Cosmetic labelling in Europe

The European Cosmetic regulation requires certain information about cosmetic products to be available to the customers. But where to start with all the confusing symbols, foreign-sounding names, and lack of space on the labels? Read on to find out!

The general cosmetic labelling requirements

When placing a cosmetic product on the EU market the following information must be present on cosmetic packaging:

• Address of the responsible person

• Country of origin for products imported into EU 

• Date of minimum durability or Period after opening (PAO)

• Precautions for use or warning statements

• Function of the product

• List of ingredients

• Batch number

• Declared quantity of contents

All the above information must be present on the container when required (primary packaging e.g. bottle, jar, etc) except the list of ingredients that must be present on primary packaging when secondary packaging, e.g. carton or box is not available.

Let us look at some practical considerations to help you on your way to compliant cosmetic labelling.

Cosmetic labelling - practical considerations

The first thing to consider when preparing a cosmetic product label is the language of the country where the product will be sold. All EU countries require labelling information to be expressed in their national language. Some countries, like Malta, require labelling to be available in both national language, i.e. Maltese and also in English.

The name and address of the Responsible Person (RP) can be abbreviated as long as it is still possible to identify the person and the address. When several addresses are included in the labelling, the one where Product Infomation File (PIF) is made available should be highlighted. The name and the address of RP must be presented on both primary and secondary packaging.

The country of origin is only required when the cosmetic product is imported into the EU from outside of the block, e.g. from the USA, Canada, China, etc. At the moment the UK doesn't have to be listed but in the future, post-transition period, when importing cosmetic products from the UK into the EU it will be mandatory to specify the UK as country of origin. The country of origin usually follows the reference 'made in...'.

Date of minimum durability (expiry date) or Period after opening will depend on the characteristics of the cosmetic product. For products that remain safe for use for 30 months or less if stored under appropriate conditions the expiry date is mandatory and can be indicated on the packaging with 'egg-timer/hourglass' symbol or words: 'best used before the end of'. For products with minimum durability over 30 months expiry date is irrelevant and instead, the 'open jar' symbol should be used to indicate Period after opening (POA). POA indicates the length of time after opening for which the product is considered fit for use by the consumer. The open jar symbol must include or has to be followed by the period in months and/or years. 

Precautions for use or warning statements if relevant need to appear on both the container and the packaging. Where it is impossible for practical reasons to print this information on the label, e.g. when the product container is too small, the information must be provided on an enclosed leaflet, card, tag, etc. 'Hand-in-book' symbol should be used to inform the consumer that there is additional information available or abbreviated information should be provided.

Product function must be included on the packaging unless it is obvious to the consumer from a combination of the presentation e.g. lipstick, its name e.g. shampoo, its claims e.g. waterproof mascara, pictures, logos or other elements e.g. a picture of an eye on eye shadow.

All substances added to the product formula must be listed on the packaging. The list of ingredients must start with the word 'ingredients' and must be in the order of descending quantity for ingredients added in more than 1%. Ingredients added in 1% or less can be listed in any order after those in concentrations of more than 1%. INCI names must be used and also 26 specific substances listed in the regulation must be indicated on the label if their concentration is above a threshold in the cosmetic product. These substances are known allergens and consumers must be informed about their presence, regardless of whether added directly or as a component of complex mixtures e.g. essential oils, botanical extracts, or fragrances. Perfume, aromatic, or flavouring compositions don't need to be disclosed on the label, but their allergenic components must be disclosed.

The regulation doesn't specify the format of batch number, the decision on the batch numbering system belongs to the responsible person. Normally batch number would consist of a combination of letters and/or numbers and must be presented on the packaging in order to identify a batch of cosmetic products through the supply chain, in case of a recall or other issues like allergic reactions. The batch number has to be present on both primary and secondary packaging unless it is impossible for practical reasons (primary packaging is too small); then it can be included on the secondary packaging only.  

In Europe, the nominal quantities have to be expressed in metric units of weight or volume, e.g. in grams, milligrams, milliliters, etc. In the case of packaging containing less than 5 grams or 5 milliliters, the quantity doesn't have to be listed.

The above list is by no means exhaustive but will help you get started with compliant cosmetic product labelling in Europe.

Please get in touch via info@moleculeregulatoryservices.co.uk for further information on labelling or other regulatory topics like CPSR (Cosmetic Product Safety Report).

Watch this space for upcoming blog posts exploring further aspects of cosmetic regulations and how to make and sell your cosmetics in a safe and compliant way. We will make it simple!

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