How to ensure your cosmetics label compliance in the EU and the UK
Cosmetics sold in Europe and the UK, including their label, must comply with the local regulations. The requirements are:
- A PIF
- A compliant formula
- A compliant label
- A notification on the EU CPNP or SCPN portal
- A EU or UK Responsible Person
As BIORIUS has already introduced most of these topics, I invite you to check our dedicated publications. This article aims at clarifying the labelling requirements which make a compliant packaging and container.
Europe and the United Kingdom enforcing the strictest cosmetics regulations in the world, you might be surprised with the following standards. However, as our credo says: No compliant cosmetic, no market!
The EU/UK Responsible Person contact details
First of all, according to the article 4 of the Cosmetics regulations, “only cosmetics products for which a legal or natural person is designated within the community as Responsible Person shall be placed on the market”. Under this regulation, the respective Responsible Person in the EU and the UK must be clearly identified on the primary and secondary label, which means writing its name and address.
Various descriptive information about the cosmetic
Moreover, labelling requirements entail several technical information about the cosmetic:
- Country of origin
- Net weight
- Batch number
- INCI list
As other parts of the globe are requiring different mandatory information, you must take in account these disparities when establishing your international development strategy.
Precautions of use, warnings and product function
Besides, the precautions of use and warnings shall be on the label. They must be adapted to your cosmetic’s specificities. They often refer to the conclusions drawn during the making of your PIF or the development of your formula. They are linked to the product function, which must be clear if the name of the cosmetic is too evasive, and to undesirable effects imputed to its reasonably foreseeable use.
Mandatory translation in the EU
In the EU, the whole label does not need mandatory translation in the local language. Minimal legal requirements include:
- The nominal content (imperial units for the UK)
- The date of minimum durability and the PAO
- The warnings and precautionary use statements
- The function of the cosmetic product (not mandatory if obvious but to be translated if reported on the product label)
- The enclosed or attached leaflet, label, tape, tag or card if there is one
- The notice in immediate proximity to the container in which the cosmetic product is exposed for sale if any
As a result, claims can stay in English but translating them would be wiser according to some local cultures and their purchasing and decision-making process, which could be affected if claims are not clearly understandable by the average consumer. Indeed, not every European country is displaying a population fluent in English.
EU cosmetics national provisions
Eventually, legally binding national provisions are adding up to the EU Cosmetics regulation even though every European country are referring to it. France, Italy, Belgium, Germany, Romania… Many EU members have adopted specific regulations on labeling requirements, implying that having an EU compliant label is trickier than it seems to be. You will likely meet this same issue in other parts of the world such as the ASEAN for instance.
How BIORIUS can help you
Thus, labelling requirements in the EU and the UK are numerous and strictly regulated. A compliant label being mandatory for a legal commercialization, brands must make sure that their packaging and containers follow the official standards. To comply with regulations on both the European/UK level and the local country level is a must. New laws are adopted every year, and to keep track of all of them in every European country is a complex task.
You can count on BIORIUS to check your label’s compliance in Europe and the UK. Moreover, our experts conduct a 24/7 legal monitoring if BIORIUS is your Responsible Person. Moreover, we also have a national provisions service if you need assistance.