Lip balm with no sunscreen requirements!

[reginaphalange]

Hi everyone! For lip balm with no SPF - what are the requirements for labels? Are there requirements for the display box it goes in as well?

I have the oz/g, ingredients, and city/state of our location. I've had someone who works with a manufacturer say that my labels are good to go - just wanted to get second opinions!

Thanks in advance!

 

[AliOop]

In the US, lip balms must follow federal cosmetic labeling regulations, as well as any state or local regulations.

But this is an international forum, so we need to know the state and country of your location.

 

[reginaphalange]

In the US, lip balms must follow federal cosmetic labeling regulations, as well as any state or local regulations.

But this is an international forum, so we need to know the state and country of your location.

Hi! I’m in Texas

 

[Zany_in_CO]

we need to know the state and country of your location.

Check under her avatar... it says "Texas" there... unless she just added it?

On that note, I always feel frustrated when members don't include their State/Country info. It helps to know where they are from when responding to queries like this one.

I've had someone who works with a manufacturer say that my labels are good to go - just wanted to get second opinions!

Without a crystal ball handy, it would be helpful if you would post a pic of the label or at least the content as written. Please and thank you.

EXAMPLE

 

[reginaphalange]

 

[TheGecko]

Hi everyone! For lip balm with no SPF - what are the requirements for labels? Are there requirements for the display box it goes in as well?

I have the oz/g, ingredients, and city/state of our location. I've had someone who works with a manufacturer say that my labels are good to go - just wanted to get second opinions!

Thanks in advance!

SPF is regulated by the FDA. In order to include SPF, you would have to be licensed by the FDA and your product tested.

So your label would follow cosmetic regulations: Summary of Cosmetics Labeling Requirements

 

[AliOop]

Hi! I’m in Texas

Thanks, I had checked your avatar last night and didn't see it listed there. Sometimes when I'm on my phone, not everything is shown or easily findable -- but more likely, my *vintage* eyesight just couldn't make it out.

Since you indicated that you aren't using sunscreen, then as @TheGecko said above, the regular cosmetic labeling rules will apply. In order not to list your physical address on the label, it must be publicly findable/accessible. If your website actually listed your physical address, then putting your website on the label would meet that requirement. But I took a quick peek at your site (very nicely done!) and didn't see it there. <insert disclaimer here re vintage eyesight, etc etc>

 

[Virgogoddess]

View attachment 69005

I’m in the US and you can’t say vit. E. It has to be listed as tocopherol.

 

[Virgogoddess]

I’m in the US and you can’t say vit. E. It has to be listed as tocopherol.

Also, where do you get your labels? I’m updating mine. Ty

 

[AliOop]

I’m in the US and you can’t say vit. E. It has to be listed as tocopherol.

Good catch - I missed that one!

 

[reginaphalange]

I’m in the US and you can’t say vit. E. It has to be listed as tocopherol.

How interesting! I’ll bring this up with my manufacturers - thank you!

 

[reginaphalange]

Also, where do you get your labels? I’m updating mine. Ty

I currently use Onlinelabes, they have lip balm specific labels that I order in bulk!

 

[reginaphalange]

Thanks, I had checked your avatar last night and didn't see it listed there. Sometimes when I'm on my phone, not everything is shown or easily findable -- but more likely, my *vintage* eyesight just couldn't make it out.

Since you indicated that you aren't using sunscreen, then as @TheGecko said above, the regular cosmetic labeling rules will apply. In order not to list your physical address on the label, it must be publicly findable/accessible. If your website actually listed your physical address, then putting your website on the label would meet that requirement. But I took a quick peek at your site (very nicely done!) and didn't see it there. <insert disclaimer here re vintage eyesight, etc etc>

Thank you so much for all the help! You’re right - my address is not listed on my website. Although, Mend is an LLC so our address is listed online with that. Do you think I still need it on the website?

 

[reginaphalange]

SPF is regulated by the FDA. In order to include SPF, you would have to be licensed by the FDA and your product tested.

So your label would follow cosmetic regulations: Summary of Cosmetics Labeling Requirements

Thank you!!

 

[Zany_in_CO]

I’m in the US and you can’t say vit. E. It has to be listed as tocopherol.

Burt's Bees labels it Vitamin E and so do I! I know my customers, and my wholesale customers would ask, "What the heck is tocoherol?!" if that's what I put on my labels.

 

[Zany_in_CO]

I’m in the US and you can’t say vit. E. It has to be listed as tocopherol.

Yes indeed. You are correct. The INCI listed ingredients for Burts Bees is cera alba (beeswax, cire d'abeille), cocos nucifera (coconut) oil, helianthus annuus (sunflower) seed oil, mentha piperita (peppermint) oil, lanolin, tocopherol, rosmarinus officinalis (rosemary) leaf extract, glycine soja (soybean) oil, canola oil (huile de colza), limonene.

However, for most of us small timers, the common nomenclature is sufficient and more user-friendly for the customers we serve:

Beeswax, coconut oil, sunflower oil, peppermint oil, lanolin, vitamin E, ROE, soybean oil, canola oil, limonene.

Others are free to disagree and make it more complicated than it needs to be. Speaking from experience, the INCI nomenclature doesn't fly when it comes to labeling handcrafted lip balms.. JMHO

 

[TheGecko]

I did a little more research and it would appear that legally, "Lip Balms" fall under 'drug' rules because it is deemed a 'lip protectant'. However, "Lip Butter" appears to be strictly a cosmetic.

I did run across this, which I hadn't seen before in my searches: Small Businesses & Homemade Cosmetics: Fact Sheet.

 

[AliOop]

Thank you so much for all the help! You’re right - my address is not listed on my website. Although, Mend is an LLC so our address is listed online with that. Do you think I still need it on the website?

I'm not positive about that, but it seems like it is "publicly accessible" as is required.

 

[TheGecko]

Thank you so much for all the help! You’re right - my address is not listed on my website. Although, Mend is an LLC so our address is listed online with that. Do you think I still need it on the website?

The FD&C Act requires cosmetic labels to identify the name and place of business of the manufacturer, packer, or distributor. By regulation, this includes the street address, city, state, and ZIP code, although you may omit the street address if your firm is listed in a current city or telephone directory. You may use the main place of business instead of the actual place where the cosmetic was manufactured, packed, or distributed, unless such a statement would be misleading.

If you use the distributor’s address, you must use a phrase such as "Distributed by" or "Manufactured for," followed by that firm's name and place of business. The name of the firm must be the corporate name. See the regulation on name and place of business at 21 CFR 701.12.

Because City or Telephone Directories are pretty much a thing of the past, the requirements are that your address MUST be publicly available. And since a lot of people wouldn't know where to search on a government website for that information (for Oregon it's the Secretary of State's website), and because not every small artisan business has a formal business structure or an 'assumed business name' or 'trade name' (or whatever your state calls them, you would need to have your street address listed on your website or publicly available social media account. By the latter, a person would have to be able to access that information without having to have an account. Simply put, I should be able to 'google' your company and find your business address.

Now the sentence about using the place of business as opposed to place of manufacturing is ONLY applicable if you have a brick and mortar store and in the United States.

 

[Virgogoddess]

Burt's Bees labels it Vitamin E and so do I! I know my customers, and my wholesale customers would ask, "What the heck is tocoherol?!" if that's what I put on my labels.

Well if you put vitamin e it puts you into a different category and you can check on the US website for labeling of cosmetics. Personally, I switched to tocopherol.