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EU Labelling Requirements for Cosmetics

EU labelling requirements for cosmetics

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.

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.

Labelling Requirements

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)
 
We will now take a look at each of these aspects in more detail.
EU labelling requirements for cosmetics

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

  • 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.
EU labelling requirements for cosmetics
The label shows name and address of manufacturer, the ingredients and the amount of contents in metric.

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.
  
Period After Opening – Lifespan of more than 30 months
  • 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.

Product Function

  • 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.

Further Information

  • 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.
EU labelling requirements for cosmetics
The batch code, the product's function and what the product doesn't contain.

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.
EU labelling requirements for cosmetics
COSMOS group of organisations that certify organic.

Hypoallergenic

  • 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

  • To find products that really are cruelty-free, look for the Leaping Bunny logo on cosmetic and household products. These products have been thoroughly assessed by Cruelty Free International and are certified as genuinely cruelty-free.
  •  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.

Free From

  • 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.

Recycling Advice

  • 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:

Find Out More

Sources:
A Guide to the Cosmetics Products (Safety) Regulations 2008: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/39334/10-761-guide-to-cpsr.pdf
The Cosmetic, Toiletry & Perfumery Association: http://www.thefactsabout.co.uk/storage-of-cosmetic-products/content/169
Labelling requirements on Legislation.gov.uk: http://www.legislation.gov.uk/uksi/2008/1284/regulation/12/made
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30 thoughts on “EU Labelling Requirements for Cosmetics”

  1. HI,
    I’m starting a handmade cosmetic business, I don’t feel comfortable placing my home address on the labels, how would I get around this?

    1. Hi Pamela. It is possible to get PO Boxes or virtual office addresses but not sure if this would be acceptable to cosmetic labelling legislation to be honest. Have a look at https://www.ukbusinessforums.co.uk/ – they have lots of useful advice/members who know legal stuff. All the best.

  2. Hi,

    I am planning on to import some cosmetics from Poland and sell it on the UK market. Shall i label the translation on my own or do they have to be labelled by the producer? (I only mean a few information that require to be translated to English as these cosmetics will have all information written in Polish)

    1. Hi Alina – as we understand it, you as the importer would be classed as the “responsible person” and, therefore, would have to ensure that the legally required information in English is on the label. However, we are not lawyers, so you would be best consulting with a legally qualified person or contacting an organisation like the CTPA (https://www.ctpa.org.uk/) for clarification on anything legal. Here’s a guide from the CTPA about supplying cosmetics in the EU/UK market: https://www.ctpa.org.uk/supplying-or-manufacturing-a-cosmetic-product.

  3. Hi, I’m planning on launching a cosmetic product (cleansing oil) next year and I’m a bit confused about primary and secondary packaging label. I’ve seen that if the seller has all the info legally required on the secondary packaging, then they only put the weight (eg 100ml, x fl oz with the e symbol) and what the product is and that’s it.
    Is that legal? What should I add to my primary container (eg bottle) if I have already put all the legally required info in the secondary packaging (eg box)?

    Thanks !

    1. We understand that you also need the name and address of the manufacturer on the main container. Have a look at the Cosmetic, Toiletry and Perfumery Assoc.’s website for the most up-to-date information. Here are some FAQs from that site re: producing cosmetics in the UK/EU :https://www.ctpa.org.uk/faqs. Also a guide to making and selling cosmetics: https://www.ctpa.org.uk/supplying-or-manufacturing-a-cosmetic-product
      Also check out: https://www.thefactsabout.co.uk/

  4. My 12 year old daughter bought some lip balm from a company and it arrived in a plastic bottle with no label and no leaflet explaining contents. I messaged them to ask what it contained and whether they are breaching regulations by not having a label. They claim labels detailing ingredients are not required if the contents are under 15ml. Is this true? If not how do I report this company?

    1. Hi David – Direct from the gov.uk site – http://www.legislation.gov.uk/uksi/2008/1284/regulation/13/made:

      (4) Where it is impracticable, for reasons of size or shape, for the required particulars as to the conditions of use or list of ingredients to appear in an enclosed leaflet those particulars shall appear on a label, tag, tape or card which is enclosed or attached to the cosmetic product.
      (5) In the case of soap, bath balls and other small products where it is impracticable, for reasons of size or shape, for the required information as to the ingredients to appear on a label, tag, tape or card or in an enclosed leaflet, those particulars shall appear on a notice in immediate proximity to the container in which the cosmetic product is exposed for sale.

      So our understanding is even small products must supply an ingredients list in some way.

      You can report UK companies to Trading Standards – more info here: https://www.citizensadvice.org.uk/consumer/get-more-help/report-to-trading-standards/

  5. Hi
    we would like one confirmation on cosmetics products

    example our product have primary and secondary packing, and our query like to print the all legal requirements on English/french and Spanish language on the primary package and all legal requirements print on secondary package in English/dutch and Portuguese different language…..
    is it accepted?

  6. Hi, who do I contact within Europe about a manufacturer who is selling face creams with different ingredients on the box to what is on the jar inside? Surely this isn’t legal? They’ve fobbed me off saying they’re saving on packaging by using older boxes for newer jars of product. The codes etc are all correct and match the jar inside just not the ingredients.

    1. Hi – if you are in the UK, speak to Trading Standards. Here’s a link to find your local one: https://www.gov.uk/find-local-trading-standards-office. Outside of the UK, I’m not sure who the official bodies are for different EU countries, but there must be an equivalent that deals with “illegal trading practices”. It is a legal requirement to list the ingredients as found in the actual product being sold, so yes it sounds to us like this is not as per the law/regulations. All the best.

  7. Hello,

    Your article does not state which language the information must be in.

    I have received a carton of sunscreen all labelled in French only (apart from ingredients which are INCI). I do not know what to do with them.

    1. Hi Nora – the function of the product, contents, and any precautions/warnings must be translated into the language of the country it is sold in. So, if you buy in the UK, this information must be in English. Certain counties (including Austria, Poland and France) require that all information is translated into their official language, including marketing information. Hope that clears that up for you and we’ve added a “language” section to the article.

    2. To put the distubutors products details on a cosmetic product does it have to be registered to in the cpnp portal and who is the product registered by if it says dm
      Manufactured for then private lable company but the address is the manufacturer

  8. HI
    I have returned an after bath spray to Chanel, the packing has no best before and it has gone off. Sadly Chanel have said it is over a certain period of time and cannot help. I think the legislation should require a date of manufacture on the packaging.

  9. hi would this also be correct labelling for cold process soap? im really struggling to find the right info on this.
    many thanks

  10. Hi,
    I just looked at the Dr Botanicals website and I got confused about their label of “natural” ingredients. I almost bought their product on sale but then looked at the ingredients and they contain preservatives such as Sodium Benzoate and Potassium Sorbate and Phenoxyethanol. Is this safe? What else more safe, if anything, can be used to replace these preservatives? They write: “Vegan certified Dr Botanicals products, are made only of natural ingredients” but these preservatives and some other ingredients that have complicated names are definitely not natural, they are chemicals. So, that means everyone can use the term “natural” and confuse consumers….not cool. Not buying from them.

    1. Hi Evelyn, indeed the term “natural” doesn’t really mean anything. If you wanted to look more at ingredients, have a look at https://www.cir-safety.org/ who “review and assess the safety of ingredients used in cosmetics in an open, unbiased, and expert manner”. It’s a handy website to check out ingredients used in cosmetics.

  11. Hi Lisa,

    I ‘m wondering if it is allowed to use ” paraben and sulfate free ” on the outer lable as a statement?

    I’ve heard that it is not allowed from next year.

    Thanks for you help!

  12. I live in the UK and only speak English.i ordered some Vichy sunscreen online – the product shot online was of a bottle with English writing on it – yet I received Greek stock – have no idea what is written on the label, how to apply it etc – the company will not let me return or replace it with English stock – what is the law/regulation with this please? (Edited by H&MUA: removed company name)

    1. Hi Lisa, as far as we understand, cosmetics sold in the UK must have English included on labels to fulfil the legislation i.e. customer safety. As you said, you have no idea what the ingredients are, how to use, any safety advice etc. Please get in touch with CTPA (Cosmetic Toiletry & Perfumery Association) based in London: Tel: 020 7491 8891 | E-mail: info@ctpa.org.uk. They will know the current legislation and be able to advise you accordingly. All the best.

    1. Hi Ting – All cosmetic products supplied in the EU/UK, whether for consumer or professional use, must comply with European Cosmetics Regulation 1223/2009. It also requires safety assessments on the products. We’re not quite sure what you mean by “not fully tested” – as cosmetics have to be tested thoroughly 🙂

  13. This is all very thorough but we still need to go further. My daughter is peanut and nut allergic. All food is labelled with allergens in bold or a warning. There does not seem to be the same duty of care within the beauty industry. The facial scrub I bought yesterday listed jurglans regia as an ingredient. I did Latin at university but still had to google what that is. Why did it not say it was walnut even in brackets?? I just feel food labelling has become almost too thorough. The beauty industry needs to think about allergies and maybe start having warning labels on as well.

  14. Butter Bros Beard Co

    Fantastic Information, this has cleared up lots of things at once I was trying g to find out over the last few weeks, great job.

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EU labelling requirements for cosmetics