In 2013, the sunscreen industry was affected by new legislation that focused on the information presented on sunscreen labels. This year, a new bill is addressing what’s INSIDE the container – in particular, the Federal Drug Administration’s (FDA) regulatory backlog of approving sunscreen ingredients. Congress recently passed the Sunscreen Innovation Act in an effort to speed up the FDA’s review process of over-the-counter sunscreen ingredients. Let us dig deeper into what this bill means and how it could impact sunscreen labeling so you can be prepared for these upcoming changes.
What is the Sunscreen Innovation Act?
The Sunscreen Innovation Act is a bi-partisan bill that was introduced in March 2014 to the House of Representatives (approved in July), and then to the Senate which approved the bill in September. Public health advocates over the years have questioned the FDA’s overly stringent review process of sunscreen ingredients, which has created a lengthy approval backlog, even though several pending ingredients have been in use for years in Europe and Asia.
So what will the bill do? First, it will require the FDA to respond faster to currently pending approval requests for sunscreen ingredients. As of today, eight sunscreen ingredients have been sitting in the FDA’s backlog for years – some for over a decade. The second thing the bill will do is to require the FDA to respond to future sunscreen ingredients within a year and a half of application, at maximum. The bill is now in the final stages, awaiting finishing touches from Congress, and ultimately President Obama’s approval.
Implications for Sunscreen Labels
There are several ways that sunscreen labels may be impacted when the Sunscreen Innovation Act becomes official; however, changes mostly affect sunscreen manufacturers and how they formulate their products. If a manufacturer decides to reformulate its sunscreen with newly approved ingredients, all product labeling will be required to reflect those changes. Here are some predictions of how the Sunscreen Innovation Act could affect future sunscreen labeling:
- New/updated information on the Drug Facts table: According to FDA regulation, every sunscreen product is required to have a “Drug Facts” section on the product. Any changes to the sunscreen’s ingredients will need to be reflected in the Drug Facts. There are two ways manufacturers can do this: design completely new labels or use cover-up labels for the Drugs Facts section on the old label.
- Label redesigns highlighting new ingredients: Marketers love showcasing new or enhanced product features, so it won’t be a surprise to see redesigned labels touting the benefits of a new sunscreen formula. Whether it’s through bold text, graphics or colors, a new or updated label design will help highlight new sunscreen ingredients.
- Increasing use of multi-layer labels: Squeezing product information onto one or two labels can result in a cluttered, distracting design. That’s where multi-layer labels can help. Sunscreen manufacturers may find themselves interested in multi-layer labels since they can streamline packaging while providing large amounts of information in an easy-to-read layout.
- More interest in shrink sleeve labels: Sunscreens with newly approved ingredients may need more chemical resistant labels that don’t compromise on shelf appeal, like shrink sleeve labels. With 360-degree label coverage, shrink sleeves offer a lot of design space to include a Drugs Facts table, sunscreen claims and eye-catching artwork.
The Sunscreen Innovation Act will undoubtedly have an impact on the sun care market, but to what extent? For one thing, it will expand the amount of over-the-counter sunscreens since new ingredients can mean new or updated products. Another consideration is how these sunscreens will be labeled and packaged. Increased competition will require manufacturers to be more strategic with their labels and packaging to even get noticed on store shelves. If you need help with your sunscreen labels, our dedicated label experts would be glad to guide you through materials selection and customization options to achieve the perfect look.