Net quantity on US cosmetic labels: dual declaration and where it goes
21 CFR 701.13 requires the net quantity of contents on US cosmetic labels — fluid measure for liquids (at 68 °F), avoirdupois weight for solids — and a separate metric statement is allowed; products under the FPLA must carry both US customary and metric units.
Short answer: US cosmetic labels must declare the net quantity of contents: liquids in fluid measure (the U.S. gallon of 231 cubic inches and its quart, pint and fluid-ounce subdivisions, expressed at 68 °F), solids in avoirdupois pounds and ounces (21 CFR 701.13). Products subject to the FPLA must carry the declaration in both US customary and metric units.
The numbers
| Rule | What it says | Source |
|---|---|---|
| What to declare | Net quantity of contents — weight, measure, numerical count, or count plus weight/measure | 21 CFR 701.13(a) |
| Units for liquids | Fluid measure: US gallon (231 in³), quart, pint, fluid ounce, volume at 68 °F | 21 CFR 701.13(b) |
| Units for solids | Avoirdupois pound and ounce | 21 CFR 701.13(b) |
| Metric statement | A separate metric statement is not a "supplemental" statement and may appear on the PDP or other panels | 21 CFR 701.13(r) |
| Dual units | Products under the FPLA must be labeled in both US customary and metric | FPLA, 15 U.S.C. 1454 (as amended) |
Where it goes
The declaration sits on the principal display panel (PDP) — the label side most likely to be shown at retail (21 CFR 701.10). The PDP must be big enough to hold the mandatory information without crowding, and its area is defined by the package shape (height × width for a rectangular package; 40% of height × circumference for cylinders).
Common mistakes
- Declaring only “3.4 fl oz” on an FPLA-covered product. The metric equivalent (100 mL) must be there too.
- Putting the metric line only on the back panel for a dual-declaration product — under 701.13(r) a metric statement may appear on the PDP, and the FPLA dual requirement applies to the declaration itself.
- Declaring weight for a liquid (or fluid measure for a powder). The rule keys off the physical form.
- Ignoring the 68 °F volume condition on fluid declarations.
Do this now
Look at your PDP: if it carries one number, add the second unit. 2 fl oz / 59 mL style, bottom third of the panel, in the required type size.
FAQ
What units does the US net quantity declaration use?
Fluid measure for liquids (US gallon, quart, pint, fluid ounce, expressed at 68 °F) and avoirdupois pound and ounce for solids (21 CFR 701.13).
Do US labels need metric units too?
Products subject to the FPLA must carry the declaration in both US customary and metric units; a separate metric statement is handled under 21 CFR 701.13(r).
Where does the net quantity go?
On the principal display panel, whose area is defined by the package shape (21 CFR 701.10).
Sources
- 21 CFR 701.13, declaration of net quantity of contents — eCFR, issue 2026-11-06
- 21 CFR 701.10, principal display panel — eCFR, issue 2026-11-06
- FPLA (15 U.S.C. 1454), dual declaration requirement — FDA, labeling requirements overview
Last verified: 2026-11-10. The 21 CFR citations were checked against the eCFR text; the FPLA section itself should be confirmed at govinfo.gov before you rely on it.
Not legal advice, and not a guarantee of compliance or of acceptance by any authority.
Want this checked against your own formula? Run the free label check. It builds the label draft with the net-quantity line and the ingredient order. It returns an issue list, not a print-ready label.
Related: MoCRA label requirements · The under-1% ordering myth