The regulations outline specific cosmetic labeling requirements which must be followed. For EU market – EU Regulation 1223/2009, Article 19 and for UK market – Schedule 34 of the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019). These rules detail exactly what information needs to appear on the packaging to ensure compliance.
The following information must be provided on the primary packaging (tube, bottle, jar, etc.) and secondary packaging (usually cardboard box):
- The name and address of the responsible person (RP);
- Nominal content of the product at the time of packaging, given by weight or volume;
- Date of minimum durability or period after opening;
- Particular precautions to be observed in use;
- Batch number of manufacture or the reference for identifying the cosmetic product;
- Function of the cosmetic product, unless it’s clear from its presentation;
- List of ingredients (may be indicated on the secondary packaging alone);
- The country of origin if the product is imported from countries outside of the EU/UK.
It should be noted that certain information on the labels needs to be translated into different languages (shall be determined by the law of the Member States in which the product is made available to the end user), and some countries have more than one official language.
Cosmetic product claims
“In the labelling, making available on the market and advertising of cosmetic products, text, names, trade marks, pictures and figurative or other signs shall not be used to imply that these products have characteristics or functions which they do not have” (EU Regulation 1223/2009, Article 20)
Every claim on cosmetic product label, but also in TV commercials, ads, websites, etc. must be substantiated. Responsible person needs to make sure that all the claims made regarding the product are proven.
The EU published a separate regulation (Regulation 655/2013) along with a guideline (Technical Document on Cosmetic Claims) to allow the correct interpretation of the Regulation previously introduced. Technical Document on Cosmetic Claims also provides guidance on the use of “free from claims” and hypoallergenic claims. See Regulation 655/2013 for more information regarding the justification of cosmetic product claims.