Unusually shaped or packaged beauty products often leave little or no room for ingredients labeling. Some confusion has therefore resulted about the ingredient labeling requirements for such products.
In its newly published guide Health Canada said manufacturers must comply with the labeling provisions in Cosmetics Regulations.
To meet the requirements, companies making cosmetics with unconventional packaging may have to turn to innovations such as accordion, peel-back and shrink-wrap/cello labeling.
On account of their size, small containers may not be able to comply with the requirements of section 18 (b) of the Cosmetics Regulations, which requires labeling text to be legible.
In this case section 21.5 (1) states that a tag, tape or card should be affixed to the product to accommodate a legible label. However, ingredient list tear-away pads at point of sales are not acceptable under the Canadian labeling laws for these types of cosmetics.
Examples of products that often fall into this category are eyeliner pencils, lipsticks and nail enamel.
The provisions are similar for ornamental containers such as decorative perfume bottles that have no promotional or advertising material on them other than a trade-mark or common name.
Under section 21.5 (2), the Cosmetic Regulations requires that an affixed tag, tape or card should be used in this case.
Non-existent or odd packaging
For cosmetics with no packaging or odd packaging an affixed tag, tape or card could be virtually impossible. This could be the case of loosely sold bath beads or soap, cut to size in store.
For these products, Health Canada said that under section 21.5 (3) an ingredient list on a tear-away pad, leaflet or sign at the point of sales would be acceptable.
To read the information sheet in full click here.