Five things a label must carry
The United States Food and Drug Administration publishes a summary of cosmetics labelling requirements, and the first lesson from it is that a label is a short, structured document rather than a design. For a cosmetic sold at retail, the principal display panel identifies the product and states the net quantity. The information panel carries the name and place of business of the firm, the ingredient list in descending order of predominance, and any warnings the product needs. The FDA cosmetics pages set the wider frame: what a cosmetic is, what makes it a drug as well, and why a false or misleading label can make a product misbranded.
The statement of identity tells the buyer what the product is. It may be a common name such as body lotion, a descriptive name, or a name the public understands, and it should be in bold type of a sensible size. The net quantity tells the buyer how much is in the pack, in weight, measure or count, placed in the lower part of the panel. A 50 g jar and a 50 ml bottle are not the same amount of product, because the density is different, which is why the unit matters and why a cream is usually declared by weight. Neither line is decoration; each answers a question the buyer is entitled to ask.
The ingredient list is the part a formulator reads first. Ingredients are declared in descending order of predominance, so the largest amount comes first and the smallest last. Colour additives and ingredients present at 1 percent or less may be listed without regard to order, which is why the last few lines are often a cluster of preservatives, fragrance and actives. Fragrance may be declared collectively. The names should be the ones established or adopted by regulation, and INCI names are widely used. If the list does not match the batch record, one of the two is wrong, and the salon should find out which before the next batch is made.
The name and place of business identify who stands behind the product, with a street address, city, state and postcode, or a qualifying phrase such as manufactured for or distributed by when the named firm is not the maker. Warnings appear where the product needs them, for example on an aerosol or a product with a hazard in normal misuse. A cosmetic that has not been shown to be safe also carries a specific warning statement under the FDA rules. Five items, one page, and a formulator who can read them can tell whether a label is complete before it goes to print.
- 1. Find the statement of identity and check that it describes the product in plain words.
- 2. Find the net quantity and check that the unit suits the product: weight for a cream, volume for a liquid.
- 3. Read the ingredient list from the top and compare the first five lines with the percent column.
- 4. Check that the small lines at the end are plausible: preservative, fragrance, actives, colour.
- 5. Find the firm's name and place of business, and the qualifying phrase if it is not the maker.
- 6. Look for warnings where the product type needs them, and check that they are legible.
- 7. Compare the label's ingredient order with the batch record, and resolve any mismatch.
- 8. Keep a proof of the printed label with the batch record before the first fill.
Bench example: reading a jar against its batch record
A 50 g jar of face cream reads: Moisturising Face Cream, 50 g, and on the back, Aqua, Glycerin, Caprylic/Capric Triglyceride, Cetearyl Alcohol, Glyceryl Stearate, PEG-100 Stearate, Dimethicone, Panthenol, Xanthan Gum, Phenoxyethanol, Ethylhexylglycerin, Tocopherol, Citric Acid, and the firm's name and address. The batch record reads water 77.20, glycerin 5.00, triglyceride 6.00, cetearyl alcohol 2.00, glyceryl stearate 1.50, PEG-100 stearate 1.50, dimethicone 1.00, panthenol 1.00, xanthan 0.20, phenoxyethanol 0.80, ethylhexylglycerin 0.10, tocopherol 0.10, citric acid solution 0.50. The orders match, and the small lines sit at the end. If the label had listed phenoxyethanol third, the record and the label would disagree, and the printed stock would have to be withdrawn. The label is a public summary of the record, and the two should be read side by side. A label proof that carries the batch number in the file makes the comparison possible years later, when nobody remembers which artwork was printed. Read the front, the back and the base of the jar, because the five items are not all in one place. A label with a beautiful front and a missing address is an incomplete label.
Caution: Never print a label from a draft formula. Compare the ingredient order with the batch record that was actually made, not with the one that was planned.
Cosmetic claim versus cure claim
The FDA defines a cosmetic as an article intended to be applied to the body for cleansing, beautifying, promoting attractiveness or altering appearance, without affecting structure or function. A product intended to treat or prevent disease, or to affect the structure or function of the body, is a drug as well, and must meet both sets of rules. That single sentence explains most of the claim discipline in this book. A moisturiser that helps the look of dry skin is a cosmetic. A cream that cures eczema is a drug, whether or not the word cure appears, because the intent is to treat a disease.
The same logic covers acne, pigmentation and infection. A product that helps the look of oily, blemish-prone skin is making a cosmetic claim. A product that treats acne is making a drug claim. A product that helps even the look of tone is cosmetic; one that removes melasma is treating a condition. A shampoo that cleans hair is cosmetic; one that treats dandruff is a drug in many markets, which is why antidandruff shampoos are often regulated as over-the-counter products. The words are not a style choice. They decide which rules apply, and the rules decide what testing and labelling are needed.
A claim must also be true for the formula. A moisturiser that is mostly water with no occlusive or humectant at a useful level does not help dry skin for long, even if the words are cosmetic. A serum with 0.10 percent of an active that is studied at 5 percent is making a claim the formula cannot support. The FDA pages note that a product may be considered misbranded if its labelling is false or misleading, and a claim that outruns the formula is exactly that. Write the claim from the percent column, the pH and the test results, not from the competitor's website. A claim that outruns the formula is false or misleading labelling, whatever the intention behind it.
When a client or an owner asks for a stronger claim, the answer is a rewrite, not a softer word. Cures acne becomes helps the look of oily, blemish-prone skin. Cures eczema becomes moisturises dry, itchy-looking skin. Removes melasma becomes helps even the look of skin tone. Whitening becomes a description of what the product actually does, or nothing at all. Each rewrite must still be true. If the formula cannot support even the cosmetic version, the honest answer is that the product does not do the job, and the formula should change before the label does. A label that is rewritten to be honest about a weak formula is still a weak product, and the client will find out.
- 1. Write the claim in one sentence, then decide whether it is cosmetic or a drug claim.
- 2. Check the claim against the FDA definition: appearance only, or structure and function.
- 3. Check the claim against the percent column, the pH and any test results.
- 4. Rewrite cure and treat language into cosmetic language that the formula supports.
- 5. Remove disease names from the label, the website and the staff script.
- 6. Keep staff scripts consistent with the label, because a spoken claim is still a claim.
- 7. Refuse a medical claim and refer the client to a clinician when the concern is medical.
- 8. Keep the final wording, the proof and the reason for any change with the batch file.
Bench example: one product, three drafts of a claim
A salon makes a 2 percent salicylic acid leave-on lotion at pH 3.8 for oily-looking skin. Draft one says Treats acne and clears blackheads. That is a drug claim, and in many markets the product would need drug approval, which the salon does not have. Draft two says Removes acne in seven days. That is worse, because it adds a timeframe the formula cannot prove. Draft three says Helps the look of oily, blemish-prone skin, and the label keeps the salicylic acid at 2 percent or below with the local limit checked. The third draft is cosmetic, and it is still true only if the product is used as directed and the client does not have a medical condition. The staff script carries the same wording, so the claim at the shelf and the claim at the chair match. The salon also writes the reason for rejecting the first two drafts in the file, so the next person does not bring them back. A claim that has been considered and refused is a decision; a claim that was never noticed is a risk.
Caution: A softened word does not turn a drug claim into a cosmetic one. If the intent is to treat a disease, the product is a drug.
Words to leave off the label
Whitening is a word to leave off. It promises a change in skin colour that a cosmetic cannot lawfully deliver, and in many markets it is treated as a medicinal claim. The same applies to lightening, bleaching and permanent. Even brightening deserves care: it can describe the look of tone, but it should not imply a change in the amount of pigment. If the formula contains niacinamide at 4 percent and a humectant system, the honest claim is about the look of uneven tone. A client who expects a different skin colour will be disappointed, and a regulator who reads the word whitening will ask a question the salon cannot answer.
Chemical-free and toxin-free are words to leave off, because they are not true of a product that contains water and a synthesised ingredient. Water is a chemical. A preservative is a chemical. A fragrance is a mixture of chemicals. The phrase is a marketing device that trades on fear, and it invites the obvious reply: which chemicals are absent, and at what limit. A better label describes what is in the product and what it does. Free-from claims about specific allergens can be useful when they are true and tested, but a general chemical-free claim is a claim with no content.
Other words to avoid include permanent, which no cosmetic can guarantee; antibacterial as a product claim, unless the product is registered for it; and dermatologist tested, unless there is a report and a named dermatologist behind it. Clinically proven is a drug-flavoured claim that needs evidence the salon does not have. Natural is not regulated in the same way everywhere, and a product with a synthesised preservative is not natural in any useful sense. None of these words improves the product. Each one creates a question that the batch record cannot answer. A longer list of forbidden words is easy to find, but the principle is shorter: if the formula cannot show it, the label cannot say it.
The practical test is simple: read the label as if you were the person who will complain. Does each claim describe something the formula does, at the level in the jar, with the tests in the file? If not, remove it. A shorter label with a modest claim is easier to defend and easier to sell honestly. The salon's reputation is built on the gap between the promise and the result, and a small promise that is kept is worth more than a large one that is not. Read the label aloud before it is printed, because a sentence that sounds like an advertisement often sounds like a claim when spoken.
- 1. Remove whitening, lightening, bleaching and permanent before the artwork is approved.
- 2. Remove chemical-free and toxin-free, and describe what the product contains instead.
- 3. Remove cure, treat, heal and repair when they refer to a disease or a medical condition.
- 4. Remove antibacterial as a product claim unless the product is registered for it.
- 5. Remove clinically proven and dermatologist tested unless a report exists and is filed.
- 6. Replace each removed word with a cosmetic claim the formula can support.
- 7. Check the website, the shelf card and the staff script, not only the jar.
- 8. Keep the final artwork and the reason for each change with the batch record.
Bench example: cleaning up a shelf card
A shelf card reads: Whitening cream, chemical-free, removes dark spots in 14 days, dermatologist tested. The product is the niacinamide gel-cream at pH 5.2 with a tested preservative. Four claims have to go. Whitening becomes helps even the look of skin tone. Chemical-free is deleted. Removes dark spots in 14 days becomes helps the look of uneven tone with regular use, and the timeframe goes, because the salon has no study. Dermatologist tested is deleted, because there is no report. The card now says less, and every remaining word can be matched to the formula and the file. The staff are briefed on the new wording, because a spoken claim can undo a careful label. The old cards are collected and destroyed rather than left in a drawer. A staff briefing takes ten minutes and prevents the shelf card from being contradicted at the chair. The new wording is also checked against the website, because the page is part of the labelling in practice. A client who reads the website and then the card should find the same promises in both places.
Caution: Do not keep an old shelf card because it sells better. A claim that cannot be defended is a liability with a laminate finish.
This is a Nandu Nai textbook. It is a private brand book, not a government licence, and it does not give the right to give medical treatment.