Cosmetic product labelling requirements in EU

It is essential to ensure that your cosmetic products comply with the European Union (EU) labelling requirements. Correct labelling is an important part of a cosmetic product, as it helps to convey information about the product such as list of ingredients, its intended use, directions for use and any precautions to be observed. Incorrect cosmetic product labelling could lead to products being withdrawn from the market or recalled from end users.

The legislation that covers the labelling requirements in the EU is the Cosmetics Regulation 1223/2009 which lists very specific requirements for cosmetic product labelling on the EU market. In order to ensure that your products comply with the labelling requirements, you must observe the legal requirements as indicated in Article 19 of the Cosmetics Regulation. It provides that cosmetic products shall be made available on the market only where the container and packaging of cosmetic products bear the following information in indelible, easily legible and visible lettering:

  • Function of the cosmetic product.
  • The name and address of the responsible person placing the product on the market.
  • The country of origin if the product is imported from countries outside of the EU.
  • Nominal content. Exemptions apply to small volumes, free samples, single-application packs or packages containing a number of items.
  • For products with a minimum durability equal to or below 30 months, the date of minimum durability must be stated preceded by the words “best used before the end of” or by the hourglass symbol.
  • For products with a minimum durability above 30 months, the period after opening (PAO) must be indicated by the open jar symbol. Exemptions apply to certain product types.
  • Precautions for use.
  • Batch number.
  • A full list of ingredients. This information may be indicated on the packaging alone. The list shall be preceded by the term ‘ingredients’. If the packaging is too small to include this information a leaflet or tag can be enclosed, and this must be referred to by specific wording or by the open book symbol. Specific rules apply to soap, bath balls and other small products. Moreover, certain information on the label needs to be translated into local language.

It is important for manufacturers and distributors of cosmetic products to be aware of consequences of non-compliance. According to the RAPEX (the European Commission’s Rapid Alert System), which is a public list of dangerous products found across Europe, several cosmetic products have appeared in this system due to non-compliance related to product labelling. Products appearing in this list are subsequently withdrawn from the market, recalled from end users or their import is rejected at the border. Based on the market surveillance, non-compliance with cosmetic product labelling requirements is mainly the result of incomplete ingredient lists, misleading directions for use or inadequate instructions and warnings being stated on the label. Therefore, it is essential to ensure that cosmetic products are in line with the labelling requirements indicated in the Cosmetics Regulation.

by Erika Budaite, Associate,

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