Product Labelling Review for Cosmetics

If you want to market your cosmetic products in the European Union and the United Kingdom then you have to comply with Cosmetics Regulation 1223/2009/EC of the EU and similar laws in the UK regarding the contents of your label. Here we discuss the functions, and contents of labels along with differences in laws of both countries and most importantly what can be the negative consequences of not complying with the regulations.

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What is a Cosmetic Product Label?

It is a substantial component of the cosmetic product which is designed to serve multiple important purposes at the same time. On the one hand, it is a marketing asset to make the product container attractive enough so that a potential consumer wants to buy it. On the other hand, it should serve the regulatory standards of the respective target market by providing every essential detail.

What are the functions of Cosmetic Product Labelling?

The main aim of Cosmetic Product Labelling is to Provide clear Information to consumers to help them make an informed decision Suppose, Mr. Joe is allergic to a certain substance ‘S’, and due to a misleading label on sunscreen and no explicit mention of ‘S’, he got allergic and had to bear an enormous cost for his treatment.

To save the general public from deceptive practices or unfortunate conditions that could have been prevented just by an explicit mention on the label, Health Authorities worldwide regulate their cosmetic product labelling and put forward rules to make any entity legally eligible for selling in their respective geographies.

What are the Contents of a Good Product Label?

What kind of information is to be included on the label depends on the country, but the general idea is What the product does, directions to use for best results, product warnings, list of ingredients.

Here is the List of general information that is to be included on the product label :

  • List of product ingredients (with the net content of each)
  • How to use it in the best way
  • Best conditions to store
  • Contact details of Importer / Representative / Manufacturer
  • Date of Expiration
  • Unique Code Details (like Lot number or batch code)
  • Risks or Precautions 
The details mentioned should be concise and should comply with the laws of that particular market. Let’s see the requirements of the EU and UK markets to understand various labelling criteria.

What are the Relevant Laws and Regulations for Product Labelling?

1)European Union Market
  •  Cosmetics Regulation 1223/2009/EC of the European Parliament and Council on cosmetic products is the main regulatory framework for cosmetic products in the Union.
  • Adopted on 30 November 2009
  • Aims to ensure a high level of safety for human health, simplify procedures, streamline terminologies, and harmonize rules in the Union.

The regulations make it an offense to supply a cosmetic product with incorrect labeling.
Note : The regulation applies to cosmetic products, but not to medicinal products, medical devices, or biocidal products.
According to the EU regulation: 
(i) All cosmetic products must be labeled in a language that can be easily understood by the consumer.
(ii) The container and packaging of cosmetic products must display the product’s function in indelible, easily legible, and visible lettering.
(iii) the packaging must also include the name, trade name, and address of the manufacturer or person responsible for marketing the product. Apart from the general contents requirements stated above, the label should include the following according to EU Regulation:

  • The nominal content of the product, expressed in weight or volume
  • A list of ingredients (INCI list = International Nomenclature of Cosmetic Ingredients). The ingredients must be listed in decreasing order of weight, except those present in concentrations of less than 1% for non-coloring ingredients and less than 0.1% for coloring ingredients.

To know more about placing your Cosmetic products in the European Market with ease, you can get in touch and avail of our Label Review Services. Get in touch for an assessment of whether your cosmetic labels are at par with Regulations with the help of our Experienced Regulatory labelling experts.

2)United Kingdom Market
All cosmetic products placed on the UK market must comply with Schedule 34 of the Product Safety and Metrology (Amendment and Transitional Provisions) Regulations 2022. The labelling requirements for cosmetics in the UK are similar to those in the EU. The label must include the same information as mentioned above. However, as a responsible manufacturer of cosmetic products looking to sell in the European Union and the United Kingdom, one must be aware of the key differences between the requirements of both.

Difference between the Labelling Requirements of the UK and the European Union:

  • Placement of Contact  Information about the Responsible Person
    In the EU, this info should be on the label itself, and in the UK, this information can be included on the packaging instead.
  • [Note : The Responsible Person can be a manufacturer, importer, or distributor or in the best case a recognized third-party consultant like cert3global]
  • Explicit name and function mention
    It is not required in the UK, unlike the European Union.
  • Language and Measurement Standards
    The Union Requires the language of the labelling to match the local market, but in the UK Language can be English, Welsh, or Irish Gaelic. The Nominal content of the product can be expressed in weight or volume in the EU. Whereas it can also be expressed in terms of numbers in the case of the UK respectively.

What are the Risks of Non-Compliance?

(Why should you even care about complying with labelling requirements?)
If You don’t comply with the labelling requirements, then it can have the following consequences:
  • High Fines and Penalties 
  • Regulatory agencies can fine the manufacturer a heavy amount if it is found that the labeling is not as per the rules stated.
  • Legal Liability
  • In case any consumer is harmed or deceived due to noncompliance with the requirements, then the manufacturer will have to bear the heavy legal expenses and possible expense of compensation.
  • Limited Market Access
  • Non-compliance can result in limited market access. Also, there are risks of bad effects on the reputation of the brand, or the product can be recalled if found non-compliance at later stages,
    Hence it is important to be aware of the latest trends in labelling requirements and trust only the experienced and competent Label Review Partner to help you in rectifying the possible error in advance and avoid hefty fines or opportunity costs.

Cert3global ‘s Product Labeling Review

Cert3global‘s team of labelling experts has the attention to detail required to ensure that all mandatory compliance with country-specific requirements is adhered to. Coupled with technology-driven processes and data safety measures to ensure the full confidentiality of your products and documents.

Send us an inquiry to help us serve you in a better way and plan the successful launch of your cosmetic products in the EU or UK market.