A Guide to West Coast Packaging and Labeling Requirements for Cosmetics Manufacturers: Ensuring Legal and Regulatory Compliance

September 28, 2023 11:30am

Allyn Stern
Principal
Beveridge & Diamond

Qareena Ahsan
Director Safety & Regulatory
Maesa

Dennis Raglin
Partner
Steptoe & Johnson LLP

California and Washington state possess some of the most rigorous packaging and labeling regulations for cosmetics nationwide. These regulations present a significant challenge for companies as they strive to ensure compliance while simultaneously meeting consumer demands for creative and appealing packaging.

This session aims to provide you with a comprehensive understanding of the requirements, as well as guidance on how your business can best manage this challenge.

West Coast Laws Affecting Cosmetic Packaging and Labeling:

  • Analyzing the impact of the California Safe Cosmetics Act on packaging and labeling
  • Examining The Federal Fair Packaging and Labeling Act (FPLA) and its impact on consumer products labeling
  • California SB 54’s influence on manufacturers, with respect to recyclable and compostable packaging
  • The California Consumers Legal Remedies Act in ensuring companies do not engage in false and deceptive advertising on labels
  • Exploring Washington State’s Renewable Materials Packaging Law and how the legislation impacts manufacturers

Practical Applications of State Federal Packaging and Labeling Laws and Regulations

  • Considering state specific requirements for labeling ingredients, warnings, and claims relative to your products
  • Analyzing how large and small companies navigate product labeling harmonization this across different markets
  • Developing compliant and attractive packaging that meets consumer demands within the scope of federal and state guidelines
  • Examining claims regarding packaging and compostability, and exploring the role of Extended Producer Responsibility (EPR) schemes in this context
  • Maintaining current knowledge of ingredient disclosure obligations, warning prerequisites, and ensuring adherence to FDA regulations to prevent inaccurate or deceptive labeling
  • Assessing how cosmetic producers can assert federal preemption and defend against slack fill claims under the FD&C Act