Labelling Legislation.

The use of some sort of personal care product is close to saturation point in most industrialised nations. More or less everybody uses soap, shampoo, makeup, sun-cream or deodorants multiple times each day, how do we know they are safe? Many measures are in place to protect and inform the consumer, product labeling is one, as a manufacturer, you can’t ignore.

When we smear anything on our skin or wash our hair in it, some of it will get absorbed through the skin into the bloodstream. All products are subject to some form of legislation and the cosmetics and personal care industry is more stringently policed than most. If you get this one wrong you could be liable to prosecution or pulling products off the shelves - both costly.

 

Requirements on the Primary Packaging.

 

   

  • Contact details of responsible person or organisation.

  • Ingredient listing.

  • Batch code or number.

  • Shelf life.

  • Some means of identifying the function.

  • The average net weight or number of the product(s).

  • Best before date.

  • Any applicable warnings or precautions.

 

A note on BREXIT, since all this legislation is designed to standardise the global labelling systems, the UK government is highly unlikely to make products made in the United Kingdom potentially disadvantaged for export so expect no change to this guide in the near to medium term.

Contact.

A fairly obvious one, the consumer and others in the chain need some point of contact for many potential reasons. A company name, address and postcode in an inconspicuous place is sufficient just so anyone can get hold of you if they need to. A country of origin is often added to facilitate the option to export.

Ingredients Listing.

Preceded by the word “Ingredients” (to keep the Obvious Police happy) you need to list every ingredient in any toiletry, perfume, cosmetics or personal care product in order of weight. Ingredients should be listed in their International Nomenclature for Cosmetic Ingredients or INCI name. The INCI name of the ingredients will accompany the safety documentation that your chemical suppliers are legally obliged to send with each shipment. There are currently over 6000 ingredients on the list, more information is available from the EU site.

Batch Code or Number.

If an error comes to light or you need to recall a product from sale, it will be less costly if you can identify a smaller proportion of the units out there. The batch code identifies the products in question, we can incorporate this into the design but it's more common to use a separate method.

Shelf Life.

Current legislation requires some indication of the length of time your product will remain effective if it’s less than 3 years. The artwork files for all these symbols are available in full resolution pdf format by clicking the required image. The symbol for period after opening or PAO is shown below with a symbol showing an open jar with a suitable period of time such as 12M for 12 months.
3 Months 6 Months 9 Months 12 Months 18 Months 24 Months
Artwork for all symbols on this page are available in full resolution pdf format - click the required image.

Best Before Date.

Best Before EndA concept that we are all familiar with from food labelling but rare on cosmetics and personal care because when sealed the products last longer than 30 months after which no best before date is required. The standard symbol for this is the egg timer.

Stability testing.

Cosmetics and personal care product testing is a specialist area. Investigations should be made into physical, microbial and chemical stability of your range. The ingredient manufacturers may have in-house facilities and offer those to you along with guidance on which areas of testing are applicable to your particular product. Alternatively, professional services can be employed from companies like Intertek.

Function.

It might seem obvious but some clarification of the purpose of the contents of any packaging is required to remove any ambiguity. Just the bare minimum terminology is needed, “Shampoo” or “Suncream” is sufficient unless but it’s always better to remove any ambiguity if possible.

Net Measurements.

Net Size.The e-mark (template available) signifies that whatever measurement is indicated is an average, the e stands for estimated. There is a range of tolerance of deficits that ranges from around 9% for small quantities down to around 1% for large amounts. Denominations of weight, volume or number of items are required in metric, where applicable, other units are permitted in addition.

Precautions or Warnings.

Only required if you need to warn of any risks of using your product such as “Avoid contact with eyes.” The consumer must also exercise common sense, there is no need to warn people not to drink shower gel. 

Optional Information to Put on a Label.

 

Cruelty Free.

Cruelty FreeNot as clear cut as you might think. A finished product may have no animal testing performed on it whatsoever but what about the ingredients? In reality, you can put “not tested on animals” on the packaging and there is very little anyone can do to investigate. To answer this problem, organisations like crueltyfreeinternational actively vet subscribers and allow them to display their logo if you comply with their guidelines.

Organic.

This is another area where legislation allows ambiguity. Words like “natural”, “organic” and “green” have positive connotations in the public consciousness but in practice mean very little. In the United Kingdom, the Soil Association is the largest body to provide certification and worldwide standardisation in this industry is being sought by COSMOS.

Dermatology.

If your product is a known irritant it should not be smeared on people’s skin, so all cosmetics and personal care products are, by implication, “non-irritant” and the ingredients have been “dermatologically tested” at some point. “Hypoallergenic” has no legally defined meaning so is used on many products to imply safety and mildness. All these words can be and are used all over the world without the need for substantiation.

Recycling.

The bottle you use is likely to have its own recycling mark embossed into the base, if this is the case you are not required to put anything extra on the label. Optional marks include the following.

Name

Symbol

Result

Mobius Loop.

Mobius Loop.

Simply indicates that the packaging is capable of being recycled.

Green Dot.

Green Dot.

Not required in the UK. Denotes that the company has made a payment to offset disposal costs. Needed in many EU countries if you’re exporting.

Keep Britain Tidy.

A reminder to the consumer to dispose of the packaging responsibly.

     

 More Useful Logos to Download.

 Additional Information.Flammable

Cruelty FreeUVA

 

The next and final page in our guide will look at the finishing touches to make your chosen design extra perfect like surface finish, shape and adhesive.