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The labelling of cosmetics protects the consumer, gives the manufacturer legal certainty and builds the brand’s credibility. Let’s look at what must be mandatory on the label, which rules apply in the EU and which errors occur most frequently in practice.
For cosmetic manufacture, it is not enough to have a good formula, 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 regulatory responsibility, safety and credibility of the product.
The consumer looks for the composition, the date of durability and the name of the person responsible for the product. The control authorities, in turn, verify whether the product meets all EU rules — and this is the first moment where the brand encounters the legal obligation and 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 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 particulars must appear on the container and packaging of a cosmetic product and requires that they be indelible, easily legible and visible. The list of ingredients shall be expressed using the common ingredient names set out in the glossary referred to in Article 33; where no common ingredient name is available, a term from a generally accepted nomenclature shall be used.
Contents of the article
The label has to look good, but first and foremost it has to work correctly. It must be consistent with the formula, 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 attractive graphics and add a few appealing sentences. For a cosmetic product, the manufacturer must also deal with the mandatory particulars, correct ingredient names, allergens, durability, batch, warnings, the language of the label and physical legibility on the specific packaging.
“A good label has to be truthful, legible, indelible, visible, understandable and in line with the composition of the product as well as cosmetic legislation.”
A correctly labelled cosmetic product must contain several mandatory particulars. Some of them help the consumer during use, others are important for traceability, safety and control of the product.
The date of minimum durability is used where a cosmetic product has a minimum durability of 30 months or less.
For products with a longer durability, the PAO symbol is usually stated, that is, the period after opening, for example 6M, 12M or 24M, where this is relevant for the product type concerned.
The nominal content is the quantity of product at the time of filling. 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 the regulatory declaration.
Note for the manufacturer
When determining the fill quantity, check technical tolerances and the rules for quantity control. For pre-packaged products, these are governed in the EU in particular by Council Directive 76/211/EEC, which sets out the permitted negative errors according to the nominal quantity of the product.
For the manufacturer, this leads to a simple rule: the nominal content must not be an estimated amount or “filled to the top”. It is an exact declared figure that has to be based on the actual filling process and has to correspond to the quantity of product stated on the label.
The list of ingredients of a cosmetic product is given in the 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 the list of ingredients according to the INCI system, that is, the International Nomenclature of Cosmetic Ingredients, or the common ingredient names used for the labelling of cosmetic products.
Ingredients are listed according to their total proportion in the product at the time they are added to the formula. Ingredients with higher content are listed at the beginning. Ingredients with a concentration of less than 1% may be listed in any order after ingredients with a concentration above 1%.
Tip for formulators
When calculating the composition, it is not always sufficient 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 drawing up the Ingredients list it is necessary to work with their individual INCI components.
Typical examples include preservation systems, solubilisers, emulsifiers, plant extracts in a carrier, active complexes or commercial blends that contain several INCI ingredients. If such a raw material is used in the formula, its trade name is not included in the final Ingredients list; instead, the individual INCI ingredients are listed according to the labelling rules.
To order the ingredients correctly, it is therefore necessary to know not only the dosage of the raw material in the formula, but also its internal composition. The manufacturer should rely on the supplier’s technical documentation, in particular the specification, technical data sheet, INCI breakdown and available information on the proportion of individual components in the raw material.
In practice 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 finished product. This proportion is then important for correctly drawing up and ordering the Ingredients list.
At the same time, not all substances present in the raw material’s technical documentation must automatically be declared on the label. Impurities in raw materials and technical auxiliary substances that are not present in the finished product are, according to Article 19 of Regulation 1223/2009, not considered to be ingredients. In borderline cases, it is therefore advisable to rely on the supplier’s documentation and on the assessment of the person responsible for placing the product on the market.
The INCI name is not a marketing name, a local language name or an English translation. It is a standardised nomenclature that 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, that is, Latin, name of the plant. That is why, for example, almond oil is not listed in the Ingredients list as Almond Oil but as Prunus Amygdalus Dulcis Oil. The specific part of the plant used and the form of the raw material are also important.
It is advisable to verify the correct names in the CosIng database or in the current glossary of common ingredient names of the European Commission. CosIng allows you to search for substance names under cosmetic regulation, ingredient names used for labelling purposes, and CAS and EC numbers. The database distinguishes between current entries marked as active and historical entries marked as not active.
We cover this topic in more detail in a separate article INCI, CAS and EC number: how to understand cosmetic ingredients.
Colourants are not listed in the ingredients list as “pink colourant”, “blue colour” or “red pigment”. Nor is their INCI name in the sense of their composition used. For cosmetic colourants, the designation by CI number, that is, 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, the designation may contain or +/- can also be used, where this corresponds to the specific product and its composition.
The fragrance may be listed in the ingredients list as:
The manufacturer may decide whether to list the perfume or flavour composition under 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 set limits, they must be listed separately in the list of ingredients. This applies to allergens regardless of their source, that is, not only fragrance compositions, but also essential oils or plant extracts.
In cosmetics, we are increasingly encountering the designation % NOI, that is, the percentage share of ingredients of natural origin. This is a figure 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 work with it carefully. It is not enough to put a high percentage of natural origin on the label without it being clear according to which methodology it was calculated and whether this figure is verifiable.
When calculating % NOI, it is necessary to start from the exact composition of the formula, the documentation of the individual raw materials and the information from suppliers. For composed raw materials, it is necessary to take into account what substances they consist of and what share of them can be considered natural or naturally derived according to the specific standard or calculation methodology.
It is important to distinguish between a claim about natural origin and certified natural or organic cosmetics. A high % NOI in itself does not mean that the product is certified as BIO, organic, COSMOS Organic or any other certified standard.
Practical note
If the manufacturer states on the label or in marketing communication the percentage of ingredients of natural origin, they should be able to substantiate this figure. The calculation should be consistent, verifiable and based on the documentation for the raw materials used. ISO 16128-2 provides a framework for determining the natural, natural origin, organic and organic origin content of cosmetic products, but it does not address product communication, claims on the label or regulatory requirements for cosmetics.
A variety of 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 simply be added to the label because it suits the design or looks trustworthy.
Certification marks such as COSMOS, Ecocert, EU Ecolabel, Leaping Bunny and others are tied to specific rules, an approval process and control by the certification body. Certification is governed by the rules of the particular standard and cannot be replaced by an in-house marketing statement.
For cosmetics, it is necessary to distinguish between the general marketing impression and the certified designation. The word BIO or organic should not be used freely by the manufacturer just because the product contains a plant oil, extract or naturally appearing ingredients.
In order for a product to bear the logo of a certification body, it has to meet the rules of the particular standard and pass through a certification process.
When certifying organic and natural cosmetic products, the following is usually assessed, for example:
In practice this means: the manufacturer cannot use a certification logo without having a valid certificate. Likewise, they should not give the impression of certified BIO cosmetics if the product only meets the brand’s internal or marketing criteria.
The label may also show an in-house graphic icon, such as “vegan”, “natural”, “handmade” or “eco packaging”. Such designations must be truthful, understandable and must not mislead.
If the label contains symbols reminiscent of 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 complement to the label. It can link to extended product information, explanations of ingredients, instructions, videos, recycling recommendations or other educational material.
It should not, however, be understood as a simple replacement for mandatory particulars.
Mandatory particulars must be available in the way required by cosmetic legislation. If for practical reasons it is not possible to state some particulars directly, they may be given, for example, on an enclosed or attached leaflet, label, band, tag or card.
Manufacturers most often make mistakes in details that can, however, be very important during inspection or sale.
A correct label is not a formality that can be added just before printing. It is the result of the formula, 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 responsible person.
A good label does not look overloaded, does not hide important information and does not try to replace facts with pretty 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 set limits.
The date of minimum durability is stated where the product has a durability of 30 months or less. For a longer durability, the PAO symbol — the period after opening (for example 6M, 12M, 24M) — is usually used, where this is relevant for the product type concerned.
Ingredients are listed according to the INCI system and ordered according to their proportion in the product at the time of addition to the formula. Ingredients with higher content are listed first. Ingredients below 1% may be listed in any order after ingredients above 1%. For composed raw materials, it is not the trade name that is stated, but the individual INCI ingredients.
No. The word BIO or organic should not be used freely by the manufacturer just because the product contains a plant oil, extract or naturally appearing ingredients. To use the logo of a certification body, the product must meet the rules of the particular standard (for example, COSMOS, Ecocert) and pass the certification process.
Generally no. A QR code is a suitable supplement for extended information, instructions or recycling recommendations, but mandatory particulars must be physically available — on the packaging, an enclosed leaflet, band, tag or card in accordance with the labelling rules.
Colourants are stated using the CI number (Colour Index). Mica, for example, is CI 77019, titanium dioxide is CI 77891, red iron oxide is CI 77491. For decorative cosmetics with several shades, the designation may contain or +/- may be used.
% NOI is the percentage share of ingredients of natural origin in the product. The designation can be used if it has been calculated according to a clear methodology (for example within the framework of ISO 16128-2) and if the manufacturer can substantiate it with documentation for the raw materials. A high % NOI does not automatically mean certified BIO or organic cosmetics.
