Cosmetic Products Labelling Requirements in the European Union

Cosmetic products sold in the European Union must be labelled according to the provisions of the Cosmetic Products Regulation. Cosmetic labels must, for example, contain information about the company selling the product, content, batch number, and intended use.

Thera are also restrictions concerning product claims, and requirement related to precautions and warnings.

Further, we also cover labelling requirements that are part of regulations other than the Cosmetic Products Regulation, but that are still applicable to cosmetic products.

Consumer Information

Article 19 of the Cosmetic Products Regulation requires the packaging and containers of cosmetic products to bear the following information:

a. Responsible person’s registered name and address

b. Product’s nominal content, by weight or volume, at the time of packaging

c. Date of minimum durability and either the symbol in point 3 of Annex VII or the words “best used before the end of”

d. Precautions listed in Annexes III to VI to be observed during the product’s usage, and special precautionary information for professional-use cosmetic products.

e. Cosmetic product’s reference or batch number of manufacture

f. Cosmetic product’s function, unless the product’s presentation makes this obvious

g. A list of ingredients, preceded by the word “ingredients”, indicated on the packaging

Warnings and Conditions of Use

Annexes III, V, and VI set warning requirements and conditions of use for specific substances and products. In particular, some cosmetic products containing certain substances must bear the warnings and conditions of use on their labels.

Annex III: Restricted substances

Annex III lists restricted substances and certain conditions by which they are restricted (e.g., maximum concentration, body part, or product type). It also establishes warnings that must be printed on the product label, as well as conditions of use (e.g., “Avoid contact with eyes”).

Annex V: Preservatives

Annex V lists substances that are permitted for use as preservatives in cosmetic products. Specific substances have their respective warnings.

Note that per this annex’s preamble, all products listed in the annex that contain substances that release formaldehyde in concentrations exceeding 0.001% must bear the warning “releases formaldehyde”.

Annex VI: UV Filters

Annex VI includes a list of substances permitted as UV filters in cosmetic products. Some specific substances have warnings and conditions of use.

Examples

Here we list some examples of warnings and conditions of use, for different substances. Note that, for some substances, there exist multiple conditions of use and more than one warning. For the three substances below, we state only one warning and one condition of use.

Substance	Annex	Product type	Warning	Conditions of use
Thioglycolic acid and its salts	III	Hair waving or straightening products	“Contains thioglycolate”	“Avoid contact with eyes”
3-Iodo-2-propyny lbutylcarbamate	V	Rinse-off products	/	“Not to be used for children under 3 years of age”
Titanium dioxide	VI	Face products containing Titanium Dioxide (nano) coated with Alumina and Manganese Dioxide	/	“Not to be used on the lips.”

Product claims

Article 20 requires that the text, names, pictures, or signs on the labelling and advertising of cosmetic products should not bear false claims. In practice, the responsible person must not claim that their cosmetic products have attributes or purposes that the product does not have.

False claims on the packaging or other labels can leda to recalls. For example, CIRS reported that a German company was fined EUR 500,000 for selling cosmetic products with misleading claims.

The claims must comply with the common criteria specified in the Annex of Regulation (EU) No 655/2013. We list and briefly explain the common criteria below.

a. Legal compliance — Prohibited claims include claims that the EU has authorised or approved the cosmetic product, or claims that the product has benefits that are simply legal compliance.

b. Truthfulness — If the product is claimed to contain a specific ingredient, that ingredient must be present in the cosmetic product.

c. Evidential support — Sufficient and attestable evidence must support claims made for cosmetic products.

d. Honesty — Claims that a cosmetic product has a specific characteristic must not be made if similar products have that same characteristic.

e. Fairness — Claims for cosmetic products must be factual and must not disparage the product’s ingredients, competitors, or their products.

f. Informed decision-making — Claims must be obvious, coherent, and contain information for end users to make informed decisions.

The responsible person may also provide information on the fact that no animal testing has been carried out during the cosmetic product’s development (as long as the information is correct).

Instructions

Article 3 requires cosmetic products to include usage and disposal instructions. However, note that the regulation does not specify where these instructions must appear (e.g., on the packaging or a separate pamphlet).

Annexes III to VI set substance-specific instruction requirements. Here are two examples from Annex III:

a. Oxalic acid, its esters and alkaline salts — “For professional use only”

b. Lithium hydroxide — “Contains alkali Avoid contact with eyes Can cause blindness Keep out of reach of children”

Placement

In this section, we list the information concerning the placement of different label information.

Consumer information

The cosmetic product’s container and packaging must permanently, clearly, and visibly bear the information listed in the “Consumer Information” section of this guide (see above).

If the cosmetic product’s size prevents the placement of some of the information mentioned above, said information may appear enclosed or attached card, label, leaflet, tag, or tape.

Small cosmetics

For small cosmetics such soap and bath balls, the list of ingredients can provided in a notice close to the container for sale, if the attached card, label, leaflet, tag, or tape is practically too small to bear this information.

Warnings and conditions of use

The regulation requires that certain cosmetic products containing specific substances as listed in Annexes III to VI must also include usage precautions on the label, as well as special warnings and usage conditions for professional-use cosmetic products.

Claims

Note that the requirements regarding product claims also pertain to the label on the cosmetic product’s container and packaging.

Other Labelling Requirements

Other directives and regulations, such as the Aerosol Dispenser Directive and the General Product Safety Regulation, also establish labelling requirements relevant to cosmetic products.

Aerosol Dispenser Directive

Article 8 of the Aerosol Dispenser Directive requires that the label on the aerosol product contain the following:

• The marketer’s name and address
• The inverted epsilon symbol, certifying conformity
• Code markings for identification
• Warning statements in Annex 2.2
• Net contents by weight and volume

General Product Safety Regulation

The General Product Safety Regulation requires manufacturers to provide information, such as:

• Product identification (e.g., type, batch, serial number)
• Name and address (or registered trademark)
• Contact details (e.g., postal and email address)
• Age suitability
• Instructions for safe use and disposal
• Warnings
• Other relevant product information