Cosmetic cream jars and skincare bottles on a neutral surface

COSMETICS & PERSONAL CARE

One word on the label can make it a drug.

One word on the label can make it a drug.

One word on the label can make it a drug.

Cosmetics are the lightest-regulated product category we work in, right up to the moment a claim, an ingredient or a function pushes them out of it. A moisturiser is a cosmetic. A moisturiser with sun protection, or one that claims to treat acne or reduce inflammation, is not. We work on that boundary, and on everything a cosmetic still needs to get right.

Cosmetics are the lightest-regulated product category we work in, right up to the moment a claim, an ingredient or a function pushes them out of it. A moisturiser is a cosmetic. A moisturiser with sun protection, or one that claims to treat acne or reduce inflammation, is not. We work on that boundary, and on everything a cosmetic still needs to get right.

Section Image Cosmetics

THE CLASSIFICATION LINE

Cosmetic, drug, or natural health product?

Cosmetic, drug, or natural health product?

What a product is intended to do decides its category. Cleansing, beautifying and altering appearance keep it a cosmetic. Treating, preventing or affecting the structure or function of the body moves it toward a drug, and in Canada some of those products are natural health products instead. Sunscreens, antiperspirants, anti-dandruff and acne products are the classic examples, but the line is crossed far more often by marketing copy than by formulas.

WHERE COSMETICS GO WRONG

Four problems we see.

Four problems we see.

01

Claims that change the category

Repairs, heals, reduces inflammation, boosts collagen production. Each can move a product out of cosmetics entirely, whether it appears on the label, the website or a social post.

02

Restricted and prohibited ingredients

Markets maintain lists of ingredients that are banned or allowed only below certain levels or in certain product types. A formula compliant in one country can breach the list in another.

03

Labelling that is not market-specific

Ingredient naming conventions, bilingual requirements in Canada, allergen disclosure and mandatory statements all differ by market, and requirements are tightening.

04

Post-market obligations nobody planned for

Notification, product listing, safety substantiation and adverse event handling now apply in more markets than brands expect, and they fall on the company placing the product on the market.

WHAT WE DO

Formula, classification and label together.

Formula, classification and label together.

Product classification in each target market.

Restricted and prohibited ingredient screening.

Claims review across label, website, listings and social content.

Cosmetic notification and product listing support.

Label review, including ingredient declarations, bilingual content and allergen disclosure.

Safety substantiation and documentation.

Formulation and stability support for creams, serums, cleansers and other personal care formats.

COMMON QUESTIONS

Before you launch a cosmetic.

Do cosmetics need approval before they are sold?

Generally not in Canada or the United States, but that does not mean no obligations. Canada requires notification to Health Canada after a cosmetic goes on sale, and the United States now requires facility registration, product listing and safety substantiation for many cosmetics.

Is a product with SPF a cosmetic?

Can a cosmetic contain vitamins or botanical actives?

Can the same label be used in Canada and the United States?

Book a consultation.

Book a consultation.

Send us the formula, the claims you want to make and the markets you are selling into. We will set out the category, what the label has to carry and where the copy needs to change.