A cosmetic label in the US needs, on the front panel, what the product is and its net quantity, by weight for a cream or butter and in fluid ounces for a liquid, placed in the bottom 30% of that panel. Elsewhere on the label it needs the ingredients in descending order of how much is in it, the name and place of business of whoever makes or distributes it, any required warnings, and, since the 2022 cosmetics law (MoCRA), a US address, phone number or website where customers can report reactions. Small businesses are exempt from some of MoCRA, but not from these label rules. And what you claim matters as much as what you list: a label that says a product treats a condition can make it a drug. Below is each part, a worked example for a body butter, the claims to avoid, and the records behind the label.
The short version
- Front panel: what it is, and the net quantity in the bottom 30%.
- Net weight for solids and creams; fluid ounces for liquids. Metric may appear too.
- Ingredients in descending order; those at 1% or less in any order after the rest; colors last.
- Your business name and place of business.
- A US address, phone number or website for adverse event reports.
- No drug claims: "heals eczema" or "cures acne" can make it a drug.
- TaroStack prints a lot label for every batch and ties each lot to its batch record. More below.
The front panel
The principal display panel is the part of the label most likely to be seen on the shelf. It carries a statement of identity, the common or usual name of the product or a descriptive name, like "whipped body butter" (21 CFR 701.11). It also carries the net quantity of contents: by weight if the product is solid, semisolid or viscous, by fluid measure if it's liquid, using the words "net weight" for weight, placed in the bottom 30% of the panel, with an exception for panels of 5 square inches or less; a metric statement may appear too (21 CFR 701.13).
The rest of the label
| Part | What it says | Rule |
|---|---|---|
| Ingredients | In descending order of predominance; at 1% or less, in any order after the rest; color additives last | 21 CFR 701.3 |
| Name and place of business | The manufacturer, packer or distributor, as the business is named | 21 CFR 701.12 |
| Contact for adverse events | A US address, phone number or electronic contact, which may be a website | 21 U.S.C. 364e |
| Safety warning | Required only if the product's safety hasn't been substantiated | 21 CFR 740.10 |
Fragrance may be listed as "fragrance" in the ingredients today. MoCRA also requires fragrance allergens to be named on the label once FDA's rule naming them is final; FDA's MoCRA page still lists that rule as one it has to establish, so check it before you print a large run.
A worked example
Windward Roots, the made-up taro business I use in these examples, sells a 4 oz whipped body butter. Its batch is 40% shea butter, about 20% each coconut oil and mango butter, 15% jojoba oil, 4% arrowroot and 1% lavender oil, so the label reads:
| Panel | Text |
|---|---|
| Front | Windward Roots Whipped Body Butter, Lavender |
| Front, bottom 30% | Net wt. 4 oz (113 g) |
| Back | Ingredients: Shea Butter, Coconut Oil, Mango Seed Butter, Jojoba Seed Oil, Arrowroot Powder, Lavender Oil |
| Back | Windward Roots, Kailua, HI 96734 |
| Back | Questions or reactions: (808) 555-0142 |
| Back | Lot WR-BB-261008 |
The lot code isn't on the list of federal label requirements, but it's what connects a customer's call about a reaction to one batch, instead of every jar you've made. The cost of the jar and label, and the rest of starting a line, is in cosmetic business startup cost, and the batch's own record in cosmetic batch record template. Bath bombs, with their own rules on colors and claims, are in starting a bath bomb business.
Claims to avoid
Whether a product is a cosmetic or a drug depends on its intended use, and claims establish intended use (FDA).
| Cosmetic claim | Drug claim |
|---|---|
| Softens and moisturizes skin | Heals eczema or psoriasis |
| Smells of lavender | Relieves pain or inflammation |
| Cleanses | Kills germs or treats acne |
| Leaves skin feeling smooth | Repairs damaged skin or reduces wrinkles permanently |
The same applies to your website, your market sign and your social posts, not only the jar. This is general information, not legal advice.
Where this stops working
The label is designed once. Then the recipe changes, jojoba goes from 15% to 22% and moves up the list, a new supplier's shea comes with a different name on its documents, and the old labels are still in the drawer. Six months later a jar with the old ingredient list goes out on the new recipe, and when a customer calls about a reaction, the lot code leads to a notebook that doesn't say which recipe that batch used.
How TaroStack does it
TaroStack ties every jar's lot code to the batch, the recipe version and the ingredient lots behind it.
Recipes with versions. Each product is a recipe with versions, so when jojoba goes up to 22%, that's a new version, and every batch records which version it was made to: the cue to check the ingredient order on the label before the next print run.
A lot label for every batch. Record a batch and TaroStack takes each ingredient from the lot used, and the finished jars go into a lot with its own code and dates. Lot labels print with the lot code, and a GS1-128 barcode when the item has a GTIN, with a ZPL file for Zebra printers. Batch record forms are filled in as the batch is recorded, with your own fields, like a label check and sign-off.
And a reaction leads somewhere. When a customer calls with a lot code, one report shows that lot's batch, its ingredient lots and suppliers, every customer who got jars from it, and what's still on your shelves.
| The question | Notebook | In TaroStack |
|---|---|---|
| Which recipe was this batch? | Maybe written down | The recipe version, on the batch |
| What's on the jar to trace it? | A date, if anything | A lot label with its code |
| Which shea went in? | "Shea" | The supplier's lot, on the batch |
| Who else has this batch? | Search the orders | One report, lot to customer |
Lots, lot labels, recalls, recipes with versions, batches and batch records are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.