Sugar scrub label requirements (US, 2026)
Scrubs are one of the easiest products to make and one of the easiest labels to get wrong: the jar invites volume instead of weight, the colorants are often unapproved botanicals, and half the Pinterest copy (“fades scars,” “treats KP”) is a drug claim. Here is what a handmade sugar or salt scrub sold in the US actually needs.
1. A scrub is a cosmetic — full FDA labeling applies
A product that exfoliates, smooths or polishes the skin is a cosmetic under the FD&C Act. There is no soap-style exemption, even for scrubs that contain soap: the complete cosmetic label is required — identity statement, net quantity, full ingredient declaration, your business line, and the MoCRA contact line.
2. The claims trap
Intended use is decided by what the label and listing say:
- “Exfoliates,” “smooths,” “polishes,” “softens rough patches” — cosmetic. Fine.
- “Treats acne / eczema / keratosis pilaris,” “fades scars,” “heals cracked heels” — drug claims; the product would need to follow OTC drug labeling, a different regime entirely;
- “Reduces cellulite,” “detoxifies” — structure/function claims that read as drug territory; don't.
3. The ingredient list (21 CFR 701.3)
- Ingredients in descending order of predominance — in most scrubs that means Sucrose (or Sodium Chloride for salt scrubs) first, then the carrier oils by their INCI names;
- Ingredients at 1% or less may follow in any order; color additives go last;
- Fragrance oils may be declared simply as “Fragrance”; essential oils by INCI name;
- Colorants must be FDA-approved color additives (21 CFR Part 73 / certified colors). Micas, iron oxides and titanium dioxide are fine for body scrubs; dried botanical powders (beetroot, spirulina, turmeric) and soap dyes are not approved color additives for cosmetics — the most common scrub mistake.
4. Net contents: weight, not volume (21 CFR 701.13)
A scrub is a semisolid, so declare net weight, not fluid ounces: e.g. Net Wt 8 oz (227 g), in dual units, in the bottom 30% of the principal display panel, type size scaled to label area. Weigh the contents without the jar (tare) — the jar's printed capacity is not your net weight.
5. Warnings worth knowing
- 21 CFR 740.10: if you haven't adequately substantiated the product's safety, the label must carry the verbatim warning “Warning — The safety of this product has not been determined.” Under MoCRA you are also required to hold safety substantiation for every cosmetic you sell;
- Water + dipping fingers = microbial growth. An anhydrous scrub used in the shower gets water in it; either preserve it appropriately or instruct dry-hands use — this is a safety-substantiation issue, not just copy;
- Voluntary but smart: “May make tub or shower floor slippery” — oils in scrubs genuinely do.
6. Identity, your name, and the MoCRA contact line
- Identity (“sugar scrub”) on the front panel;
- Business name and place of business; “Distributed by…” if you don't make it yourself (21 CFR 701.12);
- MoCRA contact line (FD&C §609(a), mandatory since Dec 29, 2024): a US address, US phone number, or electronic contact for adverse-event reports. The small-business exemption does not waive it.
Generate it instead of memorizing it
The Inkurate generator applies every rule above to your recipe — INCI ordering with sucrose first, the colorant check, “Fragrance” handling, the net-weight line, conditional 740.10, and the MoCRA contact line — citing the regulation for each element. The preview is free.