Cosmetic label requirements: Part I

May 05, 2021 – We present below several important elements (not all) that should appear on an EU compliant label of a cosmetic product.

Date of minimum durability

One extremely important element of every label is the ‘’Date of minimum durability’’ of the product. Based on Article 19 of the EU Cosmetics Regulation 1223/2009/EC, date of minimum durability is the date until which the cosmetic product, stored under appropriate conditions, will continue to fulfill its initial func­tion and, in particular, will remain in conformity with safety provisions of the Cosmetics Regulation.

There are two important differentiations in this context:

• Date of minimum durability, i.e. Expiry date of the product and
• PAO (Period-After-Opening)

Expiry date

For cosmetics with a minimum durability of less than 30 months, the date of minimum durability shall be clearly expressed either by using the symbol of the ‘’hourglass’’ (see below) or by indicating in words ‘best used before the end of’. It shall consist of either the month and year or the day, month and year, in that order.

XX/XXXX,  for ex. 12/2021

Date of minimum durability/ ‘’Hourglass’’ symbol

Do not forget that if you are not using the symbol, you shall translate the wording into the language(s) in the official languages of the European countries where you will sell the products!

PAO (Period-After-Opening)

Alternatively, indication of the date of minimum durability will not be mandatory for cosmetic products with a minimum durabil­ity of more than 30 months. In this case, the label must include an indication of the period of time after opening for which the product is safe and cannot cause any harm to the consumer. This information shall be indicated, except where the concept of durability after opening is not relevant, by the symbol in the picture below, followed by the period of time after opening for which the product is safe.

PAO symbol (with for ex. ‘’12M’’ affixed on the container)

Be aware that both symbols cannot co-exist on a single product.

Special cases

When a cosmetic product is for single use or is presented in an aerosol dispenser [therefore, where the concept of durability after opening is not relevant] and the minimum durability is of more than 30 months, the PAO symbol cannot be used.

In those cases, it is accepted that no symbol is used. However, in order for the old products not to be stockpiled on shelves, the manufacturer could exceptionally use the date of minimum durability approach, i.e., ‘’ hourglass symbol’’ or wording ‘best used before the end of’.

Ingredient list

Every label MUST have a list of ingredients. According to Article 19, the labelling must include the list of all the ingredients that are present in the formulation. Furthermore, there are some additional rules:

• All the ingredients must be listed in the descending order of concentration and preceded by the word ‘’Ingredients’’.
• Ingredients shall be indicated as per their INCI name appearing in the EU Glossary. When the INCI name is not available other known nomenclatures could be used, but this is to be avoided.
• Ingredients do not need to be translated, however any warnings related to the ingredients or special instructions for use shall. This in order to ensure safe use of the product, for ex. Contains Benzophenone-3 where ‘’contains’’ shall be translated in the language of the consumer to easily understand it.
• All the ingredients that have less than 1% do not have to follow the above-mentioned rule. These ingredients can be listed in any order; However, it is indisputable that they are indicated on the label.

There are two exclusions that do not fall under this rule:

• Impurities and traces. If a certain ingredient is present in the product as only an impurity or a trace, then it does not have to be indicated on the label.
• Only allergens that have a certain concentration in the final product must be indicated on the labelling.

Language requirements

According to EU Cosmetics Regulation 1223/2009/EC, certain information are minimal legal requirements for EU labelling. These are the information that must be translated in the official language(s) of the country in which the product is sold.

• The nominal content at the time of packaging, given by weight or by volume;
• Date of minimum durability;
• Precautions;
• The function of the cosmetic product (unless it is clear from its presentation, for ex. nail polish, lipstick)

However, Obelis as EU Responsible Person always advise to translate the entire label/packaging. In fact, some national authorities may require additional requirements.

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