Comparatively Speaking: Cosmetic Labeling in the United States

In the following excerpt adapted from an article featured on the Chemist's Corner, Tony O'Lenick looks to Perry Romanowski of Brains Publishing to describe the process of listing the ingredients on a cosmetic product label, for the benefit of novice formulators. The present article builts upon a previous discussion of naming conventions for ingredients themselves.

My first experience with cosmetic labeling occurred in college when I turned over the bottle of a shampoo and looked at the ingredient list. This was right around the time when I was learning how to name chemicals, and I was confused as to why I did not recognize almost any of the ingredients. As it turned out, the cosmetic industry does not follow the International Union of Pure and Applied Chemistry (IUPAC) system, which is what is taught to chemists in college. As previously mention, it instead follows a system set up by the Personal Care Products Council (PCPC), as described in the International Nomenclature Cosmetic Ingredient (INCI) Dictionary.

The ingredient names in a personal care formula are only part of the labeling process. A personal care product formulator must also follow the labeling rules laid out by the US Food and Drug Administration (FDA) that affect ingredient order, placement on the label, text size, language and more. Here are the relevant facts.

Cosmetic Ingredient List
In the United States, it is a requirement that all cosmetics be labeled to indicate what ingredients they contain. The list of ingredients (LOI) should be printed on the container following some specific rules.
1. Ingredients above 1% must be listed in order of concentration
2. Ingredients less than 1% can be listed in any order
3. Exception: Color ingredients are included at the end of the list and their names must be those that are used in the INCI Dictionary.

Where Does the List Go?
Once a product ingredient list is assembled, it must be placed on the package in the proper position. The FDA requires that it be placed on the principle display panel, which in most cases means somewhere on the primary package where it is visible to consumers.

What Font?
To ensure that the ingredient list is readable, the FDA requires the font size to be no smaller than one-sixteenth (1/16) of an inch unless the packaging is small, in which case the font can be one-thirty-second (1/32) of an inch.

What Language?
Products sold in the United States must list ingredients in English.

Additional Information to Include
1. Name of the product (e.g. shampoo, lipstick, eye shadow);
2. Name of manufacturer or distributor;
3. Address of manufacturer including city and zip code;
4. Net contents in container; and 
5. Warning statements if required.

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