Essential Legal Requirements for Private Label Hair Care Products

By NCL USA

Essential Legal Requirements for Private Label Hair Care Products

Table of contents





If you're planning to start your own line of private label hair care products, you're likely focused on choosing the right ingredients, packaging, and supplier. However, before your product hits the shelves, or even your website, there’s one area that demands your immediate attention: labeling compliance. Labeling might seem like a small piece of the puzzle, but it's legally non-negotiable. Missteps can result in regulatory warnings, fines, retailer rejections, or worse - loss of consumer trust. The U.S. beauty industry is highly competitive and increasingly scrutinized, and for first-time entrepreneurs, proper labeling isn't just about aesthetics. It’s a matter of consumer safety and legal responsibility. In this guide, we break down the must-know legal requirements for private label hair product labeling, with a focus on practical compliance for startups and small businesses.

Why Labeling Matters in the Hair Care Industry?

Labeling is more than branding. It's a form of consumer communication governed by law. Your product label must clearly and accurately inform users about:
  • What the product is
  • How to use it
  • What it contains
  • Who is responsible for it
  • Any relevant safety warnings
If your label is misleading or missing required information, your product can be classified as “misbranded” under U.S. law - even if the formula itself is perfectly safe. That designation can lead to removal from stores, seizure, or legal action. This is especially important for private label brands, where products are manufactured by third parties but sold under your name. As the brand owner, you are legally responsible for what your label says, regardless of who made the product.

Who Regulates Hair Product Labels in the U.S.?

In the United States, cosmetic labeling is primarily regulated by:
  • The Food and Drug Administration (FDA) under the Federal Food, Drug, and Cosmetic Act (FD&C Act)
  • The Fair Packaging and Labeling Act (FPLA)
  • U.S. Customs and Border Protection (CBP) for imported goods
Most hair care products, including shampoos, conditioners, serums, and styling sprays, are considered cosmetics under FDA definitions. However, if a product claims to treat or prevent a health condition (like hair loss or dandruff), it may also be classified as a drug, triggering stricter requirements. If you're launching a standard cosmetic hair product (without therapeutic claims), the FDA does not require pre-approval. But you must ensure your label complies with all relevant regulations before going to market.
Legal Requirements for Private Label Hair Care Products

1. Principal Display Panel (PDP): The Front of Your Label

The Principal Display Panel (PDP) is the part of your packaging that's most likely to be seen first, typically the front of the bottle or container. It must include: (a) Product Identity This is a clear statement of what the product is. Examples:
  • “Hydrating Shampoo”
  • “Leave-In Conditioner”
  • “Anti-Frizz Hair Serum”
(b) Net Contents Statement The amount of product in the container, expressed in U.S. customary units (e.g., fl. oz.) and metric units (e.g., mL). For example - “8 fl. oz. / 237 mL.” This statement must appear on the bottom 30% of the PDP and be aligned horizontally.

2. Information Panel: What Goes on the Back or Side

The Information Panel usually appears on the back or side of the product. It must contain several key pieces of information. (a) Ingredient List
  • List all ingredients in descending order of predominance (by weight).
  • Use the INCI (International Nomenclature of Cosmetic Ingredients) names.
  • Fragrance can be listed as “Fragrance” or “Parfum” - individual components don’t need to be disclosed unless required by international regulations.
(b) Directions for Safe Use Provide clear, concise instructions to ensure safe and effective use. For example - “Apply to wet hair, lather thoroughly, and rinse. Repeat if needed.” (c) Warning Statements Some products require warnings, especially if they contain potential allergens or active ingredients. The FDA mandates specific language for certain products. For example - “For external use only. Avoid contact with the eyes. If irritation occurs, discontinue use.” (d) Manufacturer or Distributor Information
  • Include the name and business address of the responsible party.
  • If you're using a private label manufacturer, the label should say “Distributed by” or “Manufactured for” followed by your business name and address.

3. Label Claims: What You Can and Cannot Say

Marketing claims are one of the most legally sensitive areas in cosmetic labeling. Any statement on your packaging, no matter how minor, must be:
  • Truthful
  • Not misleading
  • Scientifically substantiated (if necessary)
Avoid Claims That Imply a Drug Function:
  • “Regrows hair”
  • “Treats dandruff”
  • “Cures dry scalp”
These imply a therapeutic use and would classify your product as an over-the-counter drug, requiring FDA registration, testing, and compliance with OTC drug monographs. Acceptable Cosmetic Claims Include:
  • “Moisturizes dry hair”
  • “Adds shine”
  • “Smooths frizz”
  • “Helps detangle”
Stick to cosmetic claims unless you’re ready to take on additional regulatory burdens.

4. Font Size and Label Format

Your label must be legible and prominently placed. According to the FPLA:
  • All required text must be in English
  • Font size must be no smaller than 1/16 inch in height (based on the lowercase “o”), unless the packaging is too small to allow it
Make sure contrast is high enough (e.g., black text on white or light backgrounds) for readability.

5. Batch Codes and Expiration Dates

While not mandatory under FDA rules for most cosmetics, batch codes and expiration dates are best practices. Why They Matter:
  • Quality assurance: Helps track manufacturing issues
  • Consumer confidence: Shows you care about product freshness
  • Retail compliance: Many platforms (like Amazon) require expiration labeling

6. Allergen and Sensitivity Considerations

The FDA does not require allergen labeling for cosmetics, but transparency is strongly encouraged, especially if you’re using ingredients like:
  • Essential oils
  • Botanical extracts
  • Common fragrance allergens (e.g., linalool, limonene, citronellol)
In the EU and other global markets, these disclosures are mandatory. If you're planning to expand internationally, consider aligning your labeling with global compliance standards from day one.

7. Barcodes and Retail Readiness

Though not required by law, you’ll need a UPC barcode if you plan to sell your product in stores or on major e-commerce platforms.
  • Get authentic barcodes from GS1 US
  • Make sure your barcode is scannable and placed according to retailer specifications
This is an operational step, but it’s vital for scaling your private label brand professionally. Launching a private label hair care line can be creatively rewarding and financially promising, but only if you start on solid legal ground. Your product’s label is often your customer’s first point of interaction with your brand. It must be accurate, compliant, and complete. Even if you’re working with a trusted manufacturer, the responsibility for label compliance lies with you as the brand owner. Take the time to understand and implement these requirements. Consult legal experts or regulatory consultants if needed. Getting your labels right from the start can help you avoid costly delays, protect your reputation, and give your customers the confidence they need to choose your brand.




References

https://www.fda.gov/cosmetics/cosmetics-labeling/cosmetics-labeling-regulations





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