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A cream is a different kind of product from a drink powder. It goes on skin and is judged by feel and scent. Many creams are cosmetics, but claims and intended use can bring other rules into play. If you are choosing a premade cream to sell under your brand, these questions will save you from surprises.
Twelve questions to ask
| Question | Why it matters |
|---|---|
| 1. What is the full ingredient list? | Customers with sensitive skin will ask, and you need it for the label |
| 2. What does the product do, in plain cosmetic terms? | Words like moisturize and soften are about look and feel |
| 3. What can I not say about it? | Some claims turn a cosmetic into a drug in FDA's eyes. See below |
| 4. Is it scented, and with what? | Scent is personal. Scented and fragrance free products attract different buyers |
| 5. How does it feel ten minutes after use? | Greasy, tacky or dry matters more than the first touch |
| 6. What size is the jar and how much does it hold? | The net quantity goes on the label and helps set your price |
| 7. Is there an inner seal or liner? | Customers expect a product that looks untouched |
| 8. How should it be stored, and how long does it keep? | Heat can change a cream. You need to know before summer shipping |
| 9. Whose name will be on the label? | That company takes on duties. See below |
| 10. Which documents come with the batch? | Ask. Do not assume |
| 11. What is the smallest order, and how do reorders work? | So your second order is not a new project |
| 12. Will I be told if the formula changes? | Your label and your customers depend on it |
The line between a cosmetic and a drug
FDA explains that a cosmetic is meant for cleansing, beautifying or changing appearance. A product meant to treat or prevent disease, or to affect how the body works, is a drug. What you claim helps decide which one you have. FDA's page Is It a Cosmetic, a Drug, or Both? says claims on labels, in advertising and online can make a product a drug even when it is sold as a cosmetic. Its examples include claims that a product will reduce cellulite or regenerate cells.
A product name is part of the label, so it counts too. Before you settle on a name or a tagline, ask whether it promises more than a cosmetic can.
Whose name is on the jar?
Under the federal cosmetics law known as MoCRA, FDA defines the "responsible person" as the manufacturer, packer or distributor whose name appears on the label. FDA lists duties for that company. They include listing products with FDA, keeping records that support the product's safety, and reporting serious adverse events within 15 business days. FDA also says certain small businesses are exempt from some of the requirements.
If your brand will be the name on the label, ask your manufacturer how these duties are handled, and get advice on which ones apply to you.
What the label needs
FDA's Cosmetics Labeling Guide puts the product identity and the net quantity on the front panel. The ingredient list, the business name and address, directions and warnings go on an information panel. If the named company is not the manufacturer, its name must follow words such as "Distributed by". A small jar has a small label, so plan the layout early.
Test a sample properly
- Use it yourself for a week or two, at the times your customer would.
- Note the scent when you open the jar, and again after an hour on skin.
- Check how it sits under sunscreen or makeup, if your customers wear those.
- Give it to a few people with different skin types. Ask what they would change.
- Stop if anyone has a reaction, and tell the manufacturer.
Pick a look that fits a cream
People who buy creams read labels closely. Calm colors, clear type and an honest product name do well. Loud artwork that suits a candy flavored drink can feel out of place on a face cream.
Creams at OSM
OSM's white label range includes premade creams that carry your label, and you should ask OSM for the confirmed product facts before preparing your complete label. See the separate cosmetic label guide. Custom creams and lotions are handled through manufacturing. Ask OSM which creams are currently available, and ask for the ingredient list of any product you are considering.
Common questions
Does FDA approve a cream before it is sold?
FDA's fact sheet for small cosmetics businesses says cosmetic products and ingredients, other than color additives, do not need FDA approval before they go on the market. It also says that if you manufacture or market cosmetics, you are legally responsible for their safety and labeling.
Can I call my cream "anti aging"?
Be careful. Words about how skin looks and feels are cosmetic territory. Words about changing how skin works move toward drug territory. Get a qualified review before you print.
Can I add my own fragrance to a premade cream?
Not to a finished product. That would be a custom project.
