Founder's Toolkit

Cosmetic Labelling RequirementS

What legally has to be on your label in Australia, and the claim language that keeps you compliant.

What Every Label Must Include

  • Full ingredient list in INCI, descending order of concentration
  • Net contents - the weight or volume of product (e.g. 50g, 30mL)
  • Business name and address of the manufacturer, importer, or supplier responsible for the product in Australia
  • Directions for use, where the product's safe use isn't obvious
  • Batch number and, where applicable, an expiry or Period After Opening (PAO) symbol
  • Warnings or cautions, where relevant to the specific formula (e.g. "avoid contact with eyes")

Cosmetic Claims vs. Therapeutic Claims

This is the single most common compliance trap for new brands. In Australia, a cosmetic product can only make claims about appearance, cleansing, perfuming, or protecting - it cannot claim to treat, cure, or prevent a medical condition. The moment a claim crosses into treating a condition, the product is legally reclassified as a therapeutic good, regulated by the TGA - a completely different, far more rigorous pathway.

Not compliant: "Treats eczema and psoriasis"
Compliant: "Soothes and supports easily irritated, sensitive skin"
Not compliant: "Protects skin from UV damage" / any SPF claim (unless TGA-registered as a therapeutic sunscreen)
Compliant: "Contains antioxidants that help protect against environmental stressors"

The safest test: would this claim make sense on a product bought at a pharmacy specifically because it treats a diagnosed condition? If yes, it's therapeutic territory, not cosmetic.

"Natural," "Organic," and Similar Claims

These terms aren't strictly regulated in Australia the way they are in some other markets, but making them without substance is a genuine legal risk under the Australian Consumer Law's misleading and deceptive conduct provisions. A "certified organic" claim specifically should only be used where an ingredient (or the whole formula) actually holds certification from a recognised body - not just because it "feels" natural.

A Quick Practical Checklist

  • Every claim on your label and marketing should describe appearance/cosmetic benefit, never diagnosis, treatment, or cure
  • SPF and sun-protection claims require TGA registration - if you haven't gone through that process, don't make the claim
  • "Certified organic" needs an actual certification behind it, not just a natural-feeling formula
  • When in doubt, describe what an ingredient is (e.g. "contains Niacinamide") rather than what it does medically