Cosmetic products – do your labels comply with EU labelling requirements?

March 23, 2018

Ensuring that your cosmetic products comply with EU labelling requirements is crucial. Incomplete ingredients lists, misleading directions for use or inadequate instructions and warnings being stated on the label could lead to products being withdrawn from the market, recalled from end users or their import being rejected at the border.  Ensure that your products comply by observing the 10 legal requirements below.

Any cosmetic product made available on the EU market must bear specific information on the container (e.g. bottle, jar) and packaging (e.g. outer box, if applicable). This information is described in the EU Cosmetics Regulation (1223/2009) and must be indelible and easily legible.

10 items a compliant label must contain 

  1. Name and address of the responsible person.
  2. Country of origin, for imported products.
  3. Nominal content. Exemptions apply to small volumes, free samples, single-application packs or packages containing a number of items.
  4. 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.
  5. 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.
  6. Directions for use and precautions. If the container and/or packaging are 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.
  7. Batch number.
  8. Function of the product.
  9. List of ingredients, preceded by the term “ingredients”. This information may be indicated on the packaging alone. There are specific rules governing which ingredients must be declared, the order in which ingredients are listed and the ingredient names used. 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.
  10. The information referring to the nominal content, the minimum durability of the product, the directions for use and precautions and the function of the product must be translated to the language determined by the Member State where the product is being sold.

Failure to comply

Since the EU Cosmetics Regulation entered into force in July 2013 several cosmetic products have appeared in the European Commission’s Rapid Alert System (RAPEX), which is a public list of dangerous products found across Europe, due to non-compliances related to product labeling. Products appearing in this list are subsequently withdrawn from the market, recalled from end users or their import is rejected at the border.

Incompliances were mainly due to incomplete ingredient lists, misleading directions for use or inadequate instructions and warnings being stated on the label.

If you have any questions about the compliance of your cosmetic products or would like further information on cosmetic product labeling, please contact Helena Eixarch (Project Manager, Cosmetics) at helena.eixarch@tsgconsulting.com

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