Updated from an original article written by Jinpeng Li.
Most of us use cosmetics daily. In this post, we look at cosmetic product labeling and how we can make informed choices by reading and understanding our products’ packaging.
Updated March 4, 2024
What are cosmetics labels?
Cosmetic labels provide an overview of the product’s function, the ingredients in the product, and any allergens (e.g., nut oils, etc.). Our laws require manufacturers to label all cosmetics products with an ingredient list that includes all of the ingredients that make up the final product.
Some cosmetics, such as products containing sunscreen or acne medication, may contain ingredients considered over-the-counter drugs by regulators. In that case, the manufacturer will include a cosmetic label and a drug label containing the active ingredient and instructions on properly using the product.
Our laws require product manufacturers to ensure the labeling is clear and accurate. The federal government can issue a recall to keep consumers safe if a product contains adulterated or otherwise fraudulent ingredients.
Who develops, requires, and enforces labeling standards?
In the United States, there are three main entities responsible for developing and enforcing labeling requirements: the Food and Drug Administration (FDA), the United States Department of Agriculture (USDA), and the Federal Trade Commission (FTC).
U.S. federal government organizations aren’t the only entities that require labeling; some states, such as California, have passed legislation that requires additional labeling on products sold within the state. Since most product production isn’t state-specific, labeling required by specific states can be found on products available nationally.
Are cosmetic ingredients listed in a specific order on the packaging?
Regulators require manufacturers to list all ingredients found in a product from largest to smallest quantity based on weight. We need to avoid making too many assumptions from the label hierarchy because many active ingredients do not require large amounts to work effectively.
Let’s look at lotion for an example. Typically, we’ll find “water (aqua)” listed as the first ingredient; this means most of the product is made up of water. Next, we may find “glycerin,” a humectant or an ingredient that retains moisture. As we go down the list, we can get a sense of which ingredients make up most of the product. At the end of the ingredient list, we will find ingredients added in the smallest amounts for lotions that could be a preservative, artificial color, fragrance, or even an active ingredient, depending on the concentration needed.
Is there other information besides ingredient information on the packaging?
Yes, cosmetics typically include expiration date information. You can learn about the preservatives needed to keep our cosmetics safe, as well as how to calculate a cosmetic product’s expiration date.
Additionally, the Modernization of Cosmetics Regulation Act (MoCRA) passed in 2023 requires additional information, including a way to report an adverse event due to using the product.
Notably, MoCRA requires companies to label any fragrance ingredients known to cause allergic reactions.
What is a marketing or “trend” label on a cosmetic?
A marketing label is a featured word or image highlighted on a product’s packaging to encourage sales. Often, these words/images underscore an ingredient (or lack of ingredient) or process that implies health, safety, or effectiveness.
When a fad becomes part of mainstream conversation, companies may repackage, relabel, or even reformulate a product to meet the demand. Marketing labels often include “trend” or “hype” labeling.
Let’s look at an example of a marketing or “trend” label.
We regularly see companies marketing shampoos and conditioners as “gluten-free.” For people who have celiac disease, gluten can cause adverse health effects when consumed. However, there’s no evidence that people with celiac disease need to use gluten-free hair products. Yet, the trend continues to include “gluten-free” labeling on many cosmetic products.
The same is true for any number of ingredients or labels.
Are marketing labels unregulated?
Unlike government-certified labels, such as USDA Organic, government agencies do not regulate most marketing labels. The content on the marketing labels is either added by the manufacturer to call out an ingredient or certified by a third-party organization, such as the “Non-GMO Project,” which requires manufacturers to meet specific standards.
Marketing labels reflect neither the product’s health nor safety but may call out an ingredient, process, or expected outcome. Remember, the legally required labels will provide an overview of what the product does, the ingredients in the product from largest to smallest by weight, and any allergens (e.g., nut oils, etc.).
Only the regulated ingredient list labels on cosmetics reflect the safe use of the product and list the ingredients, providing you with an understanding of the product you’re purchasing without additional marketing influence.
The good news.
Knowing how cosmetic labeling works helps us avoid the potential pitfalls of trend marketing labels. There are also tools and resources available to us so we can know what ingredients are in our cosmetic products and when our products are past their expiration date.
We can review science-based safety reports for cosmetic ingredients at https://www.cir-safety.org/ingredients.
If you have any questions about foods and ingredients, please reach out to us via email or submit your idea to us at go.msu.edu/cris-idea.