Why is label review one of the last steps in the compliance process?

Recently, I attended Cosmoprof Asia in Hong Kong, where many cosmetic manufacturers presented their uniquely and sometimes quirky designed cosmetic packaging. As fun as it was to discover these designs, it immediately sparked the question: how do you manage to put an EU Label on such packaging?

In particular, as cosmetic manufacturers put a lot of effort in the design of the  cosmetics’ packaging, the first question we often receive is: “can you review my packaging/label to see if this is compliant in the EU?” Unfortunately, the answer is “not at this stage”.

Let me explain why:

Under EU cosmetics regulation 1223/2009/EC, the final artwork of a cosmetic product label must follow certain rules. The label (including container, outer packaging and inserts/leaflet) of a cosmetic product must reflect the Product Information File (PIF) of that product. As such, the EU label can only be created after the Product Information File is compiled. Some of the elements that must appear on the label are a direct result of the Cosmetic Product Safety Report (CPSR), a key component of the PIF.

For example, the ingredients (INCI) list should perfectly match those mentioned in the CPSR. Also, special precautions for use/warnings to be mandatorily placed on your label are a direct outcome of the safety evaluation.

As you can see, only once the EU compliance process has been completed – e.g. safety tests, CPSR, PIF – will a product’s label be compliant in reference to the specifics of the product.

December 29th, 2019

José Amsing

Senior Consultant, Sales department

Looking for more information on the Labelling Guidance and the New EU Cosmetic Regulation? Click here below!

Want to know more about the CPNP Notification process and the importance of EU Responsible Person? Click here below!

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