Labels are essential in the presentation and compliance of cosmetic products. Under article 19 of the EU Cosmetics Regulation, the following information must bear on the labels of cosmetic products:
- The name or registered name and the address of the responsible person,
- The nominal content at the time of packaging,
- The date until which the cosmetic product, stored under appropriate conditions, will continue to fulfil its initial function,
- 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,
- A list of ingredients, and
- The country of origin, for cosmetic products imported into the EU
Cosmetics labelling is subject to specific rules established by the EU legislator to accommodate diverse product types and packaging. Labels must adapt accordingly for categories such as small products, single-application products, free samples, non-pre-packaged products, and multi-packs.
Small products and impracticable packaging
Small products, such as lipsticks, eyeliners, and mascaras, typically feature compact packaging with limited space for detailed labelling.
Impracticable packaging refers to situations where, for practical reasons, it is not possible to include the required information on the packaging or container.
- For both precautions and list of ingredients, the information must be provided on an enclosed or attached leaflet, label, tape, tag, or card. Where feasible, a reference to this information should be indicated using the symbol:
- If it is impracticable to include the list of ingredients on an enclosed or attached leaflet, label, tape, tag, or card, in cases like small products, the list must be displayed on a notice placed in the immediate vicinity of the product.
- For small products only, the nominal content is exempted if the product contains less than 5ml or 5g.
Regardless of the above, these products must still have the name or registered name and the address of the responsible person, the date of minimum durability, the batch number, and its intended function.
Single application products
Single-application products are intended for one-time use immediately after opening. For these products, the nominal content is exempt, and the Period After Opening (PAO) does not apply. However, the date of minimum durability must be indicated if it is less than 30 months. All other required information must still be provided.
Free samples/Testers
Free samples, distributed for promotional purposes, are exempt from showing nominal content. Nevertheless, all other required information under cosmetics labelling regulations must be included to ensure compliance.
Non-pre-packaged products
Non-pre-packaged products are those that are packaged at the point of sale. These products may contain similar or different items, each with potentially similar or different functions. The labelling of such products must comply with the rules adopted by the Member States.
Multi-packs
Multi-packs, regulated by Article 19.1(b) of the EU Cosmetics Regulation, are defined as “pre-packages normally sold as a number of items, for which details of weight or volume are not significant.”
Regarding the nominal content, the number of items must appear on the packaging, unless it is visible from the outside. All other required information must be included on the labels.
Finally, it is crucial to note that, in some cases, a combination of the above requirements may apply, depending on the specific characteristics of the product and its packaging. For example, a product may fall under multiple categories, such as small products or free samples, and in such instances, the applicable labelling obligations will need to be met for each relevant classification.
Manufacturers and distributors should carefully assess the product’s unique features to ensure full compliance with all labelling requirements for cosmetic products.
Do you have any questions on compliance of labels in cosmetic products in the EU?
References:
Cosmetics Europe (2011), Guidelines on cosmetics product labelling. Retrieved on 16 December 2024.
Meric Gonul
Regulatory Intelligence & Innovation
19.12.2024
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