Cosmetics with small packaging space

As the NEW Cosmetic Regulation EC 1223/2009 on Cosmetic products implies, a correct label is the gateway to placing your product on the European market. The Label is one of the core elements within a cosmetic Product Information File (PIF).

As presented in our article on Official EU Languages & Labeling Requirements, labels shall be eligible, visible and contain the following elements:

• The name or registered name and the address of the responsible person;
• The nominal content;
• Durability (Period After Opening - PAO, Expiration date);
• Particular precautions to be observed in use;
• The batch number of manufacture or the reference for identifying the cosmetic product;
• The function of the cosmetic product, unless it is clear from its presentation;
• A list of ingredients (by INCI names and correct descending order of weight)

However, what rule shall apply when adequate labeling is impossible for practical reasons?

For instance; how will all the necessary labeling information be presented in case of mascaras or eye pencils, where the packaging space, is simply too small?

Since the Regulations do not specify in detail these explicit cases, certain provisions have been made to take into account the practical difficulties. Therefore, here is a more practical approach of Article 19 of the respective regulation:

1. Small products, which have an outer box packaging:
• The ingredient list and the precautions for use may be indicated only on the outer packaging with a reference to the “open book” symbol on the actual container.
• Where it is impossible, for reasons of size, for details of the batch code to appear on both the primary container and outer packaging, the details may be given on the outer packaging only.
2. Small products, which are sold without an outer packaging:
• Where it is impracticable for reasons of size or shape for a list of ingredients to be given, the list of ingredients must be displayed on a notice in the immediate proximity to the container in which the cosmetic product is being sold. E.g. soap, bath balls.
• In the case of the demonstrative example of mascara, there are at least three alternatives to comply with the requirements and include all the labeling information:
1. Add a sticker on the length of the product actual container;
2. Apply stickers on the bottom/top in a form of a “fan-sticker” (a sticker that unfolds);
3. Tube your product in a plastic cover

Regulation 1223/2009 EC  does not provide definitions on the concepts of “small”, “impossible for practical reasons”, “impossible for reasons of size” or “impracticable for reasons of size or shape”. Consequently, the huge varieties of cosmetic packaging confront any comprehensive definitions of these terms in the context of marking and labeling.

Regardless of the given gap in the Regulation, manufacturer must aim for the most adequate labeling and packaging in the case of small products to maintain quality and reduce risks of misuse or accidents.

Last updated Mar 12, 2012

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