Labelling & Claims
The Cosmetic Regulation applies to finished cosmetic products, and sets up requirements for the brands who intend to place a cosmetic product on the European market. Two of the key steps of cosmetic compliance are making sure that the labels and claims of your cosmetic products are compliant.
What obligations for compliant labelling?
Article 19 of the European Cosmetic Regulation defines the rules for a compliant cosmetic label. The mandatory information that must be printed on the product in “indelible, easily legible and visible lettering” are:
- Name and address of the Responsible Person : for more information on this regulatory obligation, visit our page dedicated to the role of RP
- Country of Origin : Add the words “Made in XXXXX”, unless your product is manufactured in Europe, in which case this is not compulsory
- Nominal content : The nominal content must appear in grams (g) or milliliter (ml) and in first position. You can add additional measurement units if you wish (i.e. oz.)
- Date Of Minimum Durability (DOMD) & Period After Opening (PAO) : The DOMD is established by stability tests and the PAO by challenge tests
- Particular precautions of use and warnings
- Batch number : This is mandatory. No particular format is required.
- Product function : It must be clearly indicated so as to prevent any misuse.
- List of ingredients : In decreasing order of weight, except for ingredients below 1%
The hour-glass symbol. It illustrates the DOMD when the latter is equal or below 30 months. You must add the date next to the symbol.
If the DOMD exceeds 30 months, the open-jar symbol must indicate the PAO defined by the combination of the stability test and challenge test.
The hand-in-book symbol informs the consumer that a card, tag or leaflet is enclosed with the product with additional regulatory information.
Cosmetic claims are not only mentioned in Article 20 of Regulation 1223/2009, but also in the Regulation EC No. 655/2013 specifically dedicated to claims. The latter aims at ensuring that the information conveyed to the end users through claims is useful, understandable and reliable. Claims must enable the consumers to make informed decisions and to choose the product that best suits their needs and expectations..
What’s a cosmetic claim?
According to Article 1 of Regulation n°655/2013, claims are “texts, names, trademarks, pictures and figurative or other signs that convey explicitly or implicitly product characteristics or functions in the labelling, the making available on the market and advertising of cosmetic products”.
Cosmetic claims are used for:
- Describing the effects of a product
- Helping consumers/users choose a product
- Make the product seem more appealing than the competition
What are the rules to follow?
In order for cosmetic claims to be used, they have to comply with the following 6 common criteria:
- Legal compliance : any cosmetic product placed on the European market must be compliant with regulation 1223/2009.
- Véracité Truthfulness: claims regarding a product must not be based on false information.
- Evidential support : claims must be supported by adequate and verifiable evidence (experimental tests, consumer perception tests, use of published scientific data). It is the Responsible Person’s duty to determine the adequate supporting documents (in partnership with specialised laboratories)
- Honesty : claims must not go beyond the actual performance of the product
- Fairness : cosmetic products’ claims must “be objective and must not denigrate the competitors, or ingredients that are legally used”.
- Informed decision-making : claims must be clear and understandable to the average consumer
If you wish to know more on cosmetic claims, visit our article on the matter !