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Labeling, including cosmetic product claims, is a very important part of ensuring compliance with the relevant legislation.
Products that are improperly labeled, deceptively packaged, or otherwise misbranded are prohibited and can be removed from the market.
Labels for professional-use products must comply with the general labeling requirements for cosmetic products and must include a statement indicating that the product should be used only by professionals.
The labeling for professional-use products must be updated by December 29, 2024. The responsible contact information and fragrance allergens must be listed on product labels by December 29, 2024.
Labels must comply with FDA CFR 21 as well as the new MoCRA regulation, which sets out some new labeling requirements, including:
A US address
A US phone number or
Electronic contact information (e.g., a website), which is required as a means to contact the Responsible Person (RP) in case of any adverse events
Fragrance allergens, if present in the cosmetic product (the FDA will determine which substances are considered allergens
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