Fine Print: What’s in a Name?
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Exploring the statement of identity.
by Holly C. Young and Marcus TiradoHirschhorn + Young Graphics
Packaging innovation is a key element in beauty marketing today. This is illustrated by the continuous launch of unique packages on the market. Consumers certainly appreciate packaging innovation. However, the main point of interest to a consumer is a product’s purpose—what a product is and what it can do. This is called the statement of identity (SOI), and it is regulated by FDA.
What Is the SOI?
What is the SOI? Is it “Fancy Lashes” or “Mascara”? “Soft Face” or “Soft Face Lotion”? Under FDA regulation, the SOI refers to the type or kind of cosmetic product that a product is. This requires a generic statement.
FDA regulation states that the SOI can be presented in four ways: the common or usual name; the descriptive name, which generally explains the product function; a fanciful name, in which the nature of the product is obvious; or an illustration, which displays how the product will be used. In the third and fourth alternatives, care must be taken to fully inform the consumer of the exact function of the product.
Where Does the SOI Belong?
The Code of Federal Regulations 21 section 701.11 states that the SOI is required to appear as one of the main features on the principal display panel (PDP) of a cosmetic package. The PDP is the area of the package that is most likely to be displayed to the consumer at the time of purchase. It is generally considered to be the front panel of the outer container.
On the PDP, the SOI must appear in bold type at a size consistent with the most prominent type on the PDP. In short, it must be conspicuous. It must be generally parallel to the base of a package when displayed on the shelf. The SOI should be prominent enough to be seen and not obscured by other information.
The Bottom Line
Your primary mission is to sell your fabulous product to the consumer. Communicating to your customer in a clear, informative, and innovative way amidst all of the shelf clutter is essential to your mission. Be as innovative, creative, clever, classy, and trendy as your market calls for, but be sure your SOI follows the rules.
Reference:
21 Code of Federal Regulations 701.11
Federal Fair Packaging and Labeling Act [21 U.S.C. 14554]