US cosmetic label check: a sample report

The marked-up label

Numbered boxes show where each potential risk appears on the artwork. The numbers match the findings below.

Findings

The issues the review flagged, grouped. Each shows what the label says now, the change to make, and the rules cited.

1. 1

   The eye warning icon lacks corresponding text explanations.

   The label uses an eye icon with a slash to imply avoiding contact with the eyes, but does not provide a textual warning describing this risk and usage restrictions.

   Before: on the label

   Icon of an eye with a diagonal slash through it

   After: the change to make

   Add a textual warning in a prominent place on the label, such as “Avoid contact with eyes”, to clearly convey the usage restrictions intended by the symbol in words.

   Rules cited

   • CFR Title 21 Subchapter G - Cosmetics p. 27
2. 2

   Plant icon used as an environmental claim lacks qualifying statements.

   The two-leaf plant icon may be perceived as an environmental benefit or a certification mark; however, the label does not include certification basis or qualifying language, which easily creates an unsubstantiated general environmental impression.

   Before: on the label

   Icon of two plant leaves

   After: the change to make

   Add clear and prominent qualifying language next to the icon explaining the specific, limited benefits or certification basis indicated by the icon; if there is no third-party supporting evidence, it is recommended to remove the icon.

   Rules cited

   • CFR Title 16 Chapter I - Federal Trade Commission p. 245
3. 3

   Net quantity is not declared on the principal display panel

   The net quantity of contents “0.28 OZ. NET WT./8 g” is only marked on the back or bottom of the compact and does not appear on the Principal Display Panel (PDP), which does not comply with the requirement that the net quantity of contents must be declared on the Principal Display Panel.

   Before: on the label

   The principal display panel shows only “RegaaS SKIN ENHANCER Luminous Baked Bronzer”; the net quantity “0.28 OZ. NET WT./POIDS NET 8 g” appears only on the back information panel

   0.28 OZ. NET WT./POIDS NET 8 g is on the back/bottom label; the principal display panel shows only SKIN ENHANCER Luminous Baked Bronzer

   After: the change to make

   Move or duplicate the net quantity statement to the bottom one-third of the principal display panel (front) to ensure consumers can identify the contents on the front.

   Rules cited

   • 15 U.S.C. 39 - Fair Packaging and labeling Program p. 2
   • CFR Title 21 Subchapter G - Cosmetics p. 18
4. 4

   Statutorily required information is centrally labeled on the bottom panel of the container.

   The ingredient list, distributor information, and net contents are all labeled on the bottom of the compact. In the absence of an outer box, the bottom generally may not serve as the primary labeling panel for mandatory required legal information.

   Before: on the label

   The ingredient list, distributor information and net quantity are all on the label on the bottom of the compact

   After: the change to make

   It is recommended to add an outer packaging box for the product and fully label the statutory mandatory information on the outer box, or move the information to a panel visible during display.

   Rules cited

   • Cosmetics Labeling Guide p. 8
5. 5

   Placeholder / non-genuine valid number

   The label contains suspected placeholders or non-genuine numbers/dates, which should be corrected to genuine and valid values.

   Before: on the label

   1-800-000-0000 000000000000

   After: the change to make

   Please correct the placeholders to genuine and verifiable numbers/dates/batch numbers.

   Rules cited

   • Data authenticity check

Points to verify on your file

Some requirements depend on the formula, the print file or documents that are not on the label. The report lists them as checks to make. A few from this run:

• CFR Title 16 Chapter I - Federal Trade Commission p. 608

  Verify whether the print height of the metric unit symbol “g” on the printed artwork (dieline) is 1.6 mm (1/16 inch) or greater, and ensure that the font proportion complies with regulations - ensure compliance with the requirements of 16 CFR Section 500.18.

• CFR Title 16 Chapter I - Federal Trade Commission p. 607

  Verify on the printing dieline artwork whether the net quantity declaration is printed in boldface type and has clear, legible color contrast - in compliance with relevant 16 CFR regulations.

• CFR Title 16 Chapter I - Federal Trade Commission p. 601

  Confirm that the street address of PÉSASÉS DEMO INC. is listed in a current public directory, commercial registration database, or the company's official website; if it is not publicly listed, the street address should be added to the business address on the label - in compliance with 16 CFR § 500.5.

• Cosmetics Labeling Guide p. 10

  Check whether the statement of identity (Luminous Baked Bronzer) on the printing artwork (dieline) is printed in bold type, and confirm that its font size is reasonably proportional to the most prominent printed matter - Ensure compliance with the provisions of 21 CFR 701.11 and cosmetic labeling guidance.

• CFR Title 16 Chapter I - Federal Trade Commission p. 231

  Confirm and prepare valid certification contracts and authorization documents for Leaping Bunny (CCIC) to ensure that the endorsement mark complies with the collective judgment procedures of the organization - in compliance with the provisions of FTC 16 CFR § 255.4.

• CFR Title 16 Chapter I - Federal Trade Commission p. 244

  Confirm and prepare the formal licensing agreement and valid third-party certification documentation for Leaping Bunny (CCIC) - Ensure compliance with the provisions of FTC CFR Title 16 Chapter I regarding third-party endorsements and certifications.