Everything you need to know about Cosmetic Packaging and Labeling Requirements.
Post Covid-19, there are new packaging and labeling guidelines which will be strictly adhered to moving forward. Cosmetics marketed in the United States, whether manufactured here or imported from abroad, must be in compliance with the provisions of the Federal Food, Drug, and Cosmetic Act (FD&C Act), Fair Packaging and Labeling ActExternal Link Disclaimer (FP&L Act), and the regulations published under the authority of these laws.
Refer to List N on the Environmental Protection Agency (EPA) website for EPA-registered disinfectants that have qualified under EPA’s emerging viral pathogens program for use against SARS-CoV-2.
What are considered "Cosmetics?"
The FD&C Act defines cosmetics as articles intended to be applied to the human body for cleansing, beautifying, promoting attractiveness, or altering the appearance without affecting the body's structure or functions. Included in this definition are products such as skin creams, lotions, perfumes, lipsticks, fingernail polishes, eye and facial make-up preparations, shampoos, permanent waves, hair colors, toothpastes, deodorants, and any material intended for use as a component of a cosmetic product. Soap products consisting primarily of an alkali salt of fatty acid and making no label claim other than cleansing of the human
body are not considered cosmetics under the law.
The Next Normal of Packaging Post Covid-19
The COVID-19 pandemic has changed key megatrends already reshaping the packaging industry before the crisis:
Sustainability reemphasized and redefined, with hygiene concerns addressed. Although sustainability has recently taken a back seat, it remains a key industry-shaping trend. Packaging-sustainability goals have not been abandoned by leading fast-moving consumer goods (FMCG) companies and retailers, which remain committed to achieving high recyclability across their packaging portfolio over the long term. However, given the strong emergence of the new hygiene megatrend—one likely to become a key element of the next normal in packaging—companies will have to rethink the materials and design requirements of sustainable packaging.
Cosmetic Labeling Requirements
The cosmetics distributed in the United States must comply with the labeling regulations published by the FDA under the authority of the FD&C Act and the FP&L Act. Labeling means all labels and other written, printed or graphic matter on or accompanying a product. The label statements required under the authority of the FD&C Act must appear on the inside as well as any outside container or wrapper. FP&L Act requirements, e.g., ingredient labeling and statement of the net quantity of contents on the principal display panel, only apply to the label of the outer container. The labeling requirements are codified at 21 CFR 701 and 740. Cosmetics bearing false or misleading label statements or otherwise not labeled in accordance with these requirements may be considered misbranded and may be subject to regulatory action.
Finding the Best Packaging for your Cosmetics
Just like with soap, there are many different options when it comes to packaging your cosmetics. Tubes, jars, bottles; the options for customization are nearly limitless! Choosing your shape, size and color wisely is very important, but it is also important to consider factors like duability and shippability, whether the material could be recycled, whether it is sustainably and responsibly sourced, and how you will fill the packages with your product. You must also take into consideration how the product will look with your label on it.
Packaging Materials
Whether you choose tubes, jars or bottles, you will likely have the decision between plastic or glass packaging. Today's consumers are becoming more and more environmentally aware; for this reason, it's important to know a few terms that can help you navigate the different materials at your disposal.
HDPE - High Density Polyethylene
HDPE is one of the most common materials in cosmetic packaging. It is a very strong material, and is effectively moisture and chemical resistant (although some essential and fragrance oils can cause a collapse of bottle walls). It is rated for exposure to temperatures ranging from -100ºF to 120ºF, making it more resistant to climate-related damages. HDPE is also easily recycled. BioSafe offers HDPE containers in many different shapes and sizes, and with a variety of closures to really help you customize your final product.
PET - Polyethylene Terephtahalate Plastic
Much like HDPE, PET is lightweight and relatively durable. Temperature resistance for PET ranges from -40°F to 120°F, which lends resistance to climate damage. Unlike HDPE, which has a cloudy appearance, PET is clear like glass and comes in a wide variety of colors, from cobalt blue and amber to crystal clear. PET is also easy to recycle, making it an environmentally friendly packaging decision. BioSafe offers PET containers in many different shapes and sizes, and with a variety of closures to really help you customize your final product.
Filling Containers
When purchasing your containers, be sure to consider how you will fill them.
Bottles and jars are generally a bit easier to fill, depending on the viscosity of your product. If you prefer tubes, there are a few different ways you can go about filling them. If you are filling tubes by hand, some cosmetic makers find that a large syringe is an easy way to fill multiple tubes in quick succession; others use squeeze bottles.
Whichever packaging you choose, we can help you with your plan to fill them, as well as the equipment or the source to fill them. Your package may be eye-catching, but if it takes too much time to fill it, then you are potentially wasting or losing money.
Other Things to Consider
Before choosing your packaging, also consider the following:
How will you fill the container?
Will this packaging fit your shipping needs?
Is the packaging easy to display?
Is the package large enough to hold a compliant label?
Do you know how to sterilize your containers?
Making your Final Decision
Deciding on a package for your product can seem overwhelming, but we at BioSafe are here to help! By having a plan before starting the ordering process, you will cut down the time it takes to look for the perfect container. Know your goal, whether it is to have sustainable packaging or a fully customized container, be sure to visit several suppliers and be ready to ask questions to make sure you are getting exactly what you want. And, as always, make sure to include a compliant, easy to read label so that your customer knows exactly what they are purchasing.
