EU cosmetic regulation on labeling

Before placing a finished cosmetic product on the EU market, you must be sure that labels are compliant with the Cosmetic Regulation (1223/2009).  In this article, we specify the mandatory information that must be indicated on the container (primary packaging or inner package) and packaging (secondary packaging or outer package). 

What are the labeling requirements for cosmetics?

The article 19 of the EU cosmetic regulation requires cosmetic products to provide the following mandatory information that must be printed on the container or/and on the packaging. This information must be legible, indelible, and visible.

1. The name and the address of the company (Responsible person)
   The name and address of the Responsible Person based in Europe must be indicated. This information may be abbreviated but readable.

2. Country of origin 
   Use the reference “Made in…” unless the product is made in Europe. The “Made in...” reference does not need any translations. The country of origin is specified for imported cosmetics.

3. Nominal content
   The net nominal content must appear in volume (ml) or in weight (g). In practice, liquids, cream and gels are declared by volume, solids and powders by weight. Exceptions: packaging containing less than 5 grams or milliliters such as free samples.

4. List of ingredients
   Ingredients are listed in decreasing order of concentration, except for ingredients below 1%. By practice, fragrance allergens are listed at the end followed by colorants which may be present.

5. Batch number 
   A reference for the identification of the cosmetic product, not particular format is required.

6. Product function
   The function of product must be clearly printed on the container and on the packaging, unless it can be obviously deducted.

7. Date of Minimum Durability (DOMD) & Period after Opening (PAO)
   The DOMD is mandatory only for cosmetic products with a durability of 30 months or less. For a product with a durability of more than months, the PAO is mandatory.

8. Particular precautions of use and warnings
   Specific precautions of use and warnings to be observed by end users should be labeled on cosmetics products, as a minimum, those listed in Annexes III to VI.

Particular cases

There are some particular cases for small products, single application products, free samples, and testers. 

• Small products
  Exempted of nominal content if the product contains less than 5 ml or 5 gr. Particular precautions and list of ingredients shall appear on an enclosed or attached leaflet, label, tape, tag, or card. Unless impracticable, a reference to this information shall be made by the hand-in-book symbol or by an abbreviated indication.

• Single application products
  Exempted of nominal content. PAO is not relevant but date of minimum durability shall be indicated if durability is less than 30 months.

• Free samples or testers
  Exempted of nominal content. 

Which symbols are important to know in EU cosmetics?

There are 3 important symbols to know about the labeling of cosmetic products.

Pay attention to labeling translation requirements

According to the EU Cosmetic Regulation, you must translate the following information in the language of the EU country you export:

• Product function

• Particular precautions of use and warnings

• Nominal content

Be careful, Austria, Bulgaria, France, Poland, Portugal and Slovakia request full translation of container and packaging.

What about cosmetic claims

Cosmetic claims such as "Moisturizing, Firming, Regenerating ..." are usually displayed on the package and container. These are powerful marketing tools that can persuade end consumers to buy a cosmetic product. However, claims are regulated in Europe to prevent consumers from being misled.

According to a specific regulation on cosmetic claims (EC: 655/2013), an allegation must be lawful, truthful, honest, fair, supported by sufficient and verifiable evidence and informed decision-making. This protects consumers from misleading claims and is an opportunity for a brand to prove the effectiveness of their cosmetics.

There are different ways to support claims. The most used and relevant are:

• Experimental studies: In vitro studies, in vitro studies, clinical studies, sensory evaluations, etc.

• Consumer Perception Test: Questionnaire

• Published information: Scientific publications, market data, etc.

Conclusion

In conclusion, to successfully label your container and packaging before going on the market, it is essential to check the following points:

• Check what kind of cosmetics products you are selling (finished product,small products, free samples,..)

• Check if the  mandatory items appear on your packaging (nominal contant, country of origin,...)

• Check if the language is in conformity with the country you want to sell

• Check if you have sufficient and verifiable evidance for your claims 

If all these points are consistent, your packaging are ready!

If in doubt, please refer to a person specialized in cosmetics regulation.

Do you need help to verify your labeling?
We can help you.
Contact us at info@intercosmetica.ch.