How to Label: Lotion

Here we are on the final installment of our labeling series. I hope you’ve found these helpful, easy to understand and a good starting point for entering into the world of producing retail-ready products. I’ve already shown you how to label a lip balm and cold process soap.

In this post, I want to talk about how you would label a handmade lotion and some particular things to look out for in regards to labeling lotion.

First thing to know – and this may seem obvious – is that the most dominant part of the label should be what the product is. This should be on the front of the product. So ‘Soap Queen Lotion’ should be written with the largest size font. Also, be sure that it is clear what the product is. For instance, if you want to call your lotion ‘cream’ or ‘body butter’ that is acceptable, but something confusing like ‘Soap Queen Gunkity Gunk’ would not be acceptable.

The ingredients should be listed in the order used, which I explain in more detail in the lip balm labeling post.

The quantity of lotion is different from soap and lip balm since it is a liquid (or at least not solid) so the amount needs to be listed as fluid ounces and milliliters which are volume measurements and not weight. Which also means you DO NOT write Net Weight in front of the measurement.

An example would be 6 fl. oz / 180 ml

A word about warning labels.

Many believe that since mold and bacteria can grow in a lotion that is incorrectly made that lotion must be labeled with a warning label. In my research of the laws as they are currently written, this is not correct.

Sec. 740.1 Establishment of warning statements.

(a) The label of a cosmetic product shall bear a warning statement whenever necessary or appropriate to prevent a health hazard that may be associated with the product.

The safety of lotion, when correctly made, has been established; therefore, a warning label is not required by law.

And on to the example!

For this example I am going to use the lotion recipe I posted way back in 2008, check out the original post here.

The ingredients as listed on the blog post are:

18 oz. Distilled Water
1.2 oz. Shea Butter
1.7 oz. Sweet Almond Oil
1 oz. Avocado Oil
1.2 oz. Emulsifying Wax
1 oz. Stearic Acid
.2 oz. Phenonip
.1 oz. Fragrance

And so, my ingredient list would look like this:

Ingredients: Water, Sweet Almond Oil (Prunus Amygdalus Dulcis), Shea Butter (Butyrospermum Parkii), Emulsifying Wax NF, Stearic Acid, Avocado Oil (Persea Gratissima), Fragrance, Phenoxyethanol, Methylparaben, Ethylparaben, Butylparaben, Propylparaben

Notice the Emulsifying Wax? I use Polawax which, like fragrance oil, is protected by trade secret laws and so the official INCI is Emulsifying wax.

And once again, if you like the labels I’ve used in my example, they are available as a free download from Bramble Berry. Now you’ll have a matching set!

If you’re still looking for more resouces, check out this great roundup of FDA Cosmetic law links on the Indie Business Network.

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54 Comments

  1. says

    Good Morning!
    I have been using the recipe listed above
    18 oz. Distilled Water
    1.2 oz. Shea Butter
    1.7 oz. Sweet Almond Oil
    1 oz. Avocado Oil
    1.2 oz. Emulsifying Wax
    1 oz. Stearic Acid
    .2 oz. Phenonip
    .1 oz. Fragrance

    But instead of avocado oil, I replaced with grapeseed, and I used Optiphen plus instead of phenonip, and unrefined shea butter instead of just shea butter. I used the optiphen at the 1% ratio for a 16 oz recipe.

    My question is, I just used some lotion that I made about a week ago, and it feels super soft, is the same consistancy, does not appear to have any mold or growths, but it looks like it leaves a kind of shimmer or sparkle, that I did not intentionally add. haha.
    What could be causing this?

    Second question,
    when the lotion bottle creates some condensation, does the optiphen still protect from this moisture over time?

    Thank You!!

    • says

      Hi Tara!

      That recipe sounds great! The optiphen in your lotion is a paraben and fromaldehyde-free preservative, so it will protect your product from moisture in the bottle. However, we recommend keeping your caps off of your lotion bottles while it cools to help the condensation evaporate up and out from that bottle.

      As far as the sparkle you are experiencing, the ingredients you are using should not give your product any shimmer. My best guess is that some ingredient you are using may have come in contact with a mica, giving your lotion a bit of a shimmer.

      I hope this helps! We would love to see your lotion on our Facebook page! :)

      https://www.facebook.com/BrambleBerry

      -Amanda with Bramble Berry

    • says

      Hi Tara!

      You can substitute out the Avocado Oil for the Grapeseed Oil and if you want to use the Optiphen Plus instead of the Phenonip, you can. Just make sure you are staying within the recommended usage rate for your preservatives. Let us know how your batch turns out! =)

      -Becky with Bramble Berry

  2. Carolyn says

    Hi,
    I am thinking about making a whipped shea butter lotion and have researched and heard that sellers are not allowed to make claims(moisterizing, healing, etc.). Would I be allowed to advertise the benefits of using shea butter? Like say that it may help reverse aging process? Thanks!

  3. Michelle says

    I am reading all the comments and have read your information regarding labeling and it’s great. I come with a question however. Regarding challenge testing creams, I am only beginning with my small company and do not have the money to challenge test. My cream is 100% concentrated, no water and I read on your website one of your creams is as well and so does not need any preservative. Would this hold true for any concentrated cream? Also, if we add fragrance oils/essential oils, does that change the answer?

    Also, I am in the process of forming an LLC for protection purposes as well. Regarding insurance, would you still suggest purchasing cosmetic insurance as secondary protection? I am in the process of differentiating between the protections both would offer. Any suggestion would be helpful!

    Thanks! :)

  4. Brittanie says

    Also, does labeling in fluid ounces also apply to the whipped shea butter recipe you have posted? Or should that still be labeled in net weight? I can’t decide since it’s not really liquid like a lotion, but not solid like a soap

    • says

      Good morning, Brittanie!

      If you are making a thick cream or lotion, your would label your product with fluid ounces, but if you are making a salve or balm, you would go with weight. In your case, it can be either. I personally would not consider it a lotion but more of a balm. I hope this helps! =)

      -Becky with Bramble Berry

  5. Brittanie says

    Thank you so much for these helpful posts!

    There is a lot of confusing information on the web, I’m so glad I can come here and get the simple facts.

    Do you think it’s a good idea to put something like “Discontinue use if irritation occurs” just to protect yourself from a sue-happy individual that might be allergic to almond oil for example?

    • Anne-Marie says

      That’s an interesting question and I’m not a lawyer so keep that in mind.

      This is exactly what insurance is for. You cannot possibly guard against everything that people can do with your lotions (where they put it, how they use it). It’s also difficult to guard against stupidity. Most people, if something was causing a rash, would naturally quit using it. But, for the .5% that don’t, there’s insurance. If you haven’t purchased insurance, here’s an article about it and resources to do that:

      http://www.soapqueen.com/business/business-insurance-for-the-handcrafted-industry/

      Sadly, you’re right – people can be sue-happy and just like wearing a seatbelt to protect yourself against other drivers, it’s important to protect yourself and your assets against misuse of your product or individuals that do not read your ingredient label.

      Your label is small – and its real estate is precious. Only you can determine if you’ll sleep better at night for having that warning label on it. I generally look at ‘best practices’ from the ‘big guys’ and since most of them don’t have something like that on their bottles (and they are arguably bigger lawsuit targets than you), I’d buy comprehensive insurance, label your products properly and follow all laws for manufacturing and labeling and sell with confidence. But, that’s me and my tolerance for risk may be slightly higher than yours. I 100% would never sell without insurance though – so maybe I am risk averse =)

  6. Debbie says

    Want to start selling my scrubs and lotions to the public. I’ve researched and think my labeling is where it needs to be. I want to obtain insurance coverage but have read that it’s very hard to get when it’s a home business. Any suggestions?

  7. says

    I have been told that handmade lotions must be challanged tested in order to sell, and it is a felony to sell comsmetic products that have not been tested. Is this true?

    • says

      Hi Tricia!

      The only time you ever need any of your products to be tested is if you are claiming that it heals or cures something. For instance, you can’t claim that your product cures skin cancer or eczema or it would have to be tested. Any other product that doesn’t have a claim does not have to be tested. I hope this helps! :)

      -Becky with Bramble Berry

        • says

          P.S. It is a felony to sell an ‘unsafe’ product. Example: you deliberately put battery acid in your product.

          It is NOT law that they need to be challenge tested prior to selling but we highly recommend it for insurance purposes and peace of mind.

          We use Sagescript (Cindy Jones) for all our challenge testing and we find her to be professional, knowledgeable and responsive. Challenge testing runs $600 or so. All lotion recipes on this blog have been challenge tested to ensure the preservative system is working under normal conditions

  8. Jacqui says

    Hi, I have just started creating a lotion with my brother and we are now getting our hands involved with labeling. I appreciate your blog post. Would you know what type of a process it would take to state your lotion is for ezcema or psoriasis through the FDA? even cost?

    • says

      Hi Jacqui!

      Technically, that is a drug claim and the FDA would consider this a drug with that claim. That’s why you often see people saying things that imply that their product does something but don’t come right out and say it. With a claim like that, every batch of lotion would have to be tested which can reach upwards of $1000 or more per batch. We often share recipes and products that have been known to help with certain skin issues, but we cannot claim that they are for those specific skin problems because it would then be considered a drug. I hope this helps!

      -Becky with Bramble Berry

        • says

          Good afternoon, Lena!

          I know when describing your product it can be difficult not to make a claim. Making claims is a fine line to walk, so we always recommend erring on the side of caution. If you say that it cures or heals with any specific disease, then it must be tested and proven to do that and approved by the FDA as that would be considered a drug claim. Even saying that a product “is great for” may be construed as instruction to use the product for a specific condition, thus making it a claim.

          Basically, if a customer reaches the conclusion that your product will help any medical condition they have based on the wording on your package or website then you have made a medical claim.

          I know how confusing it can be, but we are here to help you out. A great book on this subject is the book Soap And Cosmetic Labeling Book by Marie Gale. It goes over how to label any and all of your products with clear and understandable language. You can find it on Bramble Berry’s website here:

          http://www.brambleberry.com/Soap-And-Cosmetic-Labeling-Book-1-Book-P3663.aspx

          I hope this helps! =)
          -Becky with Bramble Berry

          P.S. Here is a link to a great article on this very subject from Marie Gale’s blog:

          http://blog.mariegale.com/fda-cracking-down-on-cosmetic-product-claims/

  9. says

    Hi Becky, In the BB booklet on lotion labeling it states there are 5 or 7 different acceptable editions of labeling .I’ve been labeling according to the 5th I think ,only the common name of each ingred. in desending order is this accepable?

    • says

      Hi Carolyn!

      Labeling according to the 5th Edition is perfectly acceptable, and if it has you listing each name in descending order, you can do that. When we label, we like to use the INCI (International Nomenclature of Cosmetic Ingredients) names as do other soapers, but as long as you are following an acceptable edition for labeling, you are going to be just fine! :)

      -Becky with Bramble Berry

  10. says

    Do you label lotion bars the same way as you do lotions? Also, how do you label shampoo/conditioner, liquid soap, M+P soap, mineral makeup, and bath fizzies? Thanks for the help Anne-Marie!

  11. says

    Bless you Soap Queen!

    I have been searching and searching for tips on how to label lotions, and reading the FDA site instructions is giving me a migraine! Thank you for this information in simple easy to understand english! I can now expand my line and make many customers very happy!

  12. says

    If I put on my lotion bottle or if in advertising I state that my lotion relieves dry skin would i have to have it registered through the fda as a drug?

    • Anne-Marie says

      Technically, that is a drug claim and the FDA would consider this a drug with that claim. That’s why you often see people saying things that imply that their product does something but don’t come right out and say it.

  13. Kathy Mitchell says

    Hello,
    I have a question on labeling a pre-made lotion base. If I purchased BB lotion base and scented,colored, and packaged myself do I need to add made by Bramble Berry or can I just add my company information to the label?
    Thank you!

    • says

      That is a great question! You are taking ingredients and combining them to make a new product. It doesn’t matter that one of the ingredients is a pre-made base. You would just put your info on the label as the manufacturer.

  14. Lee Douglass says

    How do you measure fluid oz? I have 4 oz bottles, if I fill them does that mean 4oz?

    • Anne-Marie says

      I use the Waterproof Inkjet label stock that we sell at Bramble Berry. It’s a nice bright white – comes in a full size sheet so I can cut down my labels to any size and they are very resistant to smudging.

  15. Georgina says

    Thank you for this recipe & the available lotion label on your website. You think of everything and it’s super appreciated !!!

  16. Georgina says

    Stearic Acid ~ Can someone please tell me how to dissolve it ? Is it dissolved in water? I tried adding it to oils & it did not dissolve. I would appreciate instructions on how to dissolve it for use. Many thanks

    • Rachel says

      Hi Georgina,

      Add the stearic acid to the oils and melt in a double boiler until the stearic acid, emulsifying wax, and any butters are melted.

      Hope this helps.

      Rachel

    • says

      Rachel’s technique is the best and safest. But you can also add it to some of your oils and microwave it to get it to melt completely. The granules are very wax like and do take a little longer to melt.