Clear, concise and compliant

Part of this consumer evolution means that consumers are more aware of ingredients that may be undesirable, either due to personal choice or potential undesirable effects caused by specific medical predispositions. The industry has also experienced a trend towards products containing ingredients considered more desirable, such as those that are ‘natural’ and ‘organic’. Consumers have also become more aware of the advertising of products and label claims on packaging. With the explosion of the digital space, the modern consumer has access to many more information than ever before on what is acceptable or not, and an increased appetite to question any claims made by brands.

To meet consumers’ expectations while complying with regulatory requirements, companies placing cosmetic products on the market should have an awareness and understanding of standards, guidelines, regulations and best practice within the South African context. As an industry association, the Cosmetic, Toiletry & Fragrance Association (CTFA) advises on such matters. It also promotes the responsibility that companies have in providing accurate and compliant label information on packaging.

Minimum labelling requirements

A number of aspects pertaining to labelling should be considered, including the requirements outlined in the Department of Health’s (DOH) draft Regulations Relating to Labelling, Advertising and Composition of Cosmetics, Government Notice R 1469; SANS 98: Ingredient labelling of cosmetic products; Advertising Code of Practice; SANS 289: Labelling Requirements for Pre-packaged Products (pre-packages) and General Requirements for the Sale of Good subject to Legal Metrology Control; Legal metrology Act; etc.

The Government Notice R 1469 draft Regulations Relating to Labelling, Advertising and Composition of Cosmetics (DOH Draft Regulations) Regulation 8: Labelling outlines and lists the requirements for the primary and secondary package of a cosmetic product.

The primary container or packaging should contain the following information:

• name of the cosmetic

• country of origin for imported cosmetics • date of minimum durability

• batch number or lot number of the product

• function of the cosmetic (unless it is clear from the presentation)

• particular precautions and warning statements to be observed in use, where applicable, and at least those listed in Annexes I, II, III, IV and V.

The secondary container or packaging should contain the following:

• the name and business address of the responsible person

• the nominal content at the time of packaging declared by weight or volume

• the list of ingredients according to INCI nomenclature.

Ingredient listing

The ingredient listing is vital, as it provides the consumer with information on the content of the product. Although the DOH Draft Regulations take precedence over other guidelines, the South African Bureau of Standards also outlines labelling requirements in SANS 98. As a minimum requirement, the ingredient listing must be present on the label preceded by the word, ‘ingredients’.

Provision is made for smaller packages, allowing the information to be included on an attached leaflet, label, inlay, tape, tag or card (as per Regulation 8.3 of DOH Draft Regulations), either enclosed with the cosmetic, or on a notice in close proximity to the container in which the cosmetic product is exposed for sale (as per SANS 98).