Labeling your Mineral Makeup
I am creating a line of "multi purpose mineral cosmetics" with micas.
Let's say one of the colored micas contains mica, titanium dioxide, iron oxides, and ferric ferrocyanide. Does the ferric ferrocyanide have to be listed on the ingredients list?? Is that considered something that would be a "trace" ingredient, and therefore I'm not required to list it?? I see a lot of little mineral companies list on their sites: multi purpose minerals - contains mica, titanium dioxide, iron oxides. May contain: chromium oxide green, ferric fero., etc.... , but it doesn't seem they list it on their products. Is this right?
Labeling of cosmetics is regulated by the US Food and Drug Administration (FDA). The laws require that your label do the following:
- State the name and place of business of the manufacturer, packer or distributor
- Give an accurate statement about the quantity of the contents (e.g., "3 grams")
- Include any safe use and/or warning statements
- Include an Ingredient Declaration.
That last one, the Ingredient Declaration, has lots of exceptions and subrules, which can be confusing.
For example, flavors and fragrances can be listed in the Ingredients Declaration without mentioning their ingredients, instead you can just list them as "flavor" or "fragrance".
Another example: While you need to list the ingredients that are greater than 1 percent of the formula in descending order, you can group the "less than 1 percent" ingredients together and list them at the end in no particular order.
Color additives are another exception. These are listed at the end of the Ingredient Declaration, regardless of order of predominance. The FDA also allows colors to be listed in a "May Contain" phrase. This lets you have one label for multiple products that are the same, just different in hue (like several different foundations).
The best place to go for a full understanding of the rules and regulations is straight to the FDA website. They have a very easy to read "Cosmetic Labeling Manual".
Plan on spending about 30 - 45 minutes just sitting down and reading, browsing and learning. Because of the potential liability in "misbranding", you are ultimately going to have to rely on yourself to figure out how your labels should read. Your vendors (such as TKB Trading) can provide information and guidance, but they are never going to give you specific instructions.
The good news? It really is not that complicated nor difficult. The other good news: once you are done, you don't have to think about it again!