Keeping Beauty Packaging Beautiful (In Spite of the Regulations)

Here are a few regulatory points that may affect your packaging designs.

WRITTEN BY: Holly Young

AUTHOR BIO: Holly Young is president of H+Y Regulatory Graphics Consultants. She has worked in the cosmetics packaging industry for almost 40 years, and is the recipient of numerous awards.

Your business is the business of making your customers look, smell and feel beautiful. Your packaging must communicate this message and hold true to your overall brand image. And it seems that many of the regulations for your product packaging are not designed to help the “beauty” concept.

For all of the SPF/sunscreen products sold in the U.S., holding true to your successful brand image and keeping within the regulations is about to get a little tougher. Looming over the horizon is the new Proposed Sunscreen Monograph, 21 CFR Parts 310, 352, 700 and 740. While this regulation has been delayed, sidetracked and then delayed again, this major regulation is scheduled to be approved in May 2010. Once a regulation is approved, the deadline for implementation is usually 18 to 24 months later.

A key factor to remember is that in the U.S., SPF/sunscreen products are considered OTC drugs and therefore strictly monitored by the FDA. Every brand that has any type of product, from beach lotion to face makeup to lipstick to moisturizer, that makes an SPF or sunscreen claim, is subject to this new regulation. There are many facets to this regulation, much of which involves testing and the chemistry of your products. But a considerable portion of this regulation is dedicated to how your packaging looks and what it communicates to your customer.

Following are a few key points that will affect your packaging and possibly your brand image.

First, the front of your outer package, which is the area of the package that is visible to the consumer at the time of purchase, will have to include a designation for both the UVB (SPF) and the UVA levels. The proposed monograph shows the UVA levels to be indicated by a 4-star system with specific text for each level. There are stipulations on the size, placement and coloring of both the UVB & UVA designations. There is a long statement about the significance of UVB & UVA rays that must also appear on the front.

The rest of the outer package must contain the Drug Facts Panel, with type size and spacing stipulations, a ruled box enclosure with do’s and don’ts, and a myriad of other graphics regulations. There is also very specific text that must be used within the Drug Facts Panel.

Cosmetic-drugs such as acne, dandruff and antiperspirant products already have the Drug Facts Panel on the package. For these companies and the beach products companies, this type of regulation is not such a new concept.

My concern is that most beauty companies are not used to this type of labeling regulation and will find this rather challenging. Working these new regulations onto your packaging while preserving your magnificent brand image is critical. Starting now and getting your brand aware of this pending regulation will move you toward solutions, and your brand will come out ahead, looking magnificent as always.