To guarantee consumer safety, cosmetic products must include in their packaging all the information necessary for their safe use. Specifically, according to Regulation (EC) No 1223/2009, cosmetic products shall only be made available on the market where their container and packaging bear the following information in indelible, easily legible, and visible lettering:
As far as the ingredient list is concerned, there are still other aspects to consider that deserve special mention:
The Cosmetic Regulation also states that where it is impossible for practical reasons to label the list of ingredients, as well as the precautions to be observed in use, this information shall be mentioned on an enclosed or attached leaflet, label, tape, tag, or card, which shall be referred by abbreviated information or the following symbol:
In addition, some related horizontal labelling requirements may also apply. The Aerosol Dispensers Directive 75/324/EEC and its adaptations to technical progress (94/1/EC and 2008/47/EC), establish the rules for aerosols with a capacity of more than 50 ml, including specific requirements related to flammability and pressure hazard related to aerosols dispensers and requiring the apposition of the so-called “inverted-epsilon” symbol certifying conformity with this Directive:
Moreover, sunscreen products may also be subject to additional label requirements specified on the Recommendation on the efficacy of sunscreen products and the claims made relating thereto. Although this is not a directive or a regulation, this document aims to standardise the way sunscreen products are labelled in the European Union (EU) and addresses the aspects relating to claims made for sunscreen products and the efficacy of such products, namely how the labelling of sunscreen products can be kept simple and comprehensible to assist the consumer in choosing the appropriate product. Among other aspects, this document establishes that:
In order to indicate that a sunscreen product offers a minimum UVA protection as endorsed in the Recommendation, Cosmetics Europe has issued a standardised UVA-label, consisting of the letters “UVA”, printed in a simple circular shape:
More recently, with the adoption of the Single-Use Plastics Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment and the new Commission Implementing Regulation (EU) 2020/2151 laying down rules on harmonised marking specifications on single-use plastic products listed in Part D of the Annex to the Directive, new labelling provisions are also in place for wet wipes (i.e., pre-wetted personal care and domestic wipes). Specifically, since 3 July 2021, packaging of wet wipes, with the surface area of 10 cm2 or more, shall bear the following printed marking:
Although not mandatory, other symbols and labelling policies may also apply to cosmetic products, in order to standardise the way information is presented and facilitate the sale of products throughout the EU market. For instance, it is recommended to affix the ℮-mark next to the nominal quantity of the product as it shows that the product complies with EU rules on the indication of the volume or weight and the measuring methods that you must use as a seller of pre-packaged products:
Additionally, at a time when sustainability is truly the watchword, packaging waste labelling has also been one of the most debated topics and although there is still no harmonisation, some practices have been adopted. The “Green Dot” financing symbol(see below on the left), for example, is widely used across the EU, being mandatory in Spain and Cyprus, and means that for such packaging a financial contribution has been paid to a qualified national packaging recovery organization; it does not have, however, any environmental or recycling meaning. Specific national requirements are also in effect in some EU member states such as Italy, which introduced, in 2020, a mandatory environmental labelling on the packaging of products, and France, where the “Triman” symbol introduced (see below on the right) by the Decree 2014-15733, must be mandatorily displayed on the labels of recyclable products, including cosmetics, since 1 January 2022.
As can be seen, checking the labelling requirements that your cosmetic products must meet can be a challenging task, demanding attention to all applicable requirements and effective communication for the prevention of non-conformities. Cosmedesk offers a labelling review functionality, which in addition to generating the list of ingredients of your product, provides a checklist with the general provisions, easily editable and adaptable to your product type. At the end, you can generate a labelling review report that you can share with your team, customers, or partners.
Commission Implementing Regulation (EU) 2020/2151 of 17 December 2020 laying down rules on harmonised marking specifications on single-use plastic products listed in Part D of the Annex to Directive (EU) 2019/904 of the European Parliament and of the Council on the reduction of the impact of certain plastic products on the environment