EU Label Compliance

By category

Cosmetics labelling in the EU: responsible person, INCI, PAO and batch

Cosmetics have their own regulation, their own responsible person and their own ingredient language. Almost nothing from the general regime transfers unchanged.

Example of the label this guide describes
Fac-simile of the file we deliver. Specimen data, invented company.

The mandatory fields

Name and address of the responsible person established in the Union. Nominal content. Date of minimum durability or the period-after-opening symbol. Particular precautions for use. Batch number. Function of the product. The ingredient list in INCI nomenclature, headed 'Ingredients'.

All of it on the container and the outer packaging, with narrow exceptions where size makes it impossible and a leaflet with the book-and-hand symbol takes over.

INCI, not marketing names

Ingredients appear under their INCI names in descending order of weight, with perfumes and aromatic compositions declared as such and allergens named where the thresholds apply. 'Aqua', not 'purified spring water'.

What a QR code can and cannot do

As the regulation stands, a data carrier cannot replace any of the eight mandatory fields. It may add information — the full allergen detail, a usage video — but the batch number, the responsible person's address, the PAO symbol and the ingredient list stay printed.

What we produce

A container layout and an outer packaging layout carrying every mandatory field with the correct symbols, plus the leaflet version where the container is too small, in the languages of the markets you sell in.

Claims are regulated too

Cosmetic claims follow common criteria: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. 'Dermatologically tested' without a test is a claim problem before it is a label problem.

Free-from claims are heavily restricted, and claims denigrating legally permitted ingredients are not allowed. This bites hardest on natural and organic positioning.

Period after opening and durability

Products with a minimum durability of more than thirty months carry the open-jar symbol with the number of months. Products below that carry a best-before date with the hourglass symbol or the words.

The two are alternatives, not decorations, and the choice follows the stability data in the product information file.

Nanomaterials and allergens

Ingredients present as nanomaterials are followed by '[nano]' in the ingredient list. Fragrance allergens above the thresholds are named individually rather than hidden inside 'parfum'.

Both are the kind of detail an authority checks quickly because it needs no laboratory: it is either printed or it is not.

The mandatory fields

FieldContainerOuter packaging
Responsible person name and addressRequiredRequired
Nominal contentRequiredRequired
Durability or PAO symbolRequiredRequired
Precautions for useRequiredRequired
Batch numberRequiredWhere space allows
Function of the productRequiredRequired
Ingredient list (INCI)Where space allowsRequired

How the pieces fit

The same information, in the order an inspector or a reviewer meets it.

The mandatory fields1Responsible person name and address2Nominal content3Durability or PAO symbol4Precautions for use5Batch number

Words that keep coming up

INCI
International Nomenclature of Cosmetic Ingredients, the naming system used in the list.
PAO
Period after opening, shown as an open-jar symbol with a number of months.
PIF
Product Information File, held by the responsible person and made available to authorities.
CPNP
The Commission's notification portal for cosmetic products.

Questions people ask

Do you act as my cosmetics responsible person?

Not under this service. We produce the artwork; the cosmetics responsible person is a separate legal role with a product information file behind it.

Is the CPNP notification part of this?

No. Notification is a separate obligation and it belongs to the responsible person.

Can I print the ingredient list only on the box?

Only where the container genuinely cannot carry it, and then the rules on leaflets and symbols apply.

Can the ingredient list go on a leaflet?

Only where the container and packaging genuinely cannot carry it, with the book-and-hand symbol.

Is the batch number needed on a 5 ml sample?

Yes, and where space is impossible it moves to the outer packaging.

Do you handle CPNP notification?

No. It belongs to the responsible person and is outside this service.

Related guides

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