Introduction:
Cosmetic labelling is an essential part of developing and marketing cosmetics. Companies must meet government requirements for labelling, including ingredient listings, cautions and warnings, cosmetic claims, directions for use and other information needed for safety and consumer understanding. This guide outlines the necessary requirements of cosmetic labelling in Canada.
Understanding Cosmetic Labelling Regulations and Requirements:
Labelling requirements for cosmetics are outlined in legislation like the Cosmetic Regulations, the Consumer Packaging and Labeling Act and the Food and Drugs Act. It’s important to familiarize yourself with these regulations to ensure your labels meet all the necessary requirements. In addition, it is also essential that your labels are truthful, easy to understand, and provide adequate information to the consumer, including ingredient lists and product warnings.
Learn More About Ingredient Listings and Cosmetic Claims:
Cosmetic labels must list ingredients by their International Nomenclature Cosmetic Ingredient (INCI) name and in order of how much is present in the product from most to least. Ingredients must also be checked to ensure they are not present on the Cosmetic Ingredient Hotlist (Prohibited List), or that they comply with the restrictions per the Hotlist (Restricted List). Additionally, cosmetic labels may make certain claims about the product, such as “moisturizes” or “cleanses skin” so it’s important to be familiar with the regulations around these types of statements, and at what point they become unacceptable.
Understand Cautions & Warnings and Special Packaging Guidelines:
Labels that could be considered a possible health hazard must include appropriate caution and warning statements, such as ” “CAUTION: This product contains ingredients that may cause skin irritation on certain individuals and a preliminary test according to accompanying directions should first be made.” Special packaging guidelines must also be followed for any cosmetics packaged in a pressurized container (e.g., aerosol deodorant). Safety data sheets should be maintained for cosmetic products and should be kept on file until the product has been sold or disposed of.
Determine the Right Way to Display Safety Information and Expiration Dates on Labels:
Cosmetic products are not required to display an expiration date, however it may be ideal to include a “Best Before” date, to ensure product freshness and quality. This should be located near the name and address information, to clearly indicate when the product may no longer be safe to use. Safety symbols (e.g., pressurized container, flammable symbols) should also be included on labels where appropriate, to concisely communicate potential risks associated with the product. It is important to adhere to established labelling regulations in order for your products to remain in compliance with applicable industry standards.
Evaluation of Cosmetic Label Claims:
When formulating a cosmetic product with purposeful ingredients, it’s important to closely evaluate the claims being made on the label. Cosmetics cannot contain “active” or “medicinal” ingredients, therefore any claims that are made for the product must be generalized and cosmetic in nature. Cosmetic claims may refer to the product performance, but only without attributing a therapeutic effect. They may only describe effects in the context of appearance/scent. For example, “Our shampoo makes your hair soft and healthy looking.” would be an acceptable cosmetic claim. The nuances of cosmetic vs. health claims can sometimes be tricky, so it’s important to evaluate your cosmetic claims to ensure they are compliant with the regulations.
How Quality Smart Solutions can help
QSS offers regulatory services from registering your cosmetic products to reviewing your cosmetic labels and submitting a cosmetic notification application to Health Canada.
We also offer FDA cosmetic product compliance solutions for USA Cosmetic Regulations.
Our experts are here to help and offer any cosmetic-related regulatory advice!
