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Labeling Your Products : Lip Balm

Filed Under: Lip Products

Labeling your handmade products can seem so confusing. In this 3 part series, I am going to give some basic examples of how to label lip balm, cold process soap, and lotion so that you can confidently sell or give these products as gifts.

I am just going to be touching the tip of the iceberg though. There is more to know than I can explain in a few blog posts.  If you’d like to become a labeling ninja, I highly recommend the book Soap & Cosmetic Labeling by Marie Gale. It is a concise and easy-to-read book, full of examples about labeling cosmetics with a special emphasis on soap.

The FDA’s website has many interesting articles and you can read the law as it is actually written. They also have a free Cosmetic Labeling Manual that addresses all of the basics of labeling.

The Basics for Labeling Lip Balm:

1. Ingredients: The ingredients need to be listed from most used to least used. The exception to this is listing colorants –  those you can just add to the end of the list of ingredients. The names of the ingredients need to follow the INCI ( International Nomenclature of Cosmetic Ingredients) rules. This is the scientific or agreed upon standard name for the ingredient. There are actually a few different versions of these rules that are acceptable, including common names (typically found in the 2nd edition). Here, we are going to use the 6th edition rules of the INCI Dictionary.

2. Quantity: You need to list how much product is in the container. We are going to go by weight since lip balm is a solid product.

3. Who made it: You need to list the name of the maker of the product and where they are located. That means an address (not just a website).

UPDATE 9/19/2017: The FTC has updated regulations concerning business name and address. The NEW regulation says the street address may be omitted if it is listed in a readily accessible, widely published, and publicly available resource. Read more here. 

And that’s it! Well sort of. There are more details and exceptions to the rule especially if you are making claims like ‘heals cracked lips’. If you want to make those types of claims, your product will end up being considered an ‘over the counter drug’ and you will definitely want to do a little more research in books and on the FDA website.

For our first example we are going to learn how to list the ingredients for a lip balm:

My recipe is:

This post does not explain how you make lip balm – but how to label it after you’ve made it (but if you’re curious, check out how to make lip balm here).

For the above recipe, the label would look like:

Ingredients:  Sweet Almond Oil (Prunus Amygdalus Dulcis), Beeswax (Cera Alba), Shea Butter (Butyrospermum Parkii Fruit), Coconut Oil (Cocons Nucifera), Flavor, Polyester-3, Red 28, Orange 5, Titanium Dioxide, Yellow 5 Lake, Hydrogenated Polybutene, Mica, Palmitic Acid

There are a few different ways to list the ingredients that are legal. I prefer the 6th edition rules because it combines the botanical name (which is standardized) and the Common name (which is easy to understand). The 2nd, 6th and 8th edition rules are all legal and accepted by the FDA.

Notice that the ingredients are listed in order of quantity from most used to least. In the case of the Shea Butter and Coconut Oil, since the same amount is used, you just pick one to list first. Also notice that the INCI for the colorants are just added at the end. It doesn’t matter what order they are in.

And that concludes this first very basic overview of labeling. I hope it’s a little less intimidating now. In the next part of this series, I will show how to label your cold process soap and handmade lotion.

If you like these little labels they are available as a free download on the Bramble Berry website.

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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92 Comments

  1. I’m struggling with labeling. I’m a perfectionist when it come to appearance. Do you have to label the tube/pot or can you label just the packaging?

  2. Hello!
    I am struggling with my wording on my labels. I have some products that are mostly natural (100% coconut oil, unrefined shea butter, Vitamin E, and Mica)but some of them contain a vegan friendly synthetic flavor oil, Am I able to state that it is Made with natural ingredients? Or will it have to be 100% natural to be able to say Made with Natural Ingredients? Also, my social media gal put Natural Ingredients on my site, I am just curious if I can state this, or if it’s too closely implied that it would be all natural?
    Thank you so much!!

    • Hi Tara!

      When labeling your lip balms, you are going to need to list everything that is in your batch, even the synthetic flavor oil. Natural is not actually a regulated term, so you can use it on your products. Just be aware that you cannot claim organic without your products being tested and approved by the FDA. I hope that this helps answer your questions. =)

      -Becky with Bramble Berry

  3. Thanks Becky!
    One other question, with me making my products at home, do I need to put my full address on the label? Kind of nervous about putting a personal address on the label :/
    Thanks again!!

    • Hi Tara!

      We totally understand how putting your home address on a label can make you nervous. According to the FDA’s website, you will need to list that name of the maker of the product (yourself) as well as your address. If you have a P.O. Box or business address, you can also use that as well. I hope this helps! =)

      -Becky with Bramble Berry

  4. I am going to be using flavorings from a website I purchased from, as well as an artisan oil blend from an etsy shop, do I include where these oils came from on the label or just what has been used?
    Thank you!

    • Good morning, Tara!

      All you need to include in the ingredients part of your label is what is exactly in your products. If there are some flavoring oils, you will need to add them to the ingredients list. There is no need to list where they come from. I hope this helps! =)

      -Becky with Bramble Berry

  6. Hi. I know to claim that a product has a certain SPF, it has to be tested. But, what if you put the ingredients in and list them without listing SPF? Basically, can I still add sunscreening ingredients as long as I don’t claim they do anything special?

    • Hi Audrey!

      As long as you do not make any claims that your product has SPF in it, you can actually add whatever ingredients you would like! I hope this helps. 🙂

      -Becky with Bramble Berry

  8. I read (not on FDA site) that if you use the word “balm” then it is a drug and you would run into more laws and regulations, fees, etc. At that same place, I read that if you don’t claim your soap does anything specific (moisturizes, soothes, etc) then you don’t have to label the ingredients????

    • Hi April!

      Great question! Labeling can be a little tricky, but we are here to help you out and wade through any confusion you may have. Soap is actually a special case when it comes to labeling and the FDA does not require labeling for soap, but you will find that many of your customers will want to know what is their handmade soaps. Here is a great blog post similar to the one above that Anne-Marie wrote about labeling your cold process soaps.

      How to Label Cold Process Soap: http://www.soapqueen.com/bath-and-body-tutorials/cold-process-soap/how-to-label-cold-process-soap/

      With the lip balm, as long as you do not make a claim, you can still label it as a balm. Once you make a claim like ‘healing’, it is considered a drug by the FDA. For more on lip balms and labeling, you can check out the FDA’s website here:

      http://www.fda.gov/Cosmetics/default.htm

      Another great resource to check out is the Soap And Cosmetic Labeling Book by Marie Gale. She goes into depth on how to labeling your cosmetics (lip balm, lotions, etc.) and soaps. I own it and find myself referring to it quite a bit! 🙂

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

      I hope this helps! Let me know if there is anything else I can do for you. 🙂
      -Becky

  9. Hi ladies, great template! Can you advise how we can change the color of the main box (currently a mint green)? I’d like to use these labels for Christmas gifts. Thank you in advance!

    • Hi Angela! Currently at this time we don’t have a way to change the color or design on the labels, but you can use the template and hand-write in the name of your product. But, I will pass that suggestion onto our Product Development Team. 🙂
      -Becky with Bramble Berry

  11. What size label did you use? I’m just getting started and I don’t really know what size label will wrap around a lip balm tube…thanks!! SO helpful!

  12. What type of paper would use use like how do you get the labels to stick to the lip balm tubes? Not sure what to buy

  13. How in the dickens does one label the quarter ounce lip balm pots? I want to take some to a craft show but have no idea how to put a label on them. Thanks in advance for any advise you can give me.

    • While you might not be able to attach a label to such a small lip balm pot, you can always have a card or some sort of label to give with the lip balm when you sell it.

      I’d also check out the Teach Soap forums, as I know there are several soapers there that go to markets and craft show that could totally help you out!

      Teach Soap Forums: http://www.teachsoap.com/forum

      -Becky with Bramble Berry

  14. Dear Anne-Marie,

    Can I ask you in the ingredient list what these items for: Polyester 3, Hydrogenated Polybutene, Palmitic Acid? Are these because the flavor?!

    Thank you,
    Monamur

  15. Hi I was wondering if you have your products tested? I read somewhere that if you do not have your products tested by a lab for contaminates you need to put “This product has not been tested for safety” on your label…do you know if this is true? Please shoot me an e-mail if you get this my e-mail is [email protected]

    Thanks!!

    • That’s a great question. I recommend going straight to the source, in this case the FDA, to read the exact regulations. You can also contact them with questions (which I’ve done several times and appreciate how quickly they’ve responded).

      Here is the relevant information about your specific question:

      http://www.fda.gov/Cosmetics/GuidanceComplianceRegulatoryInformation/ucm074162.htm

      My understanding is that if you are using individual ingredients already tested for safety that you do not have to use that phrase. It is only if you are using unsubstantiated ingredients that you would have to put that warning on.

  16. Hello,

    Where can the International Nomenclature of Cosmetic Ingredients 6th edition be purchased? I checked amazon, but it is not available.

    Thank you.

  17. I am not sure if you would be able to answer this but I have made an acne repair that only has co’s and eo’s in it. I would assume this would fall under the cosmetic is also a drug but I cannot figure out how I would label it. Do you have any suggestions. Also, is a lotion a cosmetic or a cosmetic/drug and do you know where I could find info on how to label those. Thanks!

  18. This is really good but here’s my problem. If you’re making a large batch to fill multiple tubes at once, then how do you know or figure out the proportions for each tube?

    • Great question – the ingredients are all mixed up together and so that means, the same proportions (percentages) in the big batch are the same in each little tube. Does that make sense? Let me know if I need to clarify it more =)

  19. I wanted to know do we have to label using the long name of an ingredent such as beeswax(cera alba).

    • No, you don’t. There are a few different ways you can label your products and currently they are all considered legal (confusing, I know). One of these ways is to just use the common name of the product. I would highly recommend reading Marie Gale’s book, we can’t possibly pack all of the great info she has in a few blog posts. Thanks!

  22. My prodcuts would be considered a drug and a cosmetic. I went through the many rules and am wondering, where exactly do you get that common “drug facts” label and fill it in with your information.

  23. If you’re adding a colorant to your products and labeling and selling, are there additional and special rules. I learned they’re last in the ingredients list but all the questions about.colorants and FDA rules are confusing me.

  25. I don’t know if you will know this answer, but I was reading on a company’s website that sells pigments and colorants for cosmetics, that when using FD&C dyes they need to be “batch certified” to be sold in a product. The large amounts they recieved before selling were batch certified but once opened, they no longer were. How can someone tell the difference between those dyes and dyes that are in micas? And what about the dyes/pigments that are on BB? Like the Yellow 5 Lake listed is a FD&C dye but is in the yellow mica. But if it was just the pure dye it would have to be batch certified. They had a link to information on it, but it’s not working anymore. Everything is just so confusing, I don’t think I’ll ever end up selling. From understanding all this, to licensing etc. Blah.

    • Hi Nicole,

      All dyes for cosmetics are held for batch certification. These are big master batches from the manufacturer. Once they are broken into smaller containers or made into liquids they do not need batch certification.

      Does this answer your question?

      Don’t stress too much – get a business license for your state and your city, work your homeowners insurance policy to see if they will cover you to manufacture and sell products and you’re off to the races! =)

      • …so a colorant that is batch certified to the supplier (say: Brambleberry!) may be used in cosmetics made and sold by people who purchase the colorant from the supplier? It would be nice to have the say-so in simple English as recently I’ve read things that say otherwise, without direct citation. I hope you can clear this up!

        • If I’m understanding your question correctly, if the end user is using it in the correct product, you should be good.

          So, for example, if the colorant isn’t approved for use in lip balm, then no amount of certification will allow you to use a certified colorant in lip balm.

          I hope this helps!

          • Thank you, it does. It didn’t make sense to me that home crafters/small businesses couldn’t use batch certified colors like lakes or micas in (appropriate) products for sale if the supplier had broken them down to saleable sized lots. (Which was what I had been told.)

  26. Thanks for the great post.

    I love this label design, what program was it done in? The text box for the title is adorable.

    • If you go with the same volume each time to fill up your tubes each time (so 2 dropperfuls for example), that will keep your weight pretty steady or if you use the same fill line (always filling flush with the top of the lip balm for example), that will keep an accurate weight as well.

  28. So do I have to label if I’m giving as a gift? Or only if I’m selling. I was wanting to make and give some lotion bars as Christmas gifts this year.

    • That’s a great question, Rebecca. To be squeaky clean on the law side, technically, yes, you’d need to label buuuuuuut, far be it from me to suggest not following the letter of the law but if you’re doing test batches, gifts and non-selling products, a cute *simple* label should do the trick. Ingredient labeling is designed for full disclosure for the buying public when they are comparing products on the shelves. When you are giving products to friends and family, you’ll still want to be aware of the concerns with allergies so labeling with basic ingredients is the best, most safe option for you but many, many small test batches have been done in the past with little to no labeling so do the most you can, be merry and call it good.

      Note to anyone reading this that’s even contemplating selling – you, my friends, need to label with full ingredients =) This was only for small one-off gift batches with hobbyists so don’t get too excited.

      • One more thing I just thought of:

        If you put ‘not for resale’ you don’t have to
        put the ingredients on the container. Ingredient labeling is `purely for items that are to be sold. In fact, many items sold in Salons don’t need to
        have ingredients because they are being sold to professionals and not the general public.

  29. I agree, good timing and thank you. I now need to fix all my labels! I went and read the cosmetic section of the FDA website and am fairly well informed now. I have a question/survey, though. The FDA does not require that cosmetics are tested for bacteria, etc, but if you do not test your product, you are required to put that specific warning on your label. My question is, how many of you are: 1) putting the warning on your labels, 2) actually having every batch officially tested, 3) neither?

  30. I’ve been reading that if someone uses the word “balm” it implies healing, which makes it a drug (OTC) in the eyes of the FDA. Supposedly, you have to pay a ton of money to have it fall within regulations.

    I know you can’t answer all of the questions, but it’s just so crazy. Looks like I’m going to have to pick up that book on cosmetic labeling you mentioned.

    • A product is considered a drug if it makes a claim. Curing acne and reducing wrinkles, so if you state that on your packaging you need to label your product as an Over The Counter drug.
      However, the term balm is not a claim on its own. But if you put ‘wrinkle reducing balm’ on your label then you would need to follow OTC labeling guidelines.

      • Thank you for clearing that up. I was fretting about the word Balm in Lip Balm, because nothing else sounds good. I was thinking Lip Stuff, Lip Wax, Lip… Can’t wait for the other parts in this series! Great work!

  31. Great blog thanks!

    Is lip balm a cosmetic? If the color and flavor are left out where is the cosmetic component?

    Thank you for any clarification as this is a mystery to me.

    • Yes, lip balm is considered a cosmetic. Anything that is meant to be applied to skin is a cosmetic with the exception of bar soap. The term ‘cosmetic’ doesn”t just mean makeup like lipstick or eye-shadow it also refers to lotions, perfumes, etc.

  32. This is awesome and so needed!! I love the template but are they an Avery standard size? or what type of label do you use? Thanks so much. This has been a very difficult obstacle trying to fit everything into a small space. Thanks!

  33. Thanks, Anne-Marie! The timing on this series is perfect, because I’m just starting to make lotions and other products in addition to CP soap. Hope your family has a happy & blessed Thanksgiving!

  34. Can you give info on the font size/type? Sometimes that can be an issue-getting the required info on a small space.

    • The size of your lettering depends on the overall size of your label and what part of the label you are talking about. For instance, the name of the product must be the most prominent part of the label but the exact size is determined by the size of the label and the size of the other information on that label.

      So for this label size the type must be at least 1/32″ for the ingredient listing. Of course, if your printer can’t clearly print the letters that small then you need to make it big enough to be legible.

  35. This is a good informative article, thank you for posting it for us. What type of labels do you recommend to purchase in order to print these out on?

  36. Oh – and what if your colorants do not say what they are? The colorants I have don’t have any indication of what they are made of – they’re just colors.

    • Your vendor should be able to give you that INCI information and tell you if they’re safe for lip balm. =) And if they can’t? Tough love but I’d switch vendors.

      • Hey another question off the subject. Where do the avatars come from? I would like to change the picture and can’t remember if it is yahoo or where? THANKS!

  37. Are the requirements different for “big business” versus “small business?” Because in looking at the soaps, bath salts, lip balms, etc, that I have, there is no full address – just a company name, city/state/country, and a website, or in some cases just a website with the company’s name on it. And these are from well-known brands/stores!

    • If your business is in the phone book (phone book!), with an address in there, you can get away with just doing the company name and city/state.

      • Kind of off the subject but I know I saw a link that explains how much of each ingredient to use for your own recipe; wax and oils ratio? Will you send me the link please? I have searched again and can’t locate it. Thanks a lot. Robin

  38. Love this post! I had no idea of the labeling requirements and am now redesigning mine. Thanks 🙂

  39. Thank you for this information. I am always unsure about labeling and this is simply explained and really understood.

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