An inherent part of every cosmetic product is its packaging and the label placed on it. These elements are the first to catch the eye of a potential buyer. Properly designed, they can make a particular cosmetic stand out among many similar ones on the store shelf. At the same time, the label is the element subjected to thorough inspection.
Cosmetic manufacturers, aiming to distinguish themselves in an increasingly vast market of products, strive to design labels that capture consumers’ attention. Do they have complete freedom in creating the label? Can they write/place anything on it?
First and foremost, it must be remembered that every piece of information placed on the cosmetic label must be true, and every consumer has the right to reliable information about the cosmetic they intend to purchase. Therefore, a correctly developed label should serve as a trustworthy source of information for the consumer.
Two groups of information are to be distinguished on the label – mandatory, obligatory for every cosmetic, and non-mandatory, mainly added to enhance the attractiveness of the product. Regulation (EC) No 1223/2009 provides guidance on what information must unequivocally be included on the label, specifically Article 19. According to it, the mandatory components of a cosmetic label are:
- Name and details of the responsible person, and in the case of imported products, their country of origin. The responsible person guarantees the compliance of the cosmetic with the specified requirements, hence their easy identification is necessary. Moreover, for imported products, a responsible person with a registered office in the European Union must be designated.
- Nominal quantity of the cosmetic in the packaging at the time of packaging. It is expressed in mass units (for solid, semi-solid, or semi-liquid products) or volume units (for liquid products). Exceptions may be packaging with a content of less than 5 ml or 5 g, free samples, or single-use packaging like sachets. When indicating the nominal quantity, guidelines in Annexes 1 and 2 to the Minister of Economy Regulation on specific labeling requirements for packaged goods should be followed.
- Minimum durability date and/or PAO (Period After Opening) indication. The minimum durability date is the time during which a cosmetic product, stored under appropriate conditions, fully maintains its properties. PAO, on the other hand, is the time in which a cosmetic can be safely used, starting from its first opening, or opening according to the intended use. For cosmetics with a shelf life determined, for example, through microbiological tests of 30 months or less, the minimum durability date is provided. If the durability of the cosmetic exceeds 30 months, the PAO symbol usually appears on the packaging. There are exceptions, such as single-use or air-tight packaging.
- Special precautions. These cover various groups of cosmetics, e.g., sun protection products or aerosols.
- Batch number or other identifier that allows quick identification of a single product or an entire batch. This is crucial in the case of complaints or the need to withdraw a specific batch from the market. Regulations do not specify the method of labeling or its placement on the packaging, so its location can vary.
- Qualitative composition. All ingredient names are provided according to the International Nomenclature of Cosmetic Ingredients (INCI), valid throughout the European Union. Additionally, this list should be preceded by the word “Ingredients.”
- Cosmetic product function (except when it is explicitly evident from the presentation of the cosmetic product). The function of the cosmetic should not exceed the definition given in Regulation (EC) No 1223. It can be included in the product name, e.g., firming body lotion, in the product’s usage instructions, or through a pictogram.
Non-mandatory elements include marketing descriptions, information about the material from which the packaging is made or its recyclability, declarations of the natural or organic nature of the cosmetic. All of these may appear on the label but are not obligatory, and if they do, they must be true and supported by appropriate evidence. Article 20 of Regulation (EC) No 1223 emphasizes, “On the label, during the placing on the market and advertising of cosmetic products, text, names, trademarks, images or other signs are not used to attribute to these products features or functions they do not possess.”
In conclusion, meeting all requirements regarding the correctness of the label enables any average consumer to make a decision about purchasing a particular cosmetic without being misled.
The Packaged Goods Act of 7 May 2009 on pre-packaged goods
Regulation (EC) No 1223/2009 of the European Parliament and of the Council
Regulation of the Minister for the Economy of 20 July 2009 laying down detailed requirements for the marking of pre-packaged goods
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