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The Labelling Legislation
Product labelling in the EU is regulated by law under the EU Cosmetics Regulations (1223/2009) – and the regulations main purpose is human safety.
Cosmetic laws apply to products that are intended for sale and those given away for free, as the making and selling of cosmetics is considered to be a commercial enterprise. The penalties for non-compliance can be severe, and ignorance of the law is not a defence.
All cosmetic and personal care products must have a label. It must be indelible and easy to read, and include the following information:
- Name and address of manufacturer or supplier
- List of ingredients
- The amount of contents (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 if use is not obvious)
Name & Address of Manufacturer
- The name and address of the manufacturer or supplier is required on both the primary container and any 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. If there is no outer packaging, it must be on the main container.
- There must be the title “Ingredients” followed by all the ingredients contained in the product, in descending order of concentration.
- The ingredients have to follow a standard with regard to terminology so there is consistency between different brands. This is set in the International Nomenclature for Cosmetics (INCI). It means that wherever you buy the product, the ingredients list is using the same terms, keeping the ingredients used easier to identify;
- The term “parfum” means perfume, which can consist of many ingredients. These do not have to be listed individually, with the exception of certain ingredients which must be shown on the label;
- The term “aroma” means flavour (e.g. for things like toothpaste) and the raw materials in the aroma do not need to be listed, with a few exceptions;
- Ingredients are shown in descending order of weight. For ingredients that are in concentrations of less than 1%, they can be listed in any order after all other ingredients;
- Colouring agents are shown by “Cl” followed by its number and can be listed in any order after all other ingredients;
- For a range of coloured products that come in various different shades, the symbol “+/-” or words “may contain” before the list of colours means that not all the colours listed are necessarily used in every shade;
- Nano ingredients must have “(nano)” after it e.g. “titanium dioxide (nano)”
The Amount of Contents
- The amount of product at the time of packaging must be given on the label, and can be shown as a weight or volume.
- For the EU, the net contents must be given in metric (grams, millilitres), though some may also list the weight for other markets, like the USA (so the weight will also be listed in US OZ).
- The “e” symbol (which means estimated) is a guarantee that the product has been filled in accordance with 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 single application and anything less than 5g or 5ml.
Cosmetic products must indicate when they are best used by or how long they should be kept. This is either via a “Best Before Date” or a “Period After Opening” (PAO) symbol. A PAO symbol is far more common, as most cosmetics are formulated to have a long shelf life.
Best Before Date
- Any cosmetic product that has a lifespan of less 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 (month/year) 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”, and “Best Before End” to “BBE”. The “egg timer” symbol may also be used.
- Any special precautions to be observed e.g. storage conditions, in order to maintain the product as required by the regulations must also 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 an open pot with a number in it and an “M” – this shows the number of months that the product is safe to use once it has been opened.
Warning Statements & Advice
- Not all products have this on them. 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. 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.
- This is only required on a label if the function of the product is unclear from the presentation and design. For example, the function of lipstick is clear. However, a depilatory cream could not be labelled just as “cream” – it would have to state that it was for hair removal.
- Where there is not enough space on a product to include the ingredients list, any warnings and instructions for safe use, the manufacturer will include that information somewhere else in the packaging; for example, on a leaflet.
- The “Hand Book” symbol shows that information is included elsewhere in the packaging.
Other Information Given on a Label
A product’s label can provide other information, which is down to the manufacturer rather than it being a legal requirement.
Organic or Natural
- There is no legal definition for organic cosmetic products in the EU. 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, there are five European certification bodies that have developed the Cosmetics Organic Standard (COSMOS) to try and harmonise 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. 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. 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 may take liberties on labels and can 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 may contract another company to animal test on its behalf.
- Manufacturers may state on a label what is not found in their product. It’s 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. It can be useful to know.
- The “Green Dot” is a trade mark that shows the company has membership of 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.
- In the UK, there are a number of competing recovery and recycling schemes, so this logo is not used. However, you will still the green dot on packaging in the UK for products that are also sold in other European countries.
Languages Used on Labels
There are 32 countries that come under the legislation – the 27 member states of the EU, plus Iceland, Liechtenstein, Norway, 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; products sold in Greece must be in Greek; Switzerland requires French, German and Italian.