023]. [Online] Available at: https://www.personalcarecouncil.org/resources/inci/
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