Packaging and Labeling•
Posted on October 08 2021
PACKAGING AND LABELING
This blog is by no means directions or legal advice on how to properly label products or a directional on what should be in there. Please refer to your country’s specific regulations and websites and legal team to find that information.
For the United States the labeling instructions can be found at Compliance FAQs: Packaging and Labeling in the US | NIST. The website has links to various locations where you can find more detailed information on labeling and packaging requirements.
Please consult your company’s legal team in terms of what verbiage should be on your products.
With that being said, this blog is more about what some of the labeling verbiage means and some guidelines for consumers in terms of reading labels. Hopefully, by reading through this blog, consumers can better understand what the labels mean and why some verbiage is listed the way it is.
What is meant by labeling verbiage is when you read a label that is made for children, but it has “Please keep out of reach of children.” Why if that product is safe for kids does the warning exist on the product? The warning is not saying that the product is unsafe for kids to use, it is the company covering their assets, preventing lawsuits when kids, as curious as they are, get a hold of a product and consume more then they should and have an adverse reaction to the product. The warning puts the onus back on the consumer stating that although it is safe, excessive consumption can cause medical issues therefore please put the product in a location where accidental “overdose” cannot occur. With that label, the company is better covered in terms of legalities if a child does accidentally get a hold of the product and uses more then is recommended.
You will often see next to that warning, “Parental supervision required” “Do not consume more then is recommended” or “Use only as recommended.” These three are under the same idea as the “Please keep out of reach of children.” Again, the company is not saying that the product is dangerous to kids or consumers, it merely putting the onus back on the parent/consumer to follow the directions to prevent any harm.
The “Do not consume more than is recommended” or “Use only as recommended” is also for adults in terms of abusing products that could cause adverse effects on the body or residence. Some herbs or products when used in excess can cause a permanent or semipermanent change in the body or products that are misused can cause damage to various items in the residence. Hence, the warning puts the onus on the consumer to not misuse the product and if they do misuse the product the liability and damage from the misuse is on the consumer and not the company. This is also why you will find “Do not spray directly into eyes or flame.” Although, commonsense to some, it prevents companies from having undue lawsuits from somebody misusing their products.
Herbal products have their own regulations that companies need to keep in mind. The FDA has made it clear that unless the owner of the company is a doctor or physician the company/owner cannot make a claim that the remedy, tea, herb can cure anything. Hence, you will often find in herbal companies that they either describe the origin of the herb or history of it or have the verbiage of “has the ability to,” “can help,” “may assist” to make it clear that in no way is the business/owner stating the herb will do something. Hence, you will also see the verbiage “This information has not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease. For educational purposes only.”
Keeping along those lines, you might also find the verbiage of “Please consult a qualified practitioner or doctor before using products, particularly if you are pregnant, nursing or on any medication.” Or “This product may slow or increase absorption of orally administered drugs. We recommend that you consult with a qualified healthcare practitioner before using herbal products.” These warning labels helps to prevent undue lawsuits from people having adverse reactions between their medication and herbal products.
The labeling requirements for the U.S. require that the company clearly state on the label what the product is. For example, “Peace and Safety Spray” “Furry Friend Salve.” Both clearly state what is being bought. This makes it so the consumer is clearly informed on what is being purchased.
The quantity amounts are required to be listed in metric. A business can have both imperial and metric measurements, but NIST/FDA requires metric to be on the label. It will normally be found at the bottom portion of the label.
Before I start on this one, please consult your legal team for the proper labeling of your products. In terms of quantity only those ingredients that are more then 2% of the total amount are required to be listed. If you have a 10ml rollerball bottle and use two different oils, since both oils would be measured at more the .2ml they are required to be listed. The standard drops for essential oils to fill a 10ml rollerball is approximately 10 drops for children or 15 drops for adults. Again, if your essential oil measure out to more than .2 drops or .3 drops then the essential oils is required to be listed. The only times the ingredients are not required to be listed is if the owner/company has a patent or it is a proprietary blend on that specific product. But companies must be extremely cautious on this and should consult their legal teams before leaving out ingredients.
In the United State ingredients are always listed by quantity starting out with the largest quantity to the smallest quantity. For example, with a salve if you use 2oz of beeswax, 6oz of mango butter, 3oz of shea butter, 1.5oz of avocado oil infused with 10gm of peppermint, 8gm of rosemary, and 5 grams of thyme the ingredients can be shows as: Mango butter, Shea butter, Bee’s wax, Avocado oil infused with Peppermint, Rosemary and Thyme. The easiest way to remember the formula is: the first ingredient listed in the product is the ingredient the product has the most of and the last ingredient listed is the ingredient that is in the product the least.
For those companies that follow me or are reading this, please feel free to add comments on my Instagram posts in terms of what you have found in terms of labeling your products and the specific verbiage/regulations required. I would love to hear from international companies as well. The Instagram post can be found with the following image:
Just click on the companies icon and scroll to that post.
For consumers, please feel free to leave comments on my Instagram post. If I can’t answer the questions hopefully one of the other businesses that follow me will be able to.
I just want to reiterate that a business/owner should always consult with their country’s specific regulations and the company’s legal team before making changes or creating labels. This blog is by no means a legal guideline or advice for how to, merely an informational of what I have learned from researching and doing my company’s specific labels.
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