Comprehensive Label Review for Australian cosmetics


The Comprehensive Label Review is $5,300.00 AUD per product label.
It comes with 3 complementary 30 minute consulting sessions (valued at $375.00 AUD).

This is perfect for you if you need a “whole kit and caboodle” review. You’ve drafted your Australian cosmetics label and would like a thorough review of every element of your product label, including your supporting documentation and test results.

The review is undertaken by assessing your proposed hard copy label, final packaging and carton as well as any supporting documentation pertaining to your product. It does not include any work in progress product information or products awaiting the outcome of efficacy or safety testing.

Examples of supporting documentation include (but are not limited to):
- product specifications, and release and expiry specifications
- raw material supplier information (MSDS, CoA, flow charts, toxicological reports)
- final formulation
- testing protocols
- performance/efficacy testing results
- safety testing results (e.g. microbiological, Preservative Efficacy and stability)
- evidence of claim substantiation

Payment Terms: 50% deposit before review commences, final payment due 2 weeks following commencement.
Estimated Completion Time: 6 weeks from receipt of signed Client Agreement, payment, hard copy label, final packaging, carton and all supporting documentation. Note, review will not commence until all of these have been received.

Factors that determine the turnaround time (but are not limited to):
- the number of ingredients in your product and whether they are listed on the Australian Inventory of Chemical Substances
- the types of claims you are making
- the accuracy of the information you supply
- the performance/efficacy and safety test results
- the completeness of the documentation you supply

You will receive a report which outlines the items that are non-compliant, recommendations for improvement and other considerations to improve your label quality and supporting documentation.

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What review covers

Review covers the following text on your hard copy label, final packaging and carton (if used):
- Business/Brand Name is displayed on front panel.
- Product Name is a suitable product identity statement and displayed on front panel.
- Correct unit of measurement used and displayed on front panel.
- Measuring character height, size and spacing of measurement marking.
- Correct English or International Nomenclature of Cosmetic Ingredients (INCI) name used for each ingredient and each ingredient listed in correct sequence (based on review of % concentration in formulation).
- Review of Australian Inventory of Chemical Substances to confirm permitted use of ingredient and whether they are subject to prohibited or restricted use.
- Clear product description outlining who it is for and its intended use.
- Review of performance/efficacy protocols or test results.
- Benefits/claims in line with definition of cosmetics.
- Review of supplier documentation supporting your claims.
- Clear directions of use in line with product purpose.
- Clear storage conditions in line with product type and packaging used.
- Review of safety and stability testing protocols or results.
- Warnings/Precautions in line with product purpose and product description (who it is for).
- Review of Standard for the Uniform Scheduling of Medicines and Poisons (SUSMP).
- Name and physical address of packer or the name on whose behalf it was packed.
- Expiry Date listed.

Review does NOT cover:
- Australian or international trade mark applications or searches for Business/Brand Name.
- Domain name or Australian Securities and Investments Commission (ASIC) checks.
- Australian or international trade mark applications or searches for Product Name.
- National Industrial Chemicals Notification and Assessment Scheme (NICNAS) registration, notification, permit or exemption applications.
- Review of any text book or scientific literature used to support your claims.
- Review of suitability of packaging and dispensing system.

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How to get started

1. Before starting, I recommend checking the NICNAS definition of cosmetics to confirm that your products align with these guidelines. Also, have a look at what the Comprehensive Label Review does and doesn't cover.

2. To get started, please send an email to: info(at)geraldinepierreskincare(dot)com with the following:
a. Copy of print-ready pdf file for your label and carton (if used).
b. Product launch timeline
c. Product brief
d. Performance/efficacy protocols and test results
e. Microbiological, Preservative Efficacy Testing (if applicable) and Stability Testing results
f. Any other tests you performed to validate the product's safety
g. If you would like to extend the review to any elements under "Review does NOT cover" (e.g. you would like me to review the suitability of your packaging and dispensing system).
h. Business name
i. ABN
j. Billing address
k. Formulation in percentage form (total must equal 100%) including CAS number for each ingredient
l. MSDS and CoA for each of your ingredients/raw materials
m. Any other supplier documentation you used to support your claims
n. Proposed release and expiry specifications
o. Confirmation of any applications made to NICNAS (e.g. to register your business)

Also send your hard copy label, final packaging and carton (if used) to: PO Box 62 Highpoint City VIC 3032.

3. I then send you a Client Agreement and invoice.

4. Upon receipt of the signed Client Agreement, payment (Comprehensive Label Reviews are paid in 2 instalments - 50% upfront and the remainder is due 2 weeks from commencing the review) and all documentation, I commence the review which takes approximately 6 weeks.

5. You receive a report of the review. I use a 'traffic light system' to assess the degree to which you've met the Australian regulations (e.g. green = compliant, yellow = needs review or more information, red = non-compliant) offer tips for how the regulations can be met, how to improve your label quality and whether your claims have been appropriately substantiated.

6. Once you've read the report, assess how comfortable you are with making the changes. I'm happy to answer any questions you have via email.

You can book your 3 complementary 30 minute consulting sessions (valued at $375.00 AUD) at any time during the review.

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