Fragrance labeling requirements would seem simple. Many ingredient lists simply include “fragrance” to identify a fragrance ingredient. However, fragrance labeling requirements are more complicated than they would seem. In fact, as discussed below, in certain circumstances, an expanded content label, such as those printed by a booklet label printer, may be needed. Here are five frequently asked questions about fragrance labeling requirements:

How Are Fragrances Regulated?

Fragrances are regulated by the U.S. Food and Drug Administration depending on how they are used. Fragrance products that are applied to the body are regulated as cosmetics if the fragrance is applied to the body to “make the person more attractive.” Examples of these kinds of fragrance products include perfume, aftershave, and cologne. Conversely, fragrance products that are applied to the body for therapeutic uses are regulated as drugs. Examples of these kinds of fragrance products include sleep aids and products for muscle and headache relief.

What is the Difference Between Regulations for Cosmetics and Drugs?

The distinction between cosmetics and drugs is important. Drugs must be approved by the FDA before distribution. Cosmetics, on the other hand, are FDA-regulated, but not FDA-approved. This means that cosmetics are not reviewed and approved prior to distribution. However, the FDA does retain jurisdiction over cosmetics and their manufacturers in the event that the cosmetic or the product labeling violates the Federal Food, Drug, and Cosmetic Act or the Fair Packaging and Labeling Act. Thus, cosmetic fragrance products must be labeled in accordance with federal law and federal regulations.

Do Fragrance Ingredients Need to Be Listed?

The short answer is yes. Because consumers can suffer a variety of allergies and sensitivities, fragrance ingredients must be tested to be safe and must be listed on product labeling. Even products that are marketed as “unscented” must list any fragrances used to mask chemical odors. If a label fails to include all the required information, or the required information is not prominent and conspicuous, the product may be “misbranded” under the Federal Food, Drug, and Cosmetic Act.

How Much Information Is Required to Be Disclosed About Fragrance Ingredients?

Under the Fair Packaging and Labeling Act, manufacturers are not required to disclose trade secrets. Therefore, manufacturers of cosmetic fragrance products are allowed to simply list fragrance ingredients as “fragrance.”

What Other Information Must Appear on Cosmetic Fragrance Labels?

Ingredients for cosmetics must be safe for use as instructed on the product labeling. Thus, the label must include instructions if there are any limitations on the safe use of the cosmetic fragrance product. Moreover, cosmetics must include warning statements “whenever necessary or appropriate to prevent a health hazard that may be associated with the product.”

Importantly, information required on product labeling may lack prominence or conspicuousness required under the regulations, even if it appears on the label, if there is insufficient label space or the size or style of the typeface causes the information to be obscured or crowded by other information or design elements on the label. That is, it is possible to violate the cosmetic product labeling regulations by having a product label that is too small or too crowded due to the size of the label. For some products, this may require creative solutions such as expanded content labels. For example, booklet labels, foldout labels, and peel back labels could be used to create labeling for cosmetic fragrances that provides the necessary space for ingredients, instructions, and warnings. Moreover, a booklet label printer, for example, can create labeling that also provides space for consumer information. According to one survey, 75% of consumers will forego an in-store purchase in favor of researching and purchasing a product online if they cannot find the information they need while in the store. A booklet label printer can create labels with adequate space to address these consumers’ needs.

Conclusion

Product labeling for cosmetic fragrances may need to include ingredients, instructions, and warnings in a prominent and conspicuous way. A printer who handles expanded content labels, such as a booklet label printer, may be able to provide product labeling that meets these needs.