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Getting started

A flat minimum

On this page11
In no case may the letters be less than 1/16 inch in height. No scaling, no exception you can take.

The clause

A warning statement must appear prominently and conspicuously, in bold type on contrasting background, and in no case may the letters or numbers be less than 1/16 inch in height.

Which is unusual in this library

Every other type size rule here bends. The cycling property has a table that scales type size with panel area. The hair care property gives a panel a proportion of the label space.

This one is absolute

A 15 mL roll-on and a 237 mL tub carry the same minimum letter height, and our shelf runs from 15 mL to 237.

So small packages carry the whole burden

The statement does not shrink with the container, which means the smallest containers have the hardest problem and no relief inside the rule.

There is a paragraph (b)

And it is not an exemption a maker can rely on. It lets the Commissioner establish an alternative method by regulation, on petition, as an amendment to the section.

Which is a rulemaking, not a packaging decision

Submitted to the Dockets Management Staff in a prescribed form. Nobody designs a label around that.

The practical answer is to plan the panel

Diameter and height are published on these containers, so the available wall area is calculable before anything is ordered.

And the statement is a known length

59 characters including the dash and the full stop. Which with a known minimum height makes the fit a printing question rather than a guess.

We do not compute the fit for you

Character width depends on the typeface and we do not publish one. Giving you a number would be inventing a value, which is the one thing this catalog will not do.

Then there is our own problem

380 closures on this shelf and not one pump, roller or applicator. That has its own page and it is not a legal problem.

References

21 CFR 740.2(a): "A warning statement shall appear on the label prominently and conspicuously as compared to other words, statements, designs, or devices and in bold type on contrasting background to render it likely to be read and understood by the ordinary individual under customary conditions of purchase and use, but in no case may the letters and/or numbers be less than 1/16 inch in height, unless an exemption pursuant to paragraph (b) of this section is established." law.cornell.edu
21 CFR 740.2(b): "If the label of any cosmetic package is too small to accommodate the information as required by this section, the Commissioner may establish by regulation an acceptable alternative method, e.g., type size smaller than 1/16 inch in height. A petition requesting such a regulation, as an amendment to this section, shall be submitted to the Dockets Management Staff in the form established in part 10 of this chapter." law.cornell.edu
The warning statement runs to 59 characters including the dash and the full stop. The minimum letter height is 1/16 inch. The smallest container in this group is 1.0625 inches in diameter, which gives a side wall circumference of about 3.3 inches, and diameter is recorded on 97 of the 106 containers with a median of 2.37 inches. No fit is computed from those numbers, because character width is a property of the typeface and we do not publish one.
Written from 21 CFR 740.2 and 740.10 and from the catalog as it stood on 19 October 2026. Part 740 is cosmetic labeling; whether a particular topical is a cosmetic or a drug is a determination not made here, and nothing on these pages addresses whether a cannabinoid is permitted in a cosmetic or what any state requires. The 1/16 inch minimum is stated as the regulation states it and no fit is computed, because character width depends on a typeface we do not publish. Availability figures are a single snapshot.