Do you notice what’s on your beauty labels?


Going shopping for your natural beauty products can be a lot of fun. After all, it’s exciting to try something new or purchase your favourite pampering delights.

But these feelings can quickly turn to overwhelm once you start looking at the labels. Why is there so much information in a tiny font that you can barely read? Is it necessary? Are you really expected to read and understand it all?

What makes it harder for you is that an international standard for labelling doesn’t exist. That means a product you purchase from Australia can have different symbols and phrases to a product you purchase from France, as they each need to comply with their own country/region-specific guidelines.

This post will help you understand the cosmetics labelling landscape for beauty products manufactured and sold in Australia.

Regardless of whether cosmetics are sold at local markets, online stores or retail stores, they must all follow the same regulations.

How are beauty products defined in Australia?

In Australia, beauty products are categorised as either cosmetics or therapeutic goods.

The main differences are that cosmetics (unlike therapeutic goods) must not prevent, alleviate, diagnose or cure any specific conditions, diseases, ailments, defects or injuries. They are designed to temporarily change your appearance or odour, or help to keep your skin in good condition.

For example:

A skin cream which helps to reduce the appearance of your redness from sunburn = cosmetic.

A skin cream which helps to relieve your redness caused by sunburn = therapeutic good.

The full definition of cosmetics is found here and therapeutic goods is found here.

{Hint: Therapeutic products have ‘Aust L’ or ‘Aust R’ on the label, followed by a number. Generally, Aust L products are for low-level therapeutic claims (e.g. over the counter complementary medicines) and Aust R products are for high-level therapeutic claims (e.g. prescription medicines). These types of products require a licence to manufacture, undergo a significant number of pre-market assessments, must have their labels reviewed and can take 3-5 years to develop from concept to launch.}

Who regulates cosmetics in Australia?

The main regulators are:

In addition to defining cosmetics and their uses, NICNAS assesses the risks associated with the importation, manufacture or use of industrial chemicals and manages the Australian Inventory of Chemical Substances (AICS).

Cosmetic manufacturers must ensure the natural chemicals or synthetic chemicals they use are allowed to be used in Australia. Further information can be found here.

This is a division of the Department of Industry, Innovation and Science and is Australia’s peak measurement body. They are responsible for biological, chemical, legal, physical and trade measurements.

Beauty manufacturers must comply with these standards when measuring raw materials and finished products, packaging final products and labelling final products.

This is the national competition regulator who oversees the Competition and Consumer Act 2010.

The ACCC are responsible for ensuring that businesses supplying beauty products comply with Australian competition, fair trading and consumer protection laws to provide a fair market place to trade and compete.

They also administer the Product Safety Australia website which provides information to help minimise the risks associated with unsafe products.

For beauty products, all claims must comply with Volume 3 Schedule 2 Sec 18 (Misleading and Deceptive Conduct) and Sec 29 (False or Misleading Representation).

Note: The ACCC are generally reactive and wouldn’t normally investigate the activity of individual cosmetic companies unless they receive an official complaint or the company previously breached legislation.

This Standard is set by the TGA and consists of decisions regarding the classification of medicines and poisons into Schedules, includes model provisions about containers and labels, a list of products recommended to be exempt from these provisions and recommendations about other controls on drugs and poisons.

The HSIS is an internet advisory service that provides information on the hazards of chemicals regulated by NICNAS in accordance with the Approved Criteria for Classifying Hazardous Substances [NOHSC:1008(2004] 3rd Edition.

This department, along with the Biosecurity Import Conditions System (BICON) oversees the importation of raw ingredients or finished beauty products.

They also assess organic certifying bodies, e.g. Australian Certified Organic (ACO) and once recognised as an approved certifying organisation, these bodies can perform compliance and quality management checks on behalf of the department.

What must appear on a cosmetics label?

The Trade Practices (Consumer Product Information Standards) (Cosmetics) Regulations 1991 prescribe the mandatory standard for cosmetics labelling in Australia.

The following are exempt from these guidelines:

  • Therapeutic goods within the meaning of the Therapeutic Goods Act 1989
  • Cosmetics manufactured in Australia for export
  • Free samples of cosmetic products
  • Testers of a cosmetic product

The mandatory components of a cosmetic label are:

  • Company business name and logo
  • Product name which clearly describes the identity/purpose of the product (e.g. facial cleanser). A product tagline is optional.
  • Volume or weight

Cosmetics fall under the National Measurement Institute’s Trade Measurement for Prepackaged Goods who have very strict requirements for the units, position, placement and size of the measurement.

Note: whilst some products are converted to and noted by their volume, the raw materials and finished product are measured by their weight using commercially-calibrated equipment in a temperature controlled and dust-free environment. This is the most accurate measurement system for product efficacy and to ensure consistency across batches.

Volumes and weight are not interchangeable. To convert liquids to weight, formulators multiply its volume by its specific gravity value. Specific gravity is defined as the relative density of a liquid or solid when compared to water, or the density of a gas in relation to air.

If the specific gravity of a liquid ingredient is less than 1, that means it is lighter than water.

  • Product description and claims

In order to comply with the Competition and Consumer Act 2010, all claims made about the product must be substantiated and the manufacturer must hold documentary evidence to support the benefits described.

For example, if a product purports to help reduce the appearance of wrinkles by 20% in 30 days, the manufacturer would need to document the testing and statistical methods used, how many test subjects were involved and their facial characteristics, the performance evaluation and testing protocol, and the tools used to measure wrinkle depth before and after the product was used.

Some claims you may see on your natural cosmetics are: Chemical Free, 100% Allergy Free, or promising to prevent, cure, alleviate or relieve a skin disease or skin condition such as eczema or dermatitis. These claims are all misleading.

All ingredients are a chemical and are either naturally or synthetically derived. Refer to the ACCC’s position on this.

It is also impossible to test entire populations for all allergies. And, unless you are manufacturing a therapeutic good in a licensed facility, you cannot imply that your cosmetic product prevents, cures, alleviates or relieves a skin disease or skin condition.

  • IngredientsIngredients present in concentrations of 1% or more are listed in descending order by weight. Ingredients in concentrations of less than 1% can be listed in any order.

The exception to this is colour additives, which can be listed in any order regardless of their concentration.

For information on product and ingredient toxicity, download the Environmental Working Group (EWG) Skin Deep app to your Android, iPhone, or PC.

  • Directions for use

The directions for use are usually derived from the outcome of efficacy or performance testing.

Note: they specify the maximum and not the minimum amount you can use.

This is particularly important to remember for serums or products that are highly concentrated or contain powerful actives. Taking an overzealous approach may do you more harm than good.

Always perform a patch test when trying a new product and even if you are familiar with the ingredients. The same type of raw material can be sourced from suppliers who use different processing methods and this can affect the material’s nutritive and chemical profiles. Depending on your level of sensitivity, these slight differences in profiles could have an undesirable effect on your skin.

  • Storage conditions

Manufacturers formulate and package their cosmetics under good manufacturing practice (GMP). Whilst the facility does not need to be accredited for cosmetics manufacturing, the facility and equipment are expected to be appropriately sanitised or sterilised, and the environment’s air quality and process water carefully monitored.

Additionally, the facility should be well ventilated, temperature controlled and dust-free.

The storage conditions are usually derived from the outcome of safety testing performed in the product’s final packaging.

These tests differ depending on the type of ingredients used and can include real-time and accelerated stability (shelf life) testing at different temperatures and humidities, microbiological (bacteria, yeast and mould) testing, preservative efficacy testing and assays.

Prior to being made available for sale, each product must pass these tests as defined by its release specifications.

{Hint: Whilst products should be able to withstand temporary and short-term deviations from the prescribed storage instructions, prolonged exposure to light, heat and air can cause active ingredients to significantly reduce and the pH to change, both of which could render the product dangerous to use. These changes can occur months before you notice any changes to the appearance, aroma, texture or viscosity.}

  • Warnings/Precautions

Specific risk and health phrases must appear on the label depending on the concentration of the ingredients used. The Standard for the Uniform Scheduling of Medicines and Poisons (SUSMP) and Safe Work Australia Hazardous Substances Information System (HSIS) outline the full list of risk and health phrases.

  • Expiry date

Expiry dates are determined by the results of real-time and accelerated stability (shelf life) testing.

For cosmetics, expiry dates are only required on the label when they contain a sunscreen (SPF) and have a shelf life of less than 3 years.

However, there is an unwritten rule that an expiry date be stipulated on products with a shelf life of less than 2 years.

Being mindful of expiry dates is critical as you cannot see bacteria with the naked eye.

{Side note: The Period After Opening date is only required by EU regulations when the shelf life of a product is more than 30 months. It represents the period in which the product is suitable for consumer use and looks like a container with a number and the letter ‘M’ on it. For example, 6M would mean you can use the product for up to 6 months from when it was opened.}

  • Name & Address of Packer

The National Measurement Institute’s Trade Measurement for Prepackaged Goods requires the name and physical address of the packer or the person on whose behalf it was packed to be stated on the label.

Websites and PO boxes can also appear, but not as a substitute for the physical address.

Optional information that can appear on a cosmetics label

  • Batch number

The batch number is useful for the product manufacturer to monitor sales, distribution and batch-specific issues.

  • Accreditation logos

In order to display an accreditation logo, the manufacturer must have a certificate or document from the accreditation body confirming the certification. In some instances, manufacturers would also be subject to audits.

  • QR code and/or barcode

 

I hope this information has been useful in helping you understand how cosmetic labels are prepared.

If there’s anything you’d like to know more about, please leave a comment below.

Geraldine Phua

Geraldine Phua believes you can define beauty on your own terms. This led her to create Geraldine Pierre Skin Care with a mission to empower you to be your confident and natural best, celebrate your individuality, and share your real, untampered beauty with the world.Inspired by Geraldine’s own 15-year pursuit of healthy skin and her companion Pierre, a stray Poodle adopted from a local animal shelter, Geraldine encourages you to embrace life the way he does: by living in the present, loving without judgement and exuding wholehearted enthusiasm.Her simple and all-natural product range is handmade in Australia, certified toxic-free by Safe Cosmetics Australia and accredited by PETA as cruelty-free and vegan. Geraldine also supports the Real Beauty Manifesto and the RSPCA’s Makeover the World global movement.Geraldine is qualified in Regulatory Affairs for cosmetics which enables her to provide you with information based on science, not hype.www.geraldinepierreskincare.com

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