“EU labelling requirements for cosmetics” is not a very sexy title, we know! However, 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.
EU Cosmetic Legislation
Product labelling in the European Union (EU) is regulated by law, namely the EU Cosmetics Regulations (1223/2009). The purpose of these regulations is human safety.
Cosmetic laws apply to any product 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.
The penalties for non-compliance can be severe. Furthermore, ignorance of the law is not considered a defence.
EU Labelling Requirements for Cosmetics
All cosmetic and personal care products must have a label somewhere on the packaging. It could be on the primary packaging, such as the bottle or jar the cosmetic comes 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 its use is not clear).
Name & Address of Manufacturer
- The name and address of the manufacturer (or supplier) are required on the primary container and any secondary outer packaging.
- The country of origin must also be on the label if the product is made outside of the European Economic Area (EEA).
- Ingredients must 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 in the product, with a few exceptions.
- The ingredients must be listed in descending order of weight. The exception is ingredients with a concentration of less than 1% – they can be listed in any order (after all the main ingredients).
- Ingredients have to be named following a standard terminology. It ensures consistency between different brands. It also makes it easier for the consumer to identify any ingredient that causes them issues, like an allergic reaction.
- The International Nomenclature for Cosmetics (INCI) sets the names for all cosmetic ingredients. Therefore, the ingredients listed on a product always have the same name, no matter where you buy the product.
- The term “parfum” means perfume. It can consist of many ingredients. However, these ingredients do not have to be listed individually, except certain ones that have to be on the label.
- The term “aroma” means flavour (for things like toothpaste). The raw materials in the aroma do not need to be listed, with a few exceptions.
- Colouring agents are identified by “Cl”, followed by its number. They can be listed in any order after all other ingredients are listed.
- Coloured products often come in various shade options – for example, lipstick and eyeshadow ranges. Here, the symbol “+/-” or words “may contain” can be seen before the list of colours. It means not all the colours listed are necessarily used in that particular 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 on the label. The label may have this as either weight or volume.
- The net contents must be given in metric for the EU market. However, you may also see ounces (“oz”) listed as well. It is because products may be sold in countries where they don’t use the metric system. For example, the weight will also be listed in “US OZ” for products sold in the USA.
- The “e” symbol (which means “estimated”) is a guarantee that the product is filled correctly, as 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 useable. Products with a lifespan of fewer than 30 months must have a “Best Before Date”. Products with a lifespan of over 30 months have a “Period After Opening” (PAO) symbol.
There are some exceptions to this requirement – for example, aerosol products (sealed airtight), perfumes with high alcohol content, and single-use packs.
Best Before Date – Lifespan of fewer than 30 months:
- Cosmetic products with a lifespan of fewer than 30 months from the date of manufacture must have a “best before the end of” date on the packaging.
- It is shown by the words “best before” followed by the date (shown as month and year). It indicates when the product either ceases to fulfil its intended function or no longer meets safety requirements as per the regulations.
- “Best before” can be abbreviated to “Exp”. “Best Before End” can be shortened to “BBE”. The “egg timer symbol” may also be used.
- Labels must also show any special precautions that need following. For example, any special storage conditions required to keep the product in good condition must be 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. It means once the consumer opens a product for the first time, it has a shelf life of so many months (under normal usage).
- The “little pot symbol” indicated the shelf life. It has a number in it followed by an “M”, indicating how many months the product is safe to use after opening. 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.
- It is for any “special information”, like how a product must be used properly or disposed of safely. It also includes warnings about ingredients, preservatives, UV filters, or how not to use a product. For example, precautionary advice could be “Avoid eye area” or “Do not use to dye eyelashes”.
Batch Number or Lot Codes
- The manufacturer or supplier prints a unique code on the label.
- Should there be any complaints or issues with a product, it allows a manufacturer to identify which batch made the product.
- It is only required if the product’s function is unclear from its presentation and design. For example, a lipstick’s function is clear from how it looks; therefore, it does not need to be labelled “lipstick”. However, it would not be acceptable to label a depilatory cream 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 key information, the manufacturer has to include that information somewhere else.
- For example, it could be on a leaflet contained in the box. There are also labels that peel back to reveal another layer underneath with more information on it.
- The “Hand Book” symbol shows that additional information is included somewhere else in the packaging.
Other Information Given on a Label
In addition to the legally required information, a label can provide all sorts of other information. It all depends on what the manufacturer wants to tell the consumer. Here are some things commonly seen on cosmetic products.
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. Consumers are made to believe they are buying something pure, better or safer. In some cases, they may be. However, the opposite is also true.
- To find certified organic products, look for logos from the organisations that approve products as organic.
- Five European certification bodies have developed the Cosmetics Organic Standard (COSMOS). It has the aim of harmonising organic standards across the globe. They have high standards – to achieve COSMOS certification, a product has to meet a strict set of criteria. It 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.
- Manufacturers use them to convey that they think the product will not cause a bad reaction when used. However, the company needs to provide no proof – anyone can put these terms on a label.
Not Tested on Animals
- Some companies take liberties on labels and use word trickery to create the impression that their products are not animal tested. For example, “We do not test on animals” may mean 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 in their product. In this case, it is often things like parabens, preservatives, synthetic fragrance, or colourants – 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”. It 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
Thirty-two countries come under the legislation – the 27 member states of the EU, plus Iceland, Liechtenstein, Norway, the UK, and Switzerland. The cosmetic labelling laws require that certain information on a label has to be in the official language(s) of the country where sold.
The information must include:
- The nominal contents (weight or volume).
- The date of usage.
- 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, no matter where in the EU the product is sold, the ingredient names will be the same.
Reporting Non-Compliant Cosmetics in the UK
If you think a cosmetic product offered 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. The Citizens Advice provides help on a wide range of consumer issues. However, you cannot contact Trading Standards direct. You must contact Citizens’ Advice, who will then pass your complaint to Trading Standards.
The 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
- This article on EU labelling requirements for cosmetics is for informational purposes only and does not constitute as legal advice. 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, including Making and Supplying Cosmetics in EU and FAQs on Making Cosmetics.
- EU labelling requirements for cosmetics as per the Cosmetic Products (Safety) Regulations 2008.
- 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 like anti-dandruff and preservative.