Label Compliance Checklist: What FDA, CPSC, and FTC Require on Your Packaging

You picked the perfect bottle. You nailed the formula. Your label design looks great. Then a retailer rejects your product because your net contents statement is in the wrong spot, or the FTC flags your "recyclable" claim as deceptive, or you find out your essential oil needs a child-resistant cap you never ordered.

Label compliance is where most first-time brands get blindsided. Three federal agencies govern what goes on your packaging, and each one cares about different things. The FDA regulates what information appears on cosmetic, drug, and food labels. The CPSC dictates which products need child-resistant packaging. The FTC polices environmental marketing claims like "recyclable" and "made with recycled content." Miss any one of them, and your product can be pulled from shelves, hit with fines, or blocked from retail altogether.

This is the checklist. Every requirement that applies to the bottle or jar sitting on your desk right now.

What the FDA Requires on Cosmetic and Personal Care Labels

The FDA enforces labeling requirements under 21 CFR Part 701 and the Fair Packaging and Labeling Act (FPLA). If your product is a cosmetic (skincare, hair care, soap, fragrance, makeup), these rules apply to you. If it makes a drug claim ("treats acne," "reduces wrinkles"), it falls under stricter drug labeling rules as well.

The Modernization of Cosmetics Regulation Act (MoCRA), signed into law in December 2022, expanded FDA authority significantly. MoCRA is the biggest change to cosmetics regulation since 1938. Enforcement ramped up through 2024 and 2025, and brands that have not updated their labels are now exposed.

Principal Display Panel (PDP)

The PDP is the part of the label consumers see first when they pick up the product. The FDA requires two things here:

Product identity. The common or usual name of the product, like "moisturizing lotion" or "facial cleanser." This is not your brand name. It is a description of what the product actually is.

Net quantity of contents. This must appear in the lower 30 percent of the PDP. It has to be in both metric (mL or g) and U.S. customary units (fl oz or oz). For a 250 mL bottle, the label must read something like "8.4 FL OZ (250 mL)." The type size is regulated too: the FDA specifies minimum height based on the area of the PDP. For most bottles, that means at least 1/16 of an inch.

Information Panel

The information panel is the part of the label immediately to the right of the PDP (or to the left if the right side is obstructed). This is where the detailed stuff goes:

Ingredient listing. Every cosmetic must list ingredients in descending order of predominance, using INCI (International Nomenclature of Cosmetic Ingredients) names. Fragrance and flavor can be listed as "fragrance" or "flavor" without further breakdown, though MoCRA is changing this for certain allergens (see below).

Name and address of the manufacturer, packer, or distributor. A street address is required. A P.O. box alone does not satisfy this requirement. If you are the distributor (not the manufacturer), the label must say "Distributed by" or "Manufactured for" before your company name.

Warning statements. Certain products require specific warnings. Aerosol products need flammability warnings. Products not tested for safety must carry the statement: "WARNING: The safety of this product has not been determined." Coal-tar hair dyes require patch test instructions.

MoCRA Changes (2024 and Beyond)

MoCRA added several new requirements that many brands have not caught up with yet:

Fragrance allergen disclosure. The FDA is publishing a list of specific fragrance allergens that must be individually named on labels. This aligns U.S. requirements with European Union standards, where allergens like linalool, limonene, and citronella have been listed individually for years. The compliance timeline extends through 2025 and 2026.

Adverse event contact information. Every cosmetic label must now include a domestic phone number or electronic contact (like a website) where consumers can report adverse reactions. The company must then report serious adverse events to the FDA within 15 business days.

"Professional use only" labeling. Products intended for use by licensed professionals (salon-grade treatments, for example) must be clearly marked "For professional use only."

Facility registration and product listing. While this is not a label requirement per se, MoCRA now requires all cosmetics facilities to register with the FDA and list their products. This creates a paper trail that ties back to what is on the label. If the label says one thing and the product listing says another, that is a compliance problem.

Cosmetic bottle label showing FDA-required ingredient list and net contents

What the CPSC Requires: Child-Resistant Packaging

The Consumer Product Safety Commission enforces the Poison Prevention Packaging Act (PPPA) under 16 CFR Part 1700. If your product contains certain substances, it must be packaged in child-resistant containers.

Products That Require Child-Resistant Packaging

This is not optional. The CPSC maintains a specific list under 16 CFR 1700.14 of substances that must be in child-resistant packaging. The categories most relevant to packaging buyers include:

Household chemicals. Furniture polish, paint solvents, turpentine, methanol, ethylene glycol (antifreeze), and products containing more than 10 percent hydrocarbons by weight.

Pharmaceuticals and supplements. Most prescription drugs, OTC medications containing aspirin, acetaminophen, ibuprofen, iron-containing supplements (with more than 250 mg of elemental iron per container), and dietary supplements with iron.

Essential oils. Products containing methyl salicylate (wintergreen oil) at concentrations over 5 percent require child-resistant packaging. In California, stricter rules apply: AB 2527 requires child-resistant caps on essential oil bottles containing specific chemicals, including eucalyptol, camphor, and certain other constituents. We covered this in detail in our guide on whether essential oils need child-resistant caps in California.

Caustic substances. Drain cleaners, oven cleaners, and products with a pH above 12.5 or below 2.0.

What "Child-Resistant" Actually Means

A child-resistant closure is not just a tight cap. It must pass testing protocols defined in 16 CFR 1700.20. The test requires that 85 percent of children aged 42 to 51 months cannot open the package in a five-minute test period, while 90 percent of adults aged 50 to 70 can open and properly reseal it.

Common child-resistant closure types include press-and-turn caps, squeeze-and-turn caps, and push-down-and-turn mechanisms. If you are ordering bottles for a product that requires CRC packaging, you need to verify that the specific closure has been tested and certified to ASTM D3951 or the CPSC protocol. Ask your supplier for test documentation.

"Senior-Friendly" Exemptions

The PPPA allows consumers to request non-child-resistant packaging for their own purchases (this is why pharmacies ask if you want an easy-open cap). But the manufacturer's default packaging must still be child-resistant. You cannot ship a product with a standard cap and include a note saying "keep away from children."

Child-resistant press-and-turn cap compared to standard screw cap

What the FTC Requires: Environmental Marketing Claims

The Federal Trade Commission regulates environmental marketing claims through the Green Guides (16 CFR Part 260). If you put "recyclable," "made with recycled content," or "eco-friendly" anywhere on your packaging or marketing materials, the FTC has rules about what you can and cannot say.

This matters especially for brands using PCR (post-consumer recycled) packaging. Making claims about recycled content without proper substantiation can result in enforcement actions.

Recyclable Claims

Under Section 260.12 of the Green Guides, you can only call your packaging "recyclable" if a substantial majority of consumers or communities have access to recycling facilities for that material. The FTC has interpreted "substantial majority" to mean at least 60 percent.

PET (#1) and HDPE (#2) bottles generally qualify for unqualified "recyclable" claims because curbside recycling programs accept them in most U.S. communities. But other plastics (PP #5, PS #6, PVC #3) are far less widely accepted, and an unqualified "recyclable" claim on those materials could be challenged.

The chasing arrows symbol (♻️) by itself is considered a recyclability claim. Many brands put the resin identification code inside the chasing arrows symbol out of habit, not realizing this can be interpreted as a recyclability claim. California's SB 343 (the "Truth in Labeling for Recyclable Materials" law) goes further: it prohibits the chasing arrows symbol on any product that is not actually recyclable in California's programs, regardless of the resin code.

Recycled Content Claims

If you claim your bottle is "made with recycled content" or "contains 30 percent PCR," Section 260.13 requires that the claim be truthful, substantiated, and not misleading.

Specify pre-consumer vs. post-consumer. Generic "recycled content" is vague. The FTC expects you to distinguish between pre-consumer recycled (manufacturing scrap that never reached a consumer) and post-consumer recycled (material collected from consumers after use). A "30% PCR" claim refers specifically to post-consumer recycled content and is the stronger environmental claim.

Have documentation. You need certificates or test results proving the recycled content percentage. Third-party certifications like GRS (Global Recycled Standard), SCS Recycled Content, or ISCC PLUS provide this substantiation. We wrote a detailed guide on how to verify recycled content certificates.

Do not overstate. If your bottle is 30 percent PCR and 70 percent virgin resin, do not call it a "recycled bottle." Call it a "bottle made with 30 percent post-consumer recycled plastic." Precision protects you.

"Eco-Friendly" and "Sustainable" Claims

The FTC's position is clear: broad, unqualified claims like "eco-friendly," "green," or "sustainable" are almost always deceptive because they are too vague to be substantiated. If your label says "eco-friendly packaging," you need to qualify what that means. "Bottle made with 30% post-consumer recycled HDPE" is defensible. "Eco-friendly bottle" is not.

PCR bottles showing recycling symbols and recycled content certification labels

The Combined Checklist

Here is everything in one place. Before you print labels, confirm each item that applies to your product.

Every product (cosmetic, personal care, household)

• Product identity (common name) on the principal display panel
• Net quantity of contents in the lower 30 percent of the PDP, in both metric and U.S. customary units
• Minimum type size for net contents based on PDP area
• Manufacturer, packer, or distributor name with street address on the information panel
• "Distributed by" or "Manufactured for" if you are not the manufacturer

Cosmetics and personal care specifically

• Full INCI ingredient list in descending order of predominance
• Fragrance allergen disclosure per MoCRA requirements (check FDA's published allergen list)
• Domestic adverse event reporting contact (phone number or website)
• "For professional use only" if applicable
• Any required warning statements (aerosol flammability, untested product safety, coal-tar dye patch test)
• "WARNING: The safety of this product has not been determined" if the product has not undergone safety substantiation

Products requiring child-resistant packaging

• Verify whether your product's formulation falls under 16 CFR 1700.14
• Use a CPSC-certified child-resistant closure with valid test documentation
• Confirm the closure fits your bottle's neck finish (CRC closures use specific thread patterns)
• Check state-specific requirements (California AB 2527 for essential oils is stricter than federal rules)

Environmental marketing claims

• "Recyclable" claim only if the material is accepted by at least 60 percent of U.S. communities
• Chasing arrows symbol only if the product is genuinely recyclable in practice, not just in theory
• Recycled content percentage specified as pre-consumer or post-consumer
• Third-party certification documentation (GRS, SCS, ISCC PLUS) on file
• No unqualified "eco-friendly," "green," or "sustainable" claims without specific substantiation
• California SB 343 compliance if selling in California (no chasing arrows on non-recyclable items)

When Your Packaging Supplier Should Be Part of This Conversation

Most compliance failures are not legal mistakes. They are communication gaps. The brand designs a label, the supplier ships bottles and caps, and nobody confirms that the closure type matches the regulatory requirement for the product inside.

If your product needs a child-resistant cap, your bottle's neck finish needs to support one. Not every bottle accepts CRC closures. A 24-410 neck finish has different CRC options than a 28-400. If you are ordering bottles and closures separately, you need to verify compatibility before placing the order, not after your labels are already printed.

The same applies to recycled content claims. If you want to label your bottle as "30% PCR," your supplier should provide documentation (GRS certificate, COA, or ISCC PLUS certification) that substantiates the claim. Ask for it before you commit to the claim on your packaging.