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Cosmetic labelling protects the consumer, provides the manufacturer with legal certainty and builds brand credibility. Let’s take a look at what must be included on the label, which rules apply in the EU and which errors most frequently occur in practice.
When manufacturing cosmetics, it is not enough to have a good formulation, nice packaging and a pleasant fragrance. If you want to place a cosmetic product on the market, it must be correctly labelled in accordance with the applicable European legislation.
The label is not just a design element. It is an important part of the product’s legislative responsibility, safety and credibility.
On it, the consumer looks for the composition, expiry date and the name of the responsible person for the product. Control authorities, on the other hand, verify whether the product complies with all EU rules — and here the brand has the first moment where legal obligation meets the visual first impression.
For the manufacturer, the label is a small but very important space. It must clearly tell the customer what the product is, how it is used, who is responsible for it, what its composition is, until when it is safe to use it and what to watch out for.
In the European Union, the labelling of cosmetic products is governed in particular by Regulation (EC) No 1223/2009 of the European Parliament and of the Council on cosmetic products. Article 19 lays down which information must appear on the container and packaging of a cosmetic product, and this information must be indelible, easily legible and visible. The list of ingredients must be expressed using common ingredient names according to the glossary under Article 33; if no common name exists, a term from a generally accepted nomenclature is used.
Contents of the article
The label has to look good, but first and foremost it must function correctly. It must comply with the formulation, the safety assessment, the product documentation and the requirements of the market on which the product is sold.
It is therefore not enough to design nice graphics and add a few attractive sentences. For a cosmetic product, the manufacturer must also deal with mandatory information, correct ingredient names, allergens, shelf life, batch, warnings, label language and physical legibility on the specific packaging.
“A good label must be truthful, legible, indelible, visible, comprehensible and in line with the composition of the product as well as with cosmetic legislation."
A correctly labelled cosmetic product must contain several mandatory items of information. Some of the data help the consumer when using the product, others are important for traceability, safety and control of the product.
The date of minimum durability is used when a cosmetic product has a minimum durability of 30 months or less.
For products with longer durability, a PAO symbol is generally used, i.e. the period after opening during which the product is usable, for example 6M, 12M or 24M, if this information is relevant for the given type of product.
Nominal content is the amount of product at the time of packaging. For cosmetics it is most often stated in millilitres or grams.
Examples:
For very small packs, single-use products or free samples, the nominal content does not always have to be stated. However, the manufacturer should distinguish between practical filling and legislative labelling.
Note for the manufacturer
When dosing products, check the technical tolerances and rules for quantity control. For pre-packaged products in the EU, they are governed in particular by Council Directive 76/211/EEC, which lays down the tolerable negative deviations according to the nominal quantity of the product.
For the manufacturer, a simple rule follows from this: the nominal content must not be an estimated quantity or “filled to the top”. It is an exact declared value which must be based on the actual filling process and must correspond to the quantity of product stated on the label.
The list of ingredients of a cosmetic product is indicated in the following format:
Ingredients: Aqua, Glycerin, Prunus Amygdalus Dulcis Oil, Cetearyl Alcohol, Parfum, Tocopherol, Linalool, Limonene.
The word Ingredients: is important and is not translated; it has the same form in all languages. It is followed by a list of ingredients according to the INCI system, i.e. the International Nomenclature of Cosmetic Ingredients or the common ingredient names used for the labelling of cosmetic products.
Ingredients are stated according to their total proportion in the product at the time of being added to the formulation. Ingredients with a higher content are listed at the beginning. Ingredients with a concentration lower than 1% may be listed in any order after the ingredients with a concentration above 1%.
Tip for formulators
When calculating the composition, it is not enough to look only at the trade name of the raw material as a whole. Many cosmetic raw materials are mixtures of several substances and, when compiling the Ingredients list, it is necessary to work with their individual INCI components.
Typical examples can be preservative systems, solubilisers, emulsifiers, plant extracts in a carrier, active complexes or commercial blends which contain several INCI ingredients. If such a raw material is used in the formulation, its trade name is not included in the final Ingredients list, but rather its individual INCI components according to the labelling rules.
For the correct ordering of ingredients, it is therefore necessary to know not only the dosage of the raw material in the formulation, but also its internal composition. The manufacturer should base this on the supplier’s technical documentation, in particular on the specification, technical data sheet, INCI breakdown and the available information on the content of the individual ingredients in the raw material.
Practically, this means that if, for example, you use 3% of a commercial blend consisting of several INCI ingredients, each of these ingredients may have a different actual proportion in the final product. This proportion is then important for the correct compilation and ordering of the Ingredients list.
At the same time, not all substances present in the technical documentation of a raw material must automatically be stated on the label. Impurities in raw materials and auxiliary technical substances which are not present in the final product are not considered ingredients according to Article 19 of Regulation 1223/2009. In borderline cases, it is therefore appropriate to base the decision on the supplier’s documentation and the assessment of the person responsible for placing the product on the market.
The INCI name is not a marketing name, a Slovak name or an English translation. It is a standardised nomenclature which makes it possible to identify the same ingredient across different countries and languages.
For plant-based raw materials, the INCI name often derives from the botanical, i.e. Latin, name of the plant. Therefore, for example, almond oil is not listed as Almond Oil in the Ingredients list, but as Prunus Amygdalus Dulcis Oil. The particular plant part used and the form of the raw material are also important.
Correct names should preferably be checked in the CosIng database or in the current glossary of common ingredient names of the European Commission. CosIng makes it possible to search for substance names according to cosmetic legislation, ingredient names used for labelling purposes, as well as CAS and EC numbers. The database also distinguishes current entries labelled as active and historical entries labelled as not active.
We deal with this topic in more detail in a separate article INCI, CAS and EC number: how to navigate cosmetic ingredients.
Colourants are not listed in the ingredients list as “pink colourant”, “blue colour” or “red pigment”. At the same time, their INCI name in terms of composition is not used for them. For cosmetic colourants, the designation using a CI number, that is, a Colour Index number, is used. It is the CI number that serves as the standardised designation of the colourant in the Ingredients list.
Colourants can be listed at the end of the ingredients list. For decorative cosmetics that come in several shades, it is also possible to use the designation may contain or +/-, if this corresponds to the specific product and its composition.
The fragrance can be listed in the ingredients list as:
The manufacturer can decide whether to indicate the perfume or aromatic composition using the general designation Parfum or Aroma, or whether to break down some fragrance components in more detail. However, it is important that mandatory allergens cannot be hidden under the word Parfum.
If the product contains regulated fragrance allergens above the specified limits, they must be stated separately in the ingredients list. This applies to allergens regardless of their source, i.e. not only to fragrance compositions, but also to essential oils or plant extracts.
In cosmetics we increasingly encounter the designation % NOI, i.e. the percentage of ingredients of natural origin. This is information intended to show the customer what part of the product comes from natural or naturally derived raw materials according to the calculation methodology used.
NOI can be a useful piece of information, but the manufacturer should handle it carefully. It is not enough to write a high percentage of natural origin on the label without it being clear which methodology was used for the calculation and whether this information is verifiable.
When calculating % NOI, it is necessary to start from the exact formulation composition, the documentation of the individual raw materials and the data from suppliers. For compound raw materials, it is necessary to take into account which substances they consist of and what proportion of them can be considered natural or naturally derived according to a specific standard or calculation methodology.
It is important to distinguish between a claim of natural origin and certified natural or organic cosmetics. A high % NOI alone does not mean that the product is certified as ORGANIC, organic, COSMOS Organic or another certified standard.
Practical note
If the manufacturer states the percentage of ingredients of natural origin on the label or in marketing communication, they should be able to substantiate this information. The calculation should be consistent, verifiable and based on the documentation for the raw materials used. Standard ISO 16128-2 provides a framework for determining the natural, naturally derived, organic and organically derived content of cosmetic products, but at the same time it does not address product communication, label claims or regulatory requirements for cosmetics.
Various symbols, logos and marks often appear on cosmetic labels. Some are just graphic icons, others represent independent certifications or verified standards. For the manufacturer, it is important to know that a certification logo cannot be added to the label just because it fits the design or appears trustworthy.
Certification marks such as COSMOS, Ecocert, EU Ecolabel, Leaping Bunny and others are bound to specific rules, an approval process and control by the certification body. Certification is governed by the rules of the specific standard and cannot be replaced by your own marketing statement.
For cosmetics, it is necessary to distinguish between the general marketing impression and certified labelling. The word ORGANIC or organic should not be used freely by the manufacturer just because the product contains a plant oil, extract or ingredients that appear natural.
In order for a product to bear the logo of a certification body, it must meet the rules of the specific standard and undergo the certification process.
In the certification of organic and natural cosmetic products, the following are usually assessed, for example:
Practically, this means: the manufacturer cannot use the certification logo if they do not have valid certification. Likewise, they should not create the impression of certified ORGANIC cosmetics if the product only meets the brand’s internal or marketing criteria.
The label may also contain its own graphic icon, for example “vegan”, “natural”, “handmade” or “eco packaging”. However, such designations must be truthful, comprehensible and must not be misleading.
If the label contains symbols that resemble certification, the manufacturer should have clearly documented what they mean and on what basis they are used.
A QR code can be a very good supplement to the label. It can lead to extended information about the product, explanations of ingredients, instructions, videos, recommendations for recycling or other educational materials.
However, it should not be understood as a simple replacement for mandatory information.
Mandatory information must be accessible in a way required by cosmetic legislation. If, for practical reasons, it is not possible to state some information directly, it may be given, for example, on an enclosed or attached leaflet, label, tape, tag or card.
Manufacturers most frequently make mistakes in details which, however, can be very important during inspection or sale.
A correct label is not a formality that can simply be added shortly before printing. It is the result of the formulation, the safety assessment, legislative requirements, the packaging solution and responsible communication.
For the manufacturer, a well-prepared label is both protection and a sign of professionalism. For the customer, it is proof that the product has a clear origin, composition, method of use and a responsible person.
A good label does not appear overcrowded, does not hide important information and does not try to replace facts with nice icons. A good label helps the product to appear trustworthy and gives the customer exactly the information they need.
According to Regulation 1223/2009, the label must contain the name or function of the product, the name and address of the responsible person, the nominal content, the date of minimum durability or the PAO symbol, particular precautions, the batch number, the list of ingredients in the Ingredients: format and indicated allergens above the specified limits.
The date of minimum durability is stated when the product has a durability of 30 months or less. For a longer durability, a PAO symbol is usually used — the period after opening during which the product is usable (for example 6M, 12M, 24M), if this information is relevant for the given type of product.
The ingredients are indicated according to the INCI system and are ordered according to their proportion in the product at the time of being added to the formulation. Ingredients with a higher content come first. Ingredients under 1% can be listed in any order after the ingredients above 1%. For compound raw materials, their trade name is not given, but their individual INCI components.
No. The word ORGANIC or organic should not be used freely by the manufacturer just because the product contains a plant oil, extract or ingredients that appear natural. To use the logo of a certification body, the product must meet the rules of a specific standard (for example COSMOS, Ecocert) and undergo the certification process.
Generally no. A QR code is a suitable supplement for extended information, instructions or recommendations for recycling, but the mandatory information must be physically available — on the packaging, an enclosed leaflet, tape, tag or card in accordance with the labelling rules.
Colourants are indicated using a CI number (Colour Index). Mica is, for example, CI 77019, titanium dioxide CI 77891, red iron oxide CI 77491. For decorative cosmetics with several shades, the designation may contain or +/- may be used.
% NOI is the percentage of ingredients of natural origin in the product. This information can be used if it has been calculated according to a clear methodology (for example according to the ISO 16128-2 framework) and the manufacturer can substantiate it with documentation for the raw materials. A high % NOI, however, does not automatically mean certified ORGANIC or organic cosmetics.
