Cosmetic packaging - what Startups should know before launching a product

Packaging and labelling are two extremely important components to cosmetic marketing. Not only must manufacturers, marketers and supply chain vendors all come together to agree on the most efficient type of containers, they must also be very conscious of government regulations and industry standards. Here's a simplified summary of what cosmetic startups can expect.

For a startup in the cosmetics industry, it is vital to be able to sell a product on a world-wide scale to be able to materialize on on initial investment and product development cost. Also to benefit from the economies of scale, a global focus increases the possibility to amortize investments and to reduce costs per unit.

Meeting Standards and Regulations

Commercial standards are set by the International Organization for Standardization (ISO). It is advantageous that commercial cosmetic products, whether they are free samples or for sale, conform to ISO 22715, which relates to packaging and labelling. While ISO 22715 is not legally binding, it is however, the common denominator of most of the national regulations that apply to the packaging and labeling of cosmetic products. Country regulators refer to ISO standards as guidelines to best practices for the various sectors for which they apply. Often, in order to comply with a local regulation, an individual, business or manufacturer must comply with the applicable ISO standard(s).

In many cases national regulations are more strict than international standards. Toothpastes and oral rinses, however, should also comply with ISO 11609 and ISO 16408 in addition to ISO 22715 compliance.

To get a deeper understanding of the legal requirements in USA and the European Union, please read:

For the EU: What you should know when packaging cosmetics compliant to EU regulations
and
For the USA: What you should know when packaging cosmetics compliant to FDA regulations

Some requirements apply to primary packaging, while others apply to secondary packaging. Products must position required information on their primary and secondary packaging in an indelible, easy-to-read language appropriate for the country where it is available for sale or free distribution. Precautions and warnings must be printed on primary and secondary packaging.

Role of Cosmetic Containers

storage of the product
protection of the product against damage or deterioration from marketing through consumption stages
labelling that describes the function of the product unless presentation is clear
listing of nominal content at the time of packaging according to weight and volume
tracking of manufacture batch number, date, or any identifying reference
precautions and warning statements, when appropriate
instructions for how to use, when appropriate

Information Required on Packaging

Essentially, labels must contain a wide variety of content and safety disclosures so that consumers know what they are buying. Anytime packaging obscures product visibility - whether the package is too small for text to be read or the product isn't obviously seen - a tag or leaflet must be added with the appropriate information.

Otherwise, the ingredients of the product, along with instructions, warnings and contact information must be clearly displayed on the package. Here is essential information required to be listed on packaging:

name and address of the person responsible for placing the product on the market
ingredients over 1% must be listed first in descending order of weight
ingredients under or equal to 1% must follow in any order
perfumes and aromatic compositions can be listed as one ingredient
number of units in the pack unless visible to the consumer
products containing several color shades must list all colorants preceded by "+/-" or "may contain"

Requirements for Primary Packages

Ingredients must be visible to the consumer at the point of sale. Whenever the lack of this information is confusing and may lead to inadvertent misuse, it must be indicated on the primary packaging. Otherwise, these elements can appear on secondary packaging. Information that identifies the product may be indicated on the primary packaging if it is visible before opening the secondary packaging.

Requirements for Secondary Packages

Secondary packaging contains one or more primary packages that include any protective materials. The outermost packaging is considered to be the secondary packaging that holds or contains the package at the point of sale. Ingredients, precautions, warnings, storage conditions and function of the product all need to appear only on secondary packaging, unless the information requires more clarity, which requires a listing on the primary package.

Business contact information including the person responsible for putting the product on the market, nominal content at the time packaging and instructions can appear on the secondary packaging only. Products in packages of 10 g or 10 ml and below do not require nominal content information.

Free Samples

Often, opening the cosmetics market for a startup is related with the distribution free samples to attract initial customers. Those free samples are also a means for stores to test whether a product finds positive feedback among their customer base and consequently, whether the products are worth distributing.

Free samples have slightly less strict requirements than the normal for-sales product. Their packaging should at least inform about name of the person or entity which distributes the product in the concerned market and information on the market precautions and risks, appropriate use (if these instructions are appropriate).

In any case, manufacturers or disitributors, placing samples in the European Union to test out the market must not forget to give notification of their cosmetic products via the EU Cosmetic Products Notification Portal (CPNP)

Conclusion

In addition to the ISO, location-specific regulations may apply, depending on FDA rules or the corresponding EU standard. In these regulations, additional requirements are prescribed which mainly concern health and safety issues. Other requirements to meet industry standards may apply to certain packages, depending on size. Information on product durability should be listed when appropriate. But following the ISO 22715 will allow to streamline packaging and labelling activities and thus to reduce effort, cost and time to market.