Regulatory Beauty Product Requirements

All beauty products shipped to URBN must comply with the labeling requirements of the Federal Food, Drug, and Cosmetic (FD&C) Act, the Fair Packaging and Labeling (FP&L) Act, and the regulations published by the Food and Drug Administration under the Authority of these two laws. Some information on the label (detailed below) must be printed in both English and French, in order to be compliant in the Canadian market as well.

The following information must appear on the principal display panel (the part of a label that the consumer sees or examines when displayed for retail sale):

• Identity Statement - in both English and French, indicating the nature and use of the product, by means of either the common or usual name, a descriptive name, a fanciful name understood by the public, or an illustration [21 CFR 701.11].
• Net Quantity of Contents – in both English and French (metric and imperial units) - an accurate statement of the net quantity of contents in terms of weight, measure, numerical count or a combination of numerical count and weight or measure [21 CFR 701.13].
  

The following information must appear on an information panel:

• Name and address of manufacturer, packer or distributor - If the name and address is not that of the manufacturer, the name must be preceded by phrases such as “Manufactured for …”, “Distributed by …”, or other appropriate wording. The name of the firm must be the corporate name, and the address may be that of the principal place of business. Stating also the name of a corporation’s particular division is optional. The business address must include the street address, name of the city and state, and the ZIP code. The street address may be omitted if the firm is listed in a current city or telephone directory.
• Country of Origin
• Ingredient Declaration - The ingredients must be declared in descending order of predominance. The ingredient declaration must be conspicuous so that it is likely to be read at the time of purchase.Cosmetics which are also drugs must first identify the drug ingredient(s) as “active ingredient(s)” before listing the cosmetic ingredients (21 CFR 701.3(d)). Ingredients must be listed only by their INCI (International Nomenclature of Cosmetic Ingredients) names. In the absence of an INCI name you may also use the name given in the United States Pharmacopeia, National Formulary, Food Chemical Codex, USAN, and the USP dictionary of drug names.
• Directions – Directions, warnings or cautions, in English and French, where necessary for safe use (if hazardous to consumers when misused).
• Batch Number
  

For additional information, and further detail on the above labeling regulations, please visit the FDA website.

Additional Note: Material Safety Data Sheets are required for cosmetics that include alcohol or any other flammable materials within the ingredients. MSDS sheets must be submitted to your buyer/buying operations contact for review PRIOR to a PO being issued. These must be included with the shipping documents that are provided to the freight forwarder/courier service.

*If your product is HAZARDOUS please refer to the “Shipping of Hazardous Materials (ORM-D)” section of the Vendor Guidelines for instructions on how cartons are to be packed and marked for acceptance into our distribution centers.

Beauty Product Testers/Samples All individual beauty product samples must be marked with the following information:

1. Distributor’s name
2. Net quantity
3. “Sample – Not for Resale”
4. Country of Origin
5. any warning statements (if applicable)
6. any active ingredients
   

*Please note that HazMat requirements apply to beauty samples as well. MSDS sheets must be provided for ALL beauty products, regardless of size.

Please consult your buying team if your product is missing any required information.

HOW TO PRE-LABEL A DIRECT ORDER

Please note that labels must be purchased through one of our 3rd party suppliers, FineLine or CheckNet.

Direct (online) orders require a 3×3 label applied on the front center of a polybagged item

• Your product will not require a polybag if the 3×3 label can fit directly on the item without covering important information
• Please do not seal your polybags with staples
• For tubular shaped products, such as shampoos and hairspray, the label must be placed with the barcode running lengthwise with the tube

Items packaged in a polybag with an opening greater than 5” requires a warning label, such as the following: “Warning: To avoid danger of suffocation, keep away from children. Do not use in cribs, beds, carriages, or play pens. THIS BAG IS NOT A TOY!”

HOW TO DUAL TICKET A DIRECT ORDER

Dual ticketing is only required for direct orders under Nail (Class 164) and Fragrance (Class 190)

How is this being facilitated? Direct orders that require dual ticketing will be transmitted to FineLine and CheckNet containing a new ticket code. This ticket code will result in the staging of both labels- the less than 1×1 label for retail and the 3×3 label for direct. What do I need to do differently? You will order tickets and labels as per usual. The ticket providers will facilitate the process for you. Please be sure to select all items staged on your order to be printed. Placement Instructions:

1. Place the smaller, less than 1×1, retail label directly onto the item (see page 3)
2. Place the item in a polybag
3. Place the larger, 3×3 label, on the center back of the polybag, opposite of the retail label

Please note:

• In order to process your order through our automated system, the barcode on the retail price label cannot interfere with the barcode on the direct label. Please make sure the retail and direct label are not facing the same direction.
• FineLine and CheckNet will print the labels and tickets in the same print shop and they will be individually packed, with both label and tickets shipped together in the same package.

HOW TO PRE-LABEL A RETAIL ORDER

Please note that labels must be purchased through one of our 3rd party suppliers, FineLine or CheckNet.

Retail (in-store) orders require a less than 1×1 label applied directly to the item

• The label should be placed over the product’s already existing barcode
• Avoid placing the label on the bottom of the product
• DO NOT cover important information, such as the ingredient list, country of origin, or instructions
• Please consult your buying team if you are unsure where to place the label