The importance of adapting the label to the european market

If you want to import your cosmetic products into the European market, one of the steps you shouldn't neglect is adapting the label in accordance with European guidelines.

This is an extremely important step as it is linked to consumer safety. In a society where consumers are more informed and aware of the safety of the products they use, and with an ever-increasing diversity of products available on the market, standardized requirements, based on ethical communication principles, with perceptible and indelible language are essential.

What are the mandatory labeling requirements?

According to Article 19 of Regulation (EC) No. 1223/2009, cosmetic products may only be made available on the market if their container and packaging bear the following information in indelible, easily legible, and visible characters:

1. Name/firm and address of the Responsible Person (RP) in the European Union;

2. Country of origin of the imported cosmetic products;

3. The nominal content at the time of packaging;

4. The Date of Minimum Durability (DMD) and/or the Period After Opening (PAO) until which the cosmetic product, stored under appropriate conditions, continues to fulfill its initial function;

5. Precautions of use;

6. The manufacturing batch number or reference identifying the cosmetic product;

7. The function of the cosmetic product, unless it’s clear from its presentation;

8. A list of ingredients with the following characteristics, among others:

• Preceded by the term "ingredients" (in English)

• In descending order of the weight of the ingredients at the time of their incorporation into the cosmetic product; Ingredients with a concentration of less than 1 per cent may be listed, in no particular order, after those with a concentration of more than 1 per cent

• Ingredients expressed using the common ingredient names established in the Glossary of Common Ingredient Names, which takes into account the International Nomenclature of Cosmetic Ingredients (INCI)

The law of the Member State in which the product is made available to the end user determines the language in which the above information must appear.

What about product claims?

The suitability of the label also involves a review of the product claims, whether they are in text, names, brands, images or other signs, figurative or not, and can cause some controversy.

Product claims can indeed have an impact on consumer choice at the time of purchase. However, they play a significant role in users' lives, and it’s important to ensure that the information transmitted to them is useful, understandable and reliable, enabling them to make informed decisions and choose the products that best suit their needs and expectations.

For this reason, Regulation (EU) No. 655/2013 was published, establishing common criteria for the justification of claims relating to cosmetic products. This regulation is based on 6 pillars:

1. Legal compliance;

2. Veracity;

3. Supporting evidence;

4. Honesty;

5. Impartiality;

6. Informed decision-making.

Furthermore, it is important to emphasize that claims also have a major impact on the product's legal framework. In other words, the definition of a cosmetic product described in Regulation (EC) No. 1223/2009 must always be present, as there may be a risk that the product could be subject to other types of legislation (for example, classification as a medical device).

Do you need help adapting the label of your cosmetic product? Our specialized team can help you complete this important step!