It’s not a very sexy title, we know, but proper labelling on cosmetics is so important. It tells the consumer a variety of things, including what the product is, what the ingredients are and who made it. It also lists any warnings or instructions for use. Anyone working in makeup should understand what the labels mean.
The Labelling Legislation
Product labelling in the European Union (EU) is regulated by law, namely the EU Cosmetics Regulations (1223/2009). The main purpose of these regulations is human safety.
Cosmetic laws apply to any product that is intended for sale, as well as those that are given away for free. Ultimately, the making and selling of cosmetics are considered to be a commercial enterprise, and the penalties for non-compliance can be severe. Furthermore, ignorance of the law is not considered a defense.
All cosmetic and personal care products must have a label somewhere on the packaging. This could be on the primary packaging, such as the bottle or jar the cosmetic is contained in. Alternatively, it could be on the secondary packaging, for example, the box the product is sold in.
A label must be indelible, easy to read, and include the following information:
- Name and address of manufacturer or supplier
- List of ingredients
- The amount contained (weight or volume)
- Date of minimum durability (“best before date”) or a “Period After Opening” (PAO)
- Warning statements and precautionary advice
- Batch number or lot code
- Product function (when appropriate and if the use is not obvious)
Name & Address of Manufacturer
- The name and address of the manufacturer (or supplier) are required on both the primary container and any secondary outer packaging.
- If the product is made outside of the European Economic Area (EEA), the country of origin must also be shown on the label.
- Ingredients have to be listed on any outer packaging. However, if there is no outer packaging, it must be on the main container.
- The label must have the title INGREDIENTS followed by all the ingredients contained in the product, with a few exceptions. The ingredients must be listed in descending order of weight. However, for ingredients that are in concentrations of less than 1%, they can be listed in any order after all the other ingredients.
- The naming of ingredients has to follow a standard concerning terminology, so there is consistency between different brands. This makes it easier for the consumer to identify if there are any ingredients in a product that causes them issues, like an allergic reaction. The naming of ingredients is set in the International Nomenclature for Cosmetics (INCI). This means that wherever you buy the product, the ingredients are always named the same.
- The term “parfum” means perfume, which can consist of many ingredients. However, these ingredients do not have to be listed individually, except for certain ones which must be shown on the label.
- The term “aroma” means flavour (for things like toothpaste) and the raw materials in the aroma do not need to be listed, with a few exceptions.
- Colouring agents are shown by “Cl” followed by its number and can be listed in any order after all other ingredients are listed.
- For coloured products that come in various shades (for example, lipstick), the symbol “+/-” or words “may contain” can be seen before the list of colours. This means that not all the colours listed are necessarily used in every shade.
- Nano ingredients must-have “(nano)” after them. For example, “titanium dioxide (nano)”.
The Amount of Content
- The amount of product at the time of packaging must be given on the label. It can be shown as either weight or volume.
- For the EU, the net contents must be given in metric. However, you may also see ounces (“oz”) listed as well. This is because some products may be sold in other countries where they don’t use the metric system. For example, for selling in the USA, the weight will also be listed in “US OZ”.
- The “e” symbol (which means “estimated”) is a guarantee that the product has been filled per the average system of measures used in the EU.
- The term “Net Wt.” may also be seen by the weight/volume.
- Some products are exempt from this requirement, including free items, sachets for a single application, and anything less than 5g or 5ml.
Durability of Product
Cosmetic products must indicate how long they are good for use. For products with a lifespan of fewer than 30 months, there must be a “Best Before Date”. For products with a lifespan of over 30 months, this is shown by the “Period After Opening” (PAO) symbol.
There are some exceptions to this requirement, including aerosol products (as they are effectively sealed), perfumes that have a high alcohol content, and single-use packs.
Best Before Date – Lifespan of fewer than 30 months
- Any cosmetic product that has a lifespan of fewer than 30 months from the date of manufacture must have a “best before the end of” date on the packaging.
- This is shown by the words “best before” followed by the date (shown as month and year). This indicates when the product either ceases to fulfill its intended function or no longer meets safety requirements as per the regulations.
- “Best before” can be abbreviated to “Exp”, and “Best Before End” to “BBE”. The “egg timer” symbol may also be used.
- Labels must also show any special precautions to be observed. For example, if any special storage conditions are needed to keep the product in good condition, this must be shown on the packaging.
- For products with a lifespan longer than 30 months, they must have a “Period After Opening” time. This means once a product has been opened by the consumer for the first time, it has a shelf life of so many months, under normal conditions of use.
- It is shown on cosmetics as a little pot symbol with a number in it followed by an “M”. This tells you how many months the product is safe to use, once it has been opened. So for example, 24M means that you can use the product safely for 24 months after you have opened it.
Warning Statements & Advice
- Not all products have this information on them, as it is not always relevant to the product.
- Basically, it is for any special information, like how a product must be properly used or disposed of safely. It also includes warnings about ingredients, preservatives, or UV filters, or how not to use a product. For example, precautionary advice includes things like “Avoid eye area” or “Do not use to dye eyelashes”.
Batch Number or Lot Codes
- This is a code that enables the manufacturer or supplier to identify when and where the product was made. One purpose of this would be to identify which batch a product came from, should there be complaints or issues.
- This is only required on a label if the function of the product is unclear from its presentation and design. For example, the function of lipstick is clear from how it looks, so it does not need to be labelled as lipstick. However, a depilatory cream could not be labelled just as “cream” – it would have to state that it was for hair removal to prevent any misunderstanding.
- If there is not enough space on a product to include the ingredients list, any warnings and instructions for safe use, the manufacturer has to include that information somewhere else in the packaging.
- For example, it could be on a leaflet contained in the box. You sometimes see labels that can peel back to reveal another layer underneath with more information on it.
- The “Hand Book” symbol shows that information is included elsewhere in the packaging.
Other Information Given on a Label
In addition to the legally required information, a label can provide other information that the manufacturer might want to tell the consumer. Of course, this is down to the individual manufacturer or brand.
Organic or Natural
- There is no legal definition of organic cosmetic products in the EU. Therefore, a company could label a product “organic” even if that product only had 1% organically-produced ingredients.
- Other similar terms used on labels are things like “natural” and “green“. Again, no legislation is in place for these terms. They are used by manufacturers to simply make the consumer think they are buying something pure, better or safer.
- To find certified organic products, look for logos from the organisations that approve products as organic. In fact, five European certification bodies have developed the Cosmetics Organic Standard (COSMOS), which has the aim of harmonising organic standards across the globe. They have high standards and to achieve COSMOS certification for a product, that product has to meet a strict set of criteria. This ensures that the product contains guaranteed organic ingredients and is not just label trickery.
- Terms such as hypoallergenic, dermatologist-tested, allergy-tested, or non-irritating have no legally-defined meaning. They are used by manufacturers to convey that they think the product will not cause a bad reaction when used. However, no proof of this is needed from the company – anyone can put these terms on a label.
Not Tested on Animals
- Some companies take liberties on labels and use word trickery to make the consumer think that their products are not tested on animals. For example, “We do not test on animals” may mean that the company itself doesn’t test on animals, but they might contract another company to animal-test on its behalf.
- Manufacturers may use a label to state what is not found in their product. In this case, it is often things like parabens, preservatives, synthetic fragrance, or colourants. Basically, those ingredients that some consumers do not want in their products or find irritating to their skin. By and large, it can be useful information to know, as it helps someone avoid certain ingredients.
- There are various recycling symbols, including the “Green Dot”. This shows that the company has a membership in a recycling and recovery scheme to deal responsibly with the packaging waste of their products.
- All companies in Europe and the UK have a legal obligation to recycle and recover packaging waste. Companies often pay a specialist company to do the work on their behalf.
Languages Used on Labels
32 countries come under the legislation – the 27 member states of the EU, plus Iceland, Liechtenstein, Norway, the UK, and Switzerland are included as part of the single market. The cosmetic labelling laws require that certain information on a label has to be translated into the language(s) of the country where it is sold. The information that must be translated is:
- The nominal contents (weight or volume)
- The date until which the cosmetic can be used
- Particular precautions to be observed by the user
- The function of the product
So, for example, products sold in the UK and Ireland must have the above information in English. Likewise, products sold in Greece must be in Greek, and Switzerland requires French, German and Italian.
Ingredients in a product have to be listed using their “International Nomenclature of Cosmetics Ingredients” (INCI) names. Therefore, the ingredient names used will be the same, no matter where the product is being sold in the EU.
Reporting Non-Compliant Cosmetics in the UK
If you think a cosmetic product being sold on the UK market is fake or not compliant with the law in some way, you can report it to Trading Standards via Citizens Advice.
Trading Standards is the organisation responsible for enforcement in the UK and the Citizens Advice provides help on a wide range of consumer issues. However, you cannot contact Trading Standards direct and have to go via Citizens’ Advice, who will pass your complaint on to Trading Standards.
Here are the main contact details for Citizens’ Advice:
England and Wales: Contact Citizens’ Advice by telephone on 0808 223 1133 (freephone), online chat, or by completing an online form. Website: https://www.citizensadvice.org.uk/consumer/get-more-help/report-to-trading-standards/
Northern Ireland: Contact Advice NI on 0808 802 0020 (freephone). Website: https://www.nidirect.gov.uk/contacts/contacts-az/advice-ni
Find Out More
If you are a maker or supplier and have any queries about what is legally required on labels in the UK/EU, it would be best to consult with a lawyer who understands cosmetic law.
Alternatively, there are organisations like the CTPA (Cosmetic, Toiletry and Perfumery Association), who act as the voice for the UK cosmetics industry. Furthermore, they have a wealth of information on their website.
- Labelling law as per the Cosmetic Products (Safety) Regulations 2008.
- Cosmetic, Toiletry and Perfume Association (cpta.org.uk) has various useful information, including Making and Supplying Cosmetics in EU and FAQs on Making Cosmetics.
- The facts about Understanding Your Label and Packaging and the Environment.
- The COSMOS Standard website – organic standards in the EU.
- FDA labelling requirements – cosmetic labelling in the USA.
- List of ingredient functions – for example, terms including “anti-dandruff”, “preservative”.