When designing labels for cosmetic products, one must primarily keep in mind the binding legal regulations that strictly define the content of information that must be included on the label. The rules for labeling cosmetic products are regulated by EU Regulation 1223/2009. This regulation provides detailed guidelines regarding the appearance of cosmetic labels. This is intended to ensure a high level of consumer protection, including health protection.
What information must be included on a cosmetic label?
Article 19 of Regulation 1223/2009 lists a series of information that must be placed on the cosmetic product label. These are primarily:
- data of the responsible person
- date of minimum durability of the product
- nominal content of the packaging
- particular precautions
- batch number
- function of the cosmetic
It is worth remembering that most of this information must be placed on both the outer packaging (e.g., a cardboard box) and the container, i.e., the packaging in direct contact with the product (e.g., a bottle, vial, tube). However, data such as the batch number and the list of ingredients are excluded from the double labeling obligation—these may be placed exclusively on the outer packaging.
How to indicate cosmetic ingredients on the label?
In the case of the list of ingredients, common ingredient names specified in the dictionary of ingredient names, taking into account the International Nomenclature of Cosmetic Ingredients (INCI), should be used.
The order of ingredients on the label must be organized according to their mass at the time they are added to the product, in descending order (i.e., from the ingredient of which there is the most to the ingredient of which there is the least). Exceptions are ingredients with a concentration of less than 1%, the order of which on the label is arbitrary. The deviation from the principle of maintaining the correct order also applies to colorants (except for hair dyes), which may be listed in any order.
What additional requirements must cosmetic labels meet?
The Regulation not only defines the list of information that must be included on the product label. It explicitly requires that the information be indelible, easy to read, and clearly visible.
Additionally, the indication of minimum durability or the period after opening may be expressed using symbols.
In what language should the information on the cosmetic label be placed?
The Regulation introduces an obligation to translate certain elements of the cosmetic label into the language of the country where the cosmetic is made available to the end user (most often the consumer). This is intended to protect the interests of consumers, specifically to prevent them from being misled.
The label elements that must be translated into the local language include: nominal content of the packaging (i.e., mass/weight), date of minimum durability of the product, function of the product, and particular precautions.
What if placing information directly on the cosmetic is not possible?
If, due to the properties of the product (e.g., small size), it is impossible to apply information directly to the product packaging, you can:
- place the information on, or a label, tag, tape, card in an enclosed leaflet. If even these methods fail, the information should be displayed near the container in which the product is offered for sale, or
- include the information in a shortened form or by using the aforementioned symbols.
What are the penalties for labeling a cosmetic with an incorrect label?
A lack of compliance of the information on the cosmetic product label with EU regulations involves high sanctions. In Poland, fines reach up to 70,000 PLN.
Improper labeling can also lead to the disruption of the functioning of an entity that is a link in the supply chain, due to the imposition of the obligation to take corrective measures and withdraw the product from the market.
The author of the article is legal assistant Patrycja Kiszka
