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2026 U.S. Cosmetic Label Pre-Print Checklist
Work through your pre-print review one step at a time, with the source beside each item. 39 of 63 items support automated text checks; others need artwork or manual review. Tick as you go; nothing you tick is stored or sent.
0 of 63 checked Print Clear Built from rule base version 2026.1
Net quantity of contents (4) Net quantity of contents presentchecked by the free scan PDP must include net quantity by weight, measure, or count.
Net quantity placement and lettering sizeconfirm on the artwork Put the net quantity on the front (principal display) panel, in the bottom 30% of that panel, parallel to the base. The bottom-30% placement requirement does not apply to panels of 5 square inches or less when the other requirements are met. Minimum letter height by panel size: 1/16" (≤5 sq in), 1/8" (>5, 25), 3/16" (>25, 100), 1/4" (>100 up to 400), 1/2" (>400). Add 1/16" if lettering is blown, embossed, or molded. We can't measure panel size or lettering from text, confirm this on your packaging.
Clear space around the net quantity statementconfirm on the artwork Separate the net quantity from other printed label information above and below by at least the height of its lettering. Leave at least twice the width of its letter N to the left and right. Confirm this on the print artwork; the current PDF checks do not measure this clearance.
Correct panel placement (front panel vs. information panel)confirm on the artwork Net quantity goes on the front (principal display) panel; the ingredient list and the manufacturer/distributor name and address may go on an information panel. We check that this information is present in your text but can't tell which physical panel it's on, confirm panel placement on your packaging.
Ingredient declaration (11) Ingredient declaration presentchecked by the free scan 21 CFR 701.3 requires a cosmetic ingredient declaration in descending order of predominance. Detection is a 3-state engine check (rules_engine.run_rules): PASS when a standard 'Ingredients:' / 'Active Ingredients:' / 'Inactive Ingredients:' heading is present; WARN (701.3.ingredients_heading_unconfirmed) when list-like comma structure appears without a heading (a headingless list is legal, so not a hard failure); BLOCK when the label is a product-label body with no heading and no comma-list. The literal heading is FDA-standard practice, not statutory.
Ingredients in descending order of predominanceconfirm on the artwork List ingredients from most to least by amount. Exception: ingredients at 1% or less may appear in any order after those above 1%, and color additives may appear in any order at the end. We can't see your formula's concentrations from the label, so we can't verify the order, confirm it matches your formulation.
Ingredient lettering size / small-package optionsconfirm on the artwork Ingredient lettering must meet the minimum height for your package size. Very small packages may place the ingredient list on a tag, tape, or card firmly affixed to the package, or on accompanying display material. We can't measure this from text, confirm on your packaging.
Ingredient declaration on multiunit and multicomponent packages (if applicable)confirm on the artwork 21 CFR 701.3(q): the inside containers of a multiunit or multicomponent package need no ingredient declaration when the outer package bears one that meets this section and the inner units are not sold separately. Separately, 701.3(i)-(k) let a package with less than 12 square inches of label surface carry its declaration on a firmly affixed tag, tape or card, or in leaflet labeling on a display unit or chart; such a display unit must carry the words "Federal law requires ingredient lists to be displayed here" in letters not less than 3/16 inch high, conspicuous when no lists remain. Not applicable if the individual units' ingredient declarations are already visible through or on the display package. A label-text scan of a single product panel cannot tell whether this product is sold as part of such a display package.
"New ingredient list" overlabeling notice on formulation changes (if applicable)confirm on the artwork 21 CFR 701.3(n) is a permission, not a general overlabel duty: when a shortage of a cosmetic ingredient forces a formulation change, packages already printed with the old declaration may still be used if the revised declaration appears either on a firmly affixed tag, tape, card or sticker bearing the conspicuous words "new ingredient list" in letters not less than 1/16 inch high, or on labeling inside an unsealed package whose outside bears "new ingredient list inside". Not applicable to a label being printed for the first time. A label-text scan cannot tell whether this PDF is such an overlabel.
"May contain" color additive declaration for batch color-matching (if applicable)confirm on the artwork If a color additive is added to only SOME batches of this product for the purpose of color matching, you may declare it using the phrase "may contain" (e.g. "May Contain: Red 33") instead of listing it as though every batch contains it. This is an OPTIONAL labeling accommodation - a label that lists every color additive unconditionally is also compliant. A label-text scan cannot tell whether a given batch actually varies this way; confirm with your formulator which additives are batch-variable before using this declaration style.
Composite color-additive list for an assortment sold in one package (if applicable)confirm on the artwork If this product ships as part of an assortment of cosmetics sold together in the same package, you may declare the COLOR ADDITIVES of the whole assortment in a single composite list - instead of a separate color-additive declaration for each product - as long as the listing is not misleading and makes clear it covers every product in the package. This applies to color additives only; the rest of the ingredient declaration follows the ordinary rules. A label-text scan of one product panel cannot tell whether it ships packaged together with others.
Cumulative ingredient list for an assortment of similar products (if applicable)confirm on the artwork If this product is sold as part of an assortment of products similar in composition and intended for the same use (FDA's example is an eyeshadow palette), you may declare the ingredients common to all of them in a single cumulative list, together with a statement identifying which products contain the other, non-common ingredients - or, if the package's labelable surface is under 12 square inches, in one combined list with no separate non-common statement required. A label-text scan of one product panel cannot tell whether it ships as part of such an assortment.
Shared label declaration for a branded shade line (if applicable)confirm on the artwork If this product is one item in a branded shade line sold under a common trade name with no other brand appearing on any item (FDA's examples: one lipstick in a line of lipsticks, or one compact in a line of compacts), the line may share a single label declaring the ingredients common to all shades, plus a statement identifying the other, shade-specific ingredients and which product(s) contain them; shade-specific color additives may use the "may contain" declaration under 701.3(g)(2). A label-text scan of one shade's panel cannot tell whether it is part of such a line.
Direct-mail alternative ingredient declaration (if applicable)confirm on the artwork If this product is sold to consumers by direct mail, the ingredient declaration may appear (letters not less than 1/16 inch high) in the accompanying mailing, sales catalog, or brochure instead of on the package, PROVIDED the mailed package itself carries a notice - visible on opening, letters not less than 3/16 inch high - that states where the declaration is located, promises a copy will be mailed promptly on request, and gives the mail-order distributor's name and place of business; the distributor must then actually fulfill that promise when asked. A label-text scan of the package panel cannot tell whether this product is sold by direct mail or whether the required catalog/brochure declaration exists.
Off-package leaflet ingredient declaration for small/compartmented display units (if applicable)confirm on the artwork If this product's package has under 12 square inches of labelable surface (and is not enclosed in an outer carton), the ingredient declaration may instead appear (letters not less than 1/16 inch high) on an accompanying leaflet attached to a compartmented display tray or rack - or, for a shade-matched assortment, attached to a display chart bearing shade samples - rather than on each unit. Strict conditions apply: the leaflet must be visible per specific placement rules (fully readable from the front, or accompanied by a 3/16-inch notice if partially visible or on a side); all copies used with one display must be identical; the unit must ship together with its labeling; the display must show "Federal law requires ingredient lists to be displayed here" (3/16 inch minimum) whenever no declaration is currently attached; a formulation change requires the leaflet to be dated and to distinguish old vs. new formula; sufficient copies must be provided for every purchaser; and the firm named on the product must mail a copy to anyone who requests one. A label-text scan of one product's panel cannot tell whether it is sold this way or whether the display unit meets these conditions.
Warning statements (8) Eye-contact warning (best practice)checked by the free scan If formula may irritate eyes, include 'Avoid contact with eyes.'
Children safety warning (best practice)checked by the free scan Include 'Keep out of reach of children' for potentially irritating products.
Flammability warning if applicablechecked by the free scan No federal cosmetic regulation (21 CFR subchapter G — Parts 700, 701, 740) prescribes flammability-specific warning text; the FHSA cannot reach a cosmetic (15 U.S.C. §1261(f)(2)). A cosmetic in a self-pressurized (aerosol) container must still carry the mandatory 21 CFR 740.11(a)(1) warning ('Warning—Avoid spraying in eyes. Contents under pressure. Do not puncture or incinerate...'), which is not flammability-specific but is required regardless — this rule flags it as a best practice, not a codified flammability duty.
AHA sun sensitivity warning recommendedchecked by the free scan 21 CFR 740.1 (general cosmetic warning authority); FDA AHA labeling guidance (Jan. 2005, 70 FR 1721) is a nonbinding recommendation, not a codified requirement
Products containing alpha hydroxy acids (glycolic, lactic, malic, etc.) SHOULD carry a sun sensitivity warning. NOT a codified mandate: 21 CFR Part 740 contains no AHA or sun-sensitivity provision (its only sunburn rule, 740.19, covers suntanning preparations without sunscreen). CTFA petitioned FDA to issue such a regulation and FDA DECLINED, issuing a nonbinding Level 1 guidance instead (70 FR 1721, Jan. 10, 2005), which states it does not create legally enforceable responsibilities. The engine therefore fires this at WARNING severity resting on 21 CFR 740.1's general authority, and this catalog row must say the same. Catalog entry, rule logic in rules_engine.py, not executed via DB path.
Safety-substantiation warning (if applicable)confirm on the artwork If your product's safety has not been adequately substantiated, the front panel must bear, word for word: "Warning—The safety of this product has not been determined." We can't tell from the label whether your safety data is on file, confirm whether this applies.
Tanning / self-tanner warning (if applicable)confirm on the artwork If your product is a suntanning preparation that does not contain a sunscreen, its labeling must display, word for word: "Warning-This product does not contain a sunscreen and does not protect against sunburn. Repeated exposure of unprotected skin while tanning may increase the risk of skin aging, skin cancer, and other harmful effects to the skin even if you do not burn." 21 CFR 740.19 defines "suntanning preparations" to include topical products that give a cosmetic effect on the skin while tanning under UV radiation and products that give the appearance of a tan with an approved colour additive such as dihydroxyacetone. We check this automatically when the label names the product as a tanning or self-tanning preparation, or declares dihydroxyacetone. If your product is one and uses wording we did not recognise, confirm this yourself.
Aerosol / pressurized-container warnings (if applicable)confirm on the artwork If your product is in a pressurized (aerosol) container, it must bear, word for word: "Warning—Avoid spraying in eyes. Contents under pressure. Do not puncture or incinerate. Do not store at temperature above 120 °F. Keep out of reach of children." (Glass: use "break" for "puncture"; non-spray: omit "Avoid spraying in eyes"; children's: add "except under adult supervision.") If it uses a halocarbon or hydrocarbon propellant, also: "Warning-Use only as directed. Intentional misuse by deliberately concentrating and inhaling the contents can be harmful or fatal."
Warning-statement conspicuousness (type size, bold, contrast)confirm on the artwork Every warning statement must appear prominently and conspicuously compared to other words and designs, in bold type on contrasting background, likely to be read under customary conditions of purchase and use - and never in letters or numbers under 1/16 inch in height (unless FDA has granted a small-package exemption by regulation). We can verify a warning's TEXT is present but not its size, weight, or contrast; confirm these on your packaging artwork.
Type size, contrast and panel placement (4) Required information appears in Englishchecked by the free scan All required label information must appear in English per 21 CFR § 701.2. If a foreign language also appears anywhere on the label, all required statements must also appear in that foreign language.
Conspicuousness, contrast, and Englishconfirm on the artwork All required statements must be in English and easy to find and read under normal shopping conditions, adequate type size, good contrast, not crowded. If any required statement also appears in another language, all required statements must appear in that language too. We can't assess size, contrast, or prominence from text; confirm on your packaging.
CPSIA lead and phthalate limits for children's cosmetics/packaging (if applicable)confirm on the artwork If this product, its packaging, or an accessory (e.g. an applicator) is a children's product as defined by the CPSIA, or has any paint or similar surface coating, two federal chemical limits apply: (1) total lead content in any accessible substrate material may not exceed 100 ppm (15 U.S.C. § 1278a), and lead in paint or similar surface coatings may not exceed 0.009% / 90 ppm (16 CFR 1303.2); (2) a children's toy or child care article may not contain more than 0.1% of any of eight prohibited phthalates - DEHP, DBP, BBP, DINP, DIBP, DPENP, DHEXP, or DCHP (16 CFR 1307.2-.3) - applying equally to toys and child care articles, no mouth-contact or age distinction. DIDP and DnOP, part of the ORIGINAL 2008 interim ban, are NOT on the current permanent list and are not restricted by this rule today. These are formula/material composition facts a label-text scan cannot see - confirm testing with your supplier if this product is marketed to or usable by children.
Country-of-origin marking for imported product (if applicable)confirm on the artwork If this product is of foreign origin, the ARTICLE itself - not merely the shipping carton - must be marked in a conspicuous place, as legibly, indelibly and permanently as the nature of the article will permit, with the English name of the country of origin, for example "Made in France". We raise a specific finding automatically only when the label carries a non-US address and we find no origin mark on it. Whether the product is in fact imported, and whether the physical marking is conspicuous, indelible and permanent enough, are facts about the finished package that a label-text scan cannot determine, so confirm both with your manufacturer. If the article is made in the United States, this statute requires no marking.
Prohibited and restricted ingredients (2) Tamper-resistant packaging for cosmetic liquid oral hygiene and vaginal products (if applicable)confirm on the artwork If this product is a cosmetic liquid oral hygiene product or a cosmetic vaginal product, and it is accessible to the public while held for sale, it must be packaged in a tamper-resistant retail package. Except for aerosol products, the retail package must also bear a statement, prominently placed, that alerts consumers to the specific tamper-resistant feature. (An oral-hygiene product marketed with a therapeutic claim is an OTC drug, not a cosmetic, and is covered by 21 CFR 211.132 instead.) A label-text scan cannot verify packaging, so confirm whether this applies to your product.
No prohibited cattle (BSE) materials in the formulation (if applicable)confirm on the artwork No cosmetic may be manufactured from, processed with, or otherwise contain prohibited cattle materials: specified risk materials, the small intestine of all cattle (unless the distal ileum has been removed by the procedure the regulation specifies), material from nonambulatory disabled cattle, material from cattle not inspected and passed, or mechanically separated beef. The definition expressly EXCLUDES tallow containing no more than 0.15 percent insoluble impurities, tallow derivatives, gelatin, hides and hide-derived products, and milk and milk products, so most common bovine-derived cosmetic ingredients fall outside the ban. If your formula uses any other bovine-derived ingredient, confirm its sourcing with your supplier. A label scan cannot verify ingredient sourcing.
Limitations
This checklist covers what a label SAYS. It cannot see the formula, the packaging material, a lab result, or whether a claim is true for your product. This free checklist does not measure artwork. Check print PDF measures supported type-size, contrast and placement properties for one check credit; supported PDF correction costs one additional credit. Drug-label compliance is not evaluated. An over-the-counter drug panel has its own labeling rules outside this checklist. California Proposition 65 chemical-name matching is advisory and does not establish that a warning is legally required. A checked box is your own record. Nothing you tick here is stored, sent, or read by CPGShield. This is a screening aid built from the rules CPGShield holds. It is not government approval and does not replace your own regulatory review. CPGShield LLC provides independent screening. We are not affiliated with, endorsed by, or acting for any retailer, brand, agency or organization we name.
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