Hair Product Labels
Hair Product Labels
December 17th, 2022
According to the the U.S. Food and Drug Administration (FDA) webpage on cosmetics labeling, there are no requirements in the U.S. for cosmetic manufacturers to print expiration dates on the labels of cosmetic products. Additionally, under current U.S. law (as of March 19th, 2021), cosmetic products and ingredients do not need direct approval from the FDA before they go on the market. However, companies (and individuals) who market cosmetics have a legal responsibility to ensure the safety of their products. This shows in the symbols used on their packaging, which is what this next post is all about.
I went more in-depth on how U.S. ingredient loopholes may not be as transparent compared to European regulations in another blog titled Simplifying Hair Products II. The most common example is when the term “fragrance” is shown instead of the complete ingredient list that makes up the fragrance. This is commonly classified as a “trade secret" ingredient, and is pre-approved by the U.S. FDA for all fragrances.
For this post, I start with an overview of the differences in packaging requirements between the U.S. FDA and Cosmetics Europe (CE), shown side-by-side in the chart below. A company's products will be accepted in various markets worldwide if all approved symbols and languages are present. This is the reason why you'll see durability dates on U.S. cosmetics products even though the FDA does not require them.
After that chart, I've also listed some of the most common product symbols, along with their meanings.
I went more in-depth on how U.S. ingredient loopholes may not be as transparent compared to European regulations in another blog titled Simplifying Hair Products II. The most common example is when the term “fragrance” is shown instead of the complete ingredient list that makes up the fragrance. This is commonly classified as a “trade secret" ingredient, and is pre-approved by the U.S. FDA for all fragrances.
For this post, I start with an overview of the differences in packaging requirements between the U.S. FDA and Cosmetics Europe (CE), shown side-by-side in the chart below. A company's products will be accepted in various markets worldwide if all approved symbols and languages are present. This is the reason why you'll see durability dates on U.S. cosmetics products even though the FDA does not require them.
After that chart, I've also listed some of the most common product symbols, along with their meanings.
PACKAGING REQUIREMENTS
Ingredients ➤➤➤➤➤➤➤➤➤➤➤ FDA - Must be listed on the bottle, but manufacturers can withhold ones deemed "trade secrets". CE - Must be listed on the bottle. |
Durability Dates ➤➤➤➤➤➤➤➤➤➤➤ FDA - None required. CE - Must include a “date of minimum durability” or a “period after opening” to show how long a product should be good for. |
Net Quantity ➤➤➤➤➤➤➤➤➤➤➤ FDA - Must indicate an accurate statement of weight. CE - Must indicate the normal net. |
Responsible Party ➤➤➤➤➤➤➤➤➤➤➤ FDA - Must list manufacturer, packer, or distributor, plus street address, city, state and zip. Can be omitted if address is listed in a current phone or city directory. CE - Must list the name and address of the company, plus response person. |
Material Facts ➤➤➤➤➤➤➤➤➤➤➤ FDA - Must include directions for safe use if product can cause harm when used incorrectly. Cosmetics that could be considered hazardous must bear appropriate label warnings (ex: flammable products). CE - Must include any warnings that might be necessary for applying the product safety. |
Identity Statement ➤➤➤➤➤➤➤➤➤➤➤ FDA - Must indicate the nature and use of the product, by means of either the common or usual name, a descriptive name, a fanciful name understood by the public, or an illustration. CE - Must state what the product is, if not obvious from its appearance. |
Packaging Requirements Chart Sources: U.S. Food and Drug Administration: Cosmetics and Cosmetics Europe: Understanding the Label
PAO Numbered Jar
The symbol resembles an opening jar and has a number and the letter M. This translates into the moment you open a hair product the Period After Opening (POA) timer begins. The time allotted before expiration is portrayed by the number along with “M” standing for the months. For example “12M” is a commonly depicted symbol that shows a product has a good chance of starting to deteriorate at the 12 month mark.
|
Cruelty Free Logos
There are three main "bunny logos" used on products to help animal-cruelty-conscious shoppers avoid products that have been tested on animals. While these symbols help identify how the ingredients are sourced, it does not address which of their approved brands are owned by parent companies that do test on animals. In a time where a few companies control most of the major brands we use today, it's difficult to decipher if your purchase is under an umbrella of other brands that are not cruelty free. Conversely, the absence of these is not an admission of companies using animal tested ingredients because the logo is not mandated by the FDA. Be aware that some companies try to use similar symbols that are not approved by the same standards.
Cruelty Free Logo #1
PETA 's “Cruelty Free” Program has been running since 1980. For a product to display the "cruelty free" logo means the company as a whole has proven they do not test any ingredients, including those that are externally sourced, on animals. The companies allow independent audits and renew their pledge annually. The program is free to participate in the U.S. and Canada, but there is a cost to display the actual logo. |
Cruelty Free Logo #2
Choose Cruelty Free (CCF) is a non-profit based in Australia that originated in 1993. They actively campaign to end animal testing that facilitates to market cosmetics, toiletries and other household products. |
Cruelty Free Logo #3
The International Leaping Bunny Program began in 1996 when eight national animal protection groups banded together to form the Coalition for Consumer Information on Cosmetics (CCIC). The CCIC promotes a single comprehensive standard and an internationally recognized Leaping Bunny Logo. |
Best Before End of Date (BBE)
The BBE hourglass isn't to be confused with the PAO symbol. Instead of telling you how long you can keep the product after opening it, this logo signifies that the product will only last for 30 months, whether it has been opened or not. This symbol is more common in the EU. |
Open Flame
The open flame symbol is a warning on cosmetic products like hairspray, deodorant and nail polish that typically contain ingredients like alcohol and propellant gas, which are flammable. Companies in both the U.S. and E.U. have to disclose warnings about product flammability to ensure consumers know to keep flames and high heat away during use. |
E-Mark
Both the FDA (U.S.) and CE (E.U.) require the net quantity of a product be stated when it is packed (defined at the time it is filled into the bottle/tube/etc). It's a common visual to the U.S. purchaser who buys products produced in the E.U., however the symbol is not required in the U.S. It's generally placed on the center, front bottom of the product. |
Green Dot
This arrow-filled symbol shows that the company is part of a European-wide recycling strategy that abides by packaging waste rules. A financial contribution has been paid to a qualified national packaging recovery organization set up in accordance with the principles defined in the European Packaging and Packaging Waste Directive. |