Product labelling and claims

EU and UK cosmetics labelling requirements

Just as attractive labelling is one of the most important features of the product when it comes to sales, so is correct labelling essential for the compliance of the cosmetic product with the cosmetics Regulation 1223/2009/EC and the UK Schedule 34 to the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, as labelling is an important part of the product information file.

The regulation contains various cosmetic labelling requirements and very specific rules regarding labelling, which have to be followed and are described in article 19 of the regulation. The notification of cosmetic products is not possible without the compliant product labels.

Without prejudice to other provisions in this Article, cosmetic products shall be made available on the market only where the container and packaging of cosmetic products bear the following information in indelible, easily legible and visible lettering… (EU Regulation 1223/2009, Article 19.1)

According to the regulation, the container and the outer packaging of cosmetic products have to bear the following information in indelible, easily legible and visible lettering:

The name and address of the responsible person

The country of origin if the product is imported from countries outside of the EU/UK

Nominal content of the product at the time of packaging, given by weight or volume

Date of minimum durability or period after opening

Precautions for use

Batch number of manufacture or the reference for identifying the cosmetic product

Function of the cosmetic product, unless it's clear from its presentation

List of ingredients (which may be indicated on the outer packaging alone)

Some of these elements may also be mentioned on an enclosed or attached leaflet, label, tape, tag or card if it's impossible to list them on the labels. In that case an open book symbol should be placed on the label, which indicates that some information about the product can be found elsewhere.

The open book symbol indicates that some information about the product can be found elsewhere.

Cosmetics regulatory services

The EU consists of 27 different countries and the cosmetic labelling laws require certain information on the labels to be translated into different languages. Some countries have more than one official language, which further complicates things and requires that certain information appear in more than one language on the labels.

Cosmetics regulatory servicesCosmetics regulatory services

Required languages for cosmetic labels (In the EU and EFTA)

CountryRequired language (s)
AustriaGerman
BelgiumFrench and Dutch
BulgariaBulgarian
CyprusGreek
CroatiaCroatian
Czech RepublicCzech
DenmarkDanish
EstoniaEstonian
FinlandFinish and Swedish
FranceFrench
GermanyGerman
GreeceGreek
HungaryHungarian
IrelandEnglish
ItalyItalian
LatviaLatvian
CountryRequired language (s)
LithuaniaLithuanian
LuxembourgGerman or French or Luxemburgish
MaltaMaltese or English
NetherlandsDutch
PolandPolish
PortugalPortuguese
RomaniaRomanian
SlovakiaSlovak
SloveniaSlovene
SpanSpanish
SwedenSwedish
UKEnglish
IcelandIcelandic
LiechtensteinGerman
NorwayNorwegian
SwitzerlandFrench and German and Italian

Cosmetic product claims

Every claim that appears on the cosmetic product label, on the website where the cosmetic product is presented, in TV commercials etc. has to be substantiated unless it's a clear exaggeration or it's obvious for the type of the cosmetic product. It is a responsible person's task to ensure that all of the claims made regarding the product are substantiated.

In the labelling, making available on the market and advertising of cosmetic products, text, names, trademarks, pictures and figurative or other signs shall not be used to imply that these products have characteristics or functions which they do not have. (EU Regulation 1223/2009, Article 20)

The EU published a separate regulation (Regulation 655/2013), which deals specifically with cosmetic product claims and is laying down 6 common criteria for the justification of claims used in relation to cosmetic products:

Legal compliance

Truthfulness

Evidential support

Honesty

Fairness

Informed decision-making

These common criteria are set in order to assess whether or not the use of a claim is justified. Regulation 655/2013 also provides guidance on the use of “free from claims” and hypoallergenic claims.

Additionally, there are is also a number of various guidelines for the so-called borderline products, which can also help determining which claims can be made for cosmetic products (as opposed to medical devices, biocides…) or how they should be phrased in the product is to be classified as a cosmetic.

Cosmetics regulatory servicesCosmetics regulatory services
Cosmetics regulatory servicesCosmetics regulatory services

How to prove cosmetic product claims

Best practices for claim substantiation evidence are also described in the Regulation 655/2013. Evidence for substantiation the claims can in general be based on:

Experimental studies (in silico, in vitro, ex-vivo, with instrumental or biochemical methods, sensory evaluations, etc.)

Consumer perception tests

Evidential support

Use of published information

Where a claim is based on scientific research or testing, that work should have been conducted in accordance with best practice (consult independent experts).

If you would like to find out more about the labelling requirements in the EU and UK and check if your product labels are indeed compliant with the EU and UK Cosmetics Regulation, please don't hesitate to contact us.

Contact us to find out which claims we can help you prove

And what do they say about us?

Pharmaplast began to work with CE.way almost one year ago. CE.way is our cosmetics consultant who look after compilation of PIF, safety assessments and CPNP notifications. In addition to this, CE.way is our European representative as our company is not located in Europe. Working with CE.way has been a joy so far. Their replies are very swift and Mr Tadej is very cooperative, helpful and with a deep knowledge about the cosmetics regulations. In addition to this, CE.way is very cost effective company in comparison with their European counterparts. For all the above reasons, I really recommend CE.way to other cosmetic product manufacturers.

Mena, Egypt

Pharmaplast

We were looking for a stand-alone service, not too sure what to expect... The professionalism, the assistance and the responsiveness were very much appreciated, amongst the best we have ever experienced.

Carol, Switzerland

Alpure

We are a small manufacturing company located in the US. We recently used CE.way Regulatory Consultants to help guide us through the Cosmetic regulatory changes that have taken place in the EU. They were instrumental in helping us understand the new laws and streamline the entire process. I would highly recommend their services.

Lena and Clay, USA

IBP

We didn't have any knowledge about the registration process for cosmetics in EU and were very concerned about this, but we met CE.way and they gave us whole packages of consultation and support. It was really helpful and we could do the registration without any problem. We will definitely ask CE.way again when we have new product to register in EU.

Masa, Japan

Nash Corporation

We used Tadej and CE.way for EU compliance with our products. He was very helpful and worked directly with our lab which made the process much easier for us. Tadej worked with me directly on all of our products to make sure I had the right documents. I really liked the attention to detail and how I could work with the owner of the company directly. I would highly recommend their services.

Steve, Canada

Curly Hair Solutions

Tadej from CE.way is the best consultant I've ever worked with. It's a great luck that we've found him. He is knowledgeable, fast, helpful & always ready to answer a million questions that we have. We had no exposure to cosmetics market before, so we didn't even know where to start. So he helped us to do EVERYTHING. The quality of service for the amount of money that we pay is absolutely the best! BIG THANK YOU to you Tadej & we'll definitely keep working with you!

Natalia, USA

Hi Tadej, Thank you for your highly professional approach, extremely helpful information and advice on getting our product registration under way and completed in record time! What we thought to be a very tiresome and laborious task was made quick and simple. Thank you again! The Thermitek Team.

Rene, Greece

Funkitup

It's been our first time lodging an application for EU Compliance. Although a big task, Tadej from CE.way made it as painless as possible. His patience and help were invaluable. He was so responsive and was available at all times to work with myself and my manufacturers. We now have our first round of product successfully assessed and notified. I will be placing our next round asap for notification, I can't recommend CE.way highly enough, thanks Tadej - Heather Spierings Eye of Horus Cosmetics.

Heather, Australia

RA Cosmetics

CE.way offers professional and reliable service. The team is diligent and extremely helpful throughout the whole process. We are very satisfied the way the work was executed. We definitely recommend CE.way to others.

Tamar, USA

Nuvision

CE.way made the whole EU process easy to understand. They were very responsive to all our needs.

James, USA

Eufora

This is a major investment for a small business like ours and it took me a few years to find a company (CE.way) that I felt comfortable working with! That speaks volume to my appreciation of the quality of your communications with me.

Vivian, USA

VB cosmetics

Our company had a great experience with CE.way. They were very organized and provided us with a detailed roadmap of exactly what we needed to gather on our end for them to put together our Product Information File and complete the notification process for the EU. They continued to help us along the way, providing quick feedback on any changes we needed to make to a document for it to work and reminders on what we still needed to provide. They are organized, knowledgeable, fast, and attentive; I would absolutely recommend them to any companies looking to get their products approved in the EU.

Cyrus, USA

SBBM

CE.way's assistance was tremendous, helping our company navigate the EU cosmetic regulation and efficiently get products to market.

Mike, USA

Inverness

Our cooperation with Tadej and his team at CE.way Consultants aimed to assist us to launch our products in UK for the first time. Tadej is a very hands on and always quick with his responses. The process was smooth and beyond our expectations in terms of cost savings and the speed with which we accomplished our goal. We look forward to working with them again.

Ruta, UK

Art de Parfum

We are really appreciate your speedy replies and clear and understandable guide. As there are a lot of differences in cosmetic regulations between Japan and EU first we thought that it would be hard to make all necessary procedures for our products compliance with EU laws, but thanks for your prompt support, all procedures were made smoothly. And now we are successfully selling MT Metatron in EU. We also thinking to expand our other brands in EU and when we start - definitely will ask your company for assist again.

Olga, Japan

MT Cosmetics, Inc.

After a less than pleasurable experience with another company, we found CE.way and we can honestly say that it could not be more beneficial for our brand. The whole notification process is made as easy as possible. The people at CE.way are all very accessible, knowledgeable and always ready to answer questions. CE.way is a great asset to our company and we are grateful for all the help and support we receive. Navigating through all rules and regulations alone is impossible, with the team at CE.way, we have the best support that we could ask for. Highly recommended in all aspects from their support to their reliable service!

Daniel, USA

NCLA

Testimonials

Need help with the cosmetics regulations and testing?