September 2024: Introduction to Cosmetic Labels

Cosmetic labels are more than just decorative features; they provide critical information about product safety, ingredients, and usage instructions. These labels are regulated differently across various global markets, reflecting each region’s approach to consumer protection, safety, and transparency. Understanding the unique labeling requirements in markets like the EU, UK, and USA is essential for manufacturers who want to ensure compliance and maintain consumer trust.

Understanding Cosmetic Labels

Cosmetic labels serve multiple functions, including informing consumers about the product’s content, providing instructions for safe use, and highlighting any warnings or precautions. Key elements typically found on cosmetic labels include the principal display panel, ingredient list, net quantity, and manufacturer’s details. However, the specific regulations governing these elements vary significantly between major markets.

Key Differences in Cosmetic Labeling Regulations:

1. United States (USA)

   • Regulatory Authority: In the USA, the Food and Drug Administration (FDA) regulates cosmetic labeling under the Federal Food, Drug, and Cosmetic Act (FD&C Act) and the Fair Packaging and Labeling Act (FP&L Act).
   • Principal Display Panel (PDP): The PDP is the part of the label that consumers see first, usually the front of the package. It must include the product’s identity and net quantity of contents, adhering to specific guidelines for text size and placement to ensure readability.
   • Ingredient Listing: All ingredients must be listed in descending order by weight using their common names. Special requirements apply to products containing over-the-counter (OTC) drug ingredients, such as sunscreens or acne treatments, which must include a drug label section with active ingredients and specific usage instructions.
   • Warnings and Safe Use Directions: Cosmetic labels must include warnings when necessary, such as allergy alerts for products containing certain fragrances. The FDA also mandates that labeling information be prominently displayed and easily readable under normal purchasing conditions.
   • Marketing Claims: The FDA does not pre-approve cosmetic labels, and claims like “natural” or “cruelty-free” are generally unregulated. However, misleading claims can result in enforcement actions, emphasizing the need for manufacturers to ensure all statements are truthful.

2. European Union (EU)

   • Regulatory Authority: The EU regulates cosmetic products through the Cosmetic Products Regulation (Regulation (EC) No 1223/2009), which sets stringent labeling requirements designed to ensure product safety and consumer transparency.
   • Mandatory Labeling Information: EU regulations require that labels include the product’s name, list of ingredients, nominal content, date of minimum durability (if less than 30 months), and specific safety instructions. The label must also include the name and address of the ‘responsible person’ within the EU who ensures the product complies with all relevant regulations.
   • Ingredient Listing: Ingredients are listed using the International Nomenclature of Cosmetic Ingredients (INCI) names, ordered by weight. Specific allergens must be disclosed if present above certain thresholds, offering consumers clear information about potential allergens.
   • Batch Number and Traceability: EU labels must include a batch number for traceability, a critical aspect for recalls and consumer safety.
   • Claims and Marketing Terms: Product claims such as “hypoallergenic” or “dermatologically tested” are subject to strict regulation, requiring scientific evidence to support such statements. The EU also closely monitors marketing claims to prevent misleading consumers​.

3. United Kingdom (UK)

   • Regulatory Authority: Following Brexit, the UK established its own Cosmetic Products Enforcement Regulations 2013, closely mirroring EU rules but with specific differences to accommodate the UK market.
   • Labeling Requirements: UK labeling requirements align with the EU, including the need for INCI ingredient listings, warnings, and the address of the responsible person within the UK. All products sold in the UK must list the UK Responsible Person rather than an EU one.
   • Product Notification: Manufacturers must register their products with the UK’s equivalent of the EU’s Cosmetic Product Notification Portal (CPNP), ensuring proper safety documentation and market traceability.
   • Potential Divergence: While UK regulations currently align closely with EU standards, there is the potential for future regulatory divergence, which may affect labeling practices, permissible claims, and ingredient safety assessments.

4. Other Key Markets

   • China: Cosmetic products must meet strict Chinese regulations, including mandatory animal testing for most products, Chinese language labeling, and pre-market approval for many product types. China’s regulatory environment often necessitates different product formulations and labeling strategies.
   • Japan: Japan enforces stringent labeling laws, requiring clear ingredient disclosure and safety claims, especially for products like hair dyes or sunscreens that pose higher risks.
   • Canada and Australia: Both markets follow similar regulatory frameworks to the EU, focusing on safety, transparency, and clear ingredient disclosures, but with local nuances that companies must consider when entering these markets.

Conclusion

Cosmetic labeling regulations across major markets like the USA, EU, and UK reflect each region’s commitment to consumer safety, transparency, and product quality. Understanding and adhering to these diverse regulations is crucial for cosmetic manufacturers aiming for global market access. By ensuring compliance with each market’s unique standards, companies can build consumer trust, avoid costly regulatory pitfalls, and successfully expand their product reach.

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